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Georgeson Monthly Roundup - January 2022
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Latest Georgeson publications

US: Georgeson memo about the 2022 Glass Lewis updates

Georgeson has published a memo entitled Glass Lewis 2022 U.S. Policy Updates.

“In November 2021, Glass Lewis published its 2022 Policy Guidelines containing updates, codifications and clarifications for policies relevant to U.S. companies. In addition, Glass Lewis also published updates to its global Environmental, Social & Governance ("ESG") guidelines which includes new policies, as well as codification and clarification of existing policies.”

Read the full report here.

In the news

US & Global: Georgeson’s Hannah Orowitz and Cas Sydorowitz were interviewed on The Corporate Counsel's podcast Inside Track with Liz.

“In this podcast, we discuss: 1) Expectations for the 2022 AGM season in the US, particularly considering the surprises we saw during the 2021 proxy and annual meeting season; 2) Early trends for shareholder proposals; 3) Changes in voting behaviour of traditional investors - and what they are most likely to focus on; 4) Whether the record-breaking level of negotiated proposals in the 2021 season is the 'new normal'; 5) How the new SEC guidance on Rule 14a-8 will impact shareholder proposals during the 2022 proxy season and beyond; 6) What impact COP26 and the formation of the International Sustainability Standards Board may have on companies in 2022; 7) Following COP26, there was a rapid uptake of asset managers signing The Net Zero Asset Managers Initiative, which includes BlackRock, Vanguard, States Street and at least 220 others. What might that mean for 2022?; 8) Predictions for activism in 2022, in light of environmental issues playing a role in a successful proxy contest, and activists' cooperation with NGO proponents (e.g., Ceres and As You Sow).; 9) Other parting thoughts and advice.”

See details here.

UK: Georgeson’s Domenic Brancati and Daniele Vitale were quoted in IR Magazine.

“Investors expected to continue less flexible approach to remuneration. This year there was an increase in contested remuneration policy votes and contested remuneration report votes, says Daniele Vitale, head of governance for UK/Europe at Georgeson. There was also an increase in director elections contested.”

Read the full article here.

Spain: Georgeson’s Carlos Saez was quoted in Revista Consejeros.

“There is a trend that claims that virtual meetings arouse some mistrust in the market because it is considered that they do not guarantee the exercise of the political rights of all shareholders, due to problems of access to technological means for minority shareholders. In Spain, we have been pioneers, as the possibility of telematic attendance at meetings has gone from being a matter of extraordinary necessity to a model for the future, as Spanish listed companies have begun to incorporate this method into their own internal rules for normal use", explains Carlos Sáez, Country Head of the proxy solicitor Georgeson for Spain.”

Read the full article here (pg 20).


US: Georgeson’s Hannah Orowitz and Don Cassidy spoke at a Latham & Watkins and Georgeson webcast about the 2022 Proxy Season: Considerations for Your Proxy Statement and Preparing for Your Annual Meeting.

“Latham & Watkins and Georgeson join together to discuss what public companies and their advisors should know, and be doing now, as we enter the 2022 proxy season. The second 60-minute program of the three-part proxy season webcast series covers the following topics: Executive compensation updates and proxy considerations; SEC and ESG updates; Proxy disclosure trends and drafting tips; Latest proxy advisor and investor policy updates: ISS, Glass Lewis and Institutional Advisors; Shareholder proposal highlights.”

See here for more information.

The Netherlands: Georgeson’s Ivana Cvjetkovic, Arun Kelshiker and Daniele Vitale spoke at a NEVIR event about ESG.

“NEVIR & ING are pleased to invite you to the virtual IR conference on Thursday January 20, 2022. During this online event we will bring you two interesting presentations on the current trending topics related to IR: ESG and the economic impact of the pandemic in 2022. Ivana Cvjetkovic (Head of Benelux - Georgeson), Arun Kelshiker (Head of Environmental and Social UK & Europe - Georgeson) and Daniele Vitale (Head of Governance UK & Europe - Georgeson) will open this conference on 'ESG themes for 2022' followed by Bert Colijn (Senior Economist Eurozone - ING), giving us an update on the economic impact of COVID-19.”

See here for more information.

Spain: Georgeson’s Claudia Morante and Carlos Saez spoke at a WomenCEO and Georgeson event about Boards of Directors facing the challenges of the New Economy.

Carlos presented a session entitled “The importance of remuneration within Boards of Directors” and Claudia moderated a panel about "New challenges for Boards of Directors”.

See here for more information.

Shareholder Activism
  • The Financial Times reports that Oil majors under pressure as activists circle: https://www.ft.com/content/0e5a0373-ee69-438a-9026-4588338f6ee4. “Over the past year activist investors have targeted oil supermajors ExxonMobil and Royal Dutch Shell, commodity giant Glencore and Scottish energy group SSE. Other institutional and retail investors have also pushed for change, voting in higher numbers than ever before for climate-related resolutions.”
  • Reuters reports that Activists behind Shell climate verdict target 30 multinationals: https://www.reuters.com/markets/commodities/activists-behind-shell-climate-verdict-target-30-multinationals-2022-01-13/. “The Dutch wing of environmental group Friends of the Earth, which won a landmark court case against Royal Dutch Shell last year, demanded 30 corporations publish plans for big cuts in greenhouse gas emissions in a campaign launched on Thursday. Milieudefensie has set its sights on large companies with legal bases in the Netherlands, where a court ruled in May that Shell must reduce its environmental footprint.”
  • Reuters reports that Analysis: Elliott, Ancora lead hedge funds in pushing for more women on boards: https://www.reuters.com/markets/europe/elliott-ancora-lead-hedge-funds-pushing-more-women-boards-2022-01-12/. “Elliott Management Corp and Ancora Advisors LLC led activist hedge funds in pushing for women to join corporate boards last year, as a Wall Street old boys’ network makes strides toward diversity. Activist investors who push for changes at companies shake up boards by putting slates of nominees to a shareholder vote or negotiating directly to add or remove directors.”
  • Bloomberg reports that Shareholder Activism’s Rebound to Confront Game-Changing Rules: https://www.bloomberg.com/news/articles/2021-12-29/shareholder-activism-s-rebound-to-confront-game-changing-rules. “Shareholder activism rebounded in 2021 but activists and defense advisers alike are bracing for regulatory changes that are likely to change how they do business for years to come. There were 220 campaigns launched against target companies with a market value of more than $1 billion by activist investors this year through Dec. 28, according to data compiled by Bloomberg. That was up about 20% from the 183 campaigns launched in 2020 but still below the 238 launched in 2019 prior to the coronavirus pandemic.”
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  • Vanugard has published a memo entitled Vanguard’s expectations for companies with significant coal exposure: https://corporate.vanguard.com/content/dam/corp/advocate/investment-stewardship/pdf/perspectives-and-commentary/Coal_1961823_122021.pdf. “Vanguard has explained its concerns about climate change and the financial risk it presents to long- term investors. We have outlined expectations for companies where climate change is a material risk: They should have climate-competent boards, robust climate risk oversight and mitigation measures, and effective climate risk disclosure. In this Insights, we focus on the risks that coal production and consumption can pose to long-term investors.”
  • The Financial Times reports about The search for climate-savvy board directors: https://www.ft.com/content/6eade3cc-2856-4a3f-bcff-8852e4d7ca04. “Three-quarters of board directors now consider climate change a central issue for their companies’ long-term success, according to a new global study by Insead business school and headhunter Heidrick & Struggles. Yet only half said that the subject was properly integrated into their business’s investment decisions, and the majority said their board still needed to increase its climate knowledge.”
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Pan-European developments
  • The Wall Street Journal reports that Some European Companies Struggle to Calculate How Much of Their Business Is Green: https://www.wsj.com/articles/some-european-companies-struggle-to-calculate-how-much-of-their-business-is-green-11640601009. “Many European companies are getting ready to tell investors how much of their revenue, capital investments and operating costs come from activities that regulators consider green. Starting on Jan. 1, publicly listed companies with more than 500 employees – those that fall under what’s known as the Nonfinancial Reporting Directive – will be required to disclose in their annual reports what percentage of their operations falls under the European Union’s green taxonomy. The classification system aims to give more clarity to investors on what types of economic activities can be considered sustainable. […] To come up with their disclosures, companies must map their business operations against a long list of criteria and then tabulate how much of their revenue, investments and costs stem from eligible activities. Many companies’ business models don’t fit neatly within the taxonomy criteria, which is making the disclosure process cumbersome, executives and sustainability advisors said, and raising the prospect that some companies may publish metrics that may make them look unflattering in the eyes of investors that focus on green companies.”
  • The Institute of Directors has published a policy paper entitled ‘ESG Priorities for UK Companies 2022’: https://www.iod.com/news-campaigns/news/articles/ESG-is-not-a-fad-but-an-urgent-business-priority-says-IoD. “Environmental, social and governance considerations are increasingly important decision-making criteria for all types of organisations – not only as a means of winning the trust of stakeholders but also as barometers of effective business management. The IoD provides a checklist of ESG priorities which are worthy of boardroom discussion in 2022, organised across the following key themes: Stakeholders and business purpose; Sustainability; Inclusion and Diversity; Governance; and, Executive remuneration.”
  • The 30% Club France Investor Group has published a report entitled Driving Gender Diversity in French Companies – The state of play in 2021: https://30percentclub.org/france-investor-group/. “In France, under the Copé-Zimmermann law, listed companies have been required to have a minimum of 40% of women on the Board of Directors since 2017. As a natural second step, gender diversity is expected to trickle down from the board to reach all executive management layers. As of mid-2020, women accounted for 21% on average of the main French-listed companies’ Executive Committees (SBF 120). Their roles are predominantly functional: only 12% of operational roles in SBF 120 Executive Committees are held by women. As investors, we believe both boards and executive management teams that genuinely embrace cognitive diversity, as manifested through appropriate gender representation and a broad spectrum of skills and experience, are more likely to achieve better outcomes for investors.” See the full report here: https://30percentclub.org/wp-content/uploads/2022/01/30Club_France_Diversity_Report_Final.pdf.
  • Eumedion has published a revised version of its Corporate Governance Manual: https://en.eumedion.nl/Latest-news/News/eumedion-publishes-revised-version-of-its-corporate-governance-manual.html. “Eumedion has updated its Corporate Governance Manual in response to the entry into force of new legislation and regulations and changes to its own voting guidelines. The previous version dated from 2017. The most important changes are the inclusion of the Stewardship Code and the impact of new statutory rules on shareholders' rights and obligations and on the voting items on the agendas of shareholders' meetings. In addition, the Eumedion recommendations with regard to the structure of executive remuneration have been amended on one point. As of 1 January 2022, Eumedion members expect Dutch listed companies that "a substantial part" of the variable remuneration elements is based on environmental, social and/or governance ('ESG') goals. Until now, the only 'recommendation' was that part of the variable remuneration was made dependent on the achievement of ESG objectives. Eumedion members use the Manual in determining their voting behaviour at the shareholders' meetings of Dutch listed companies. It is also used in Eumedion's decision-making process to alert its members to a controversial voting item on the shareholders' meeting agenda of a Dutch listed company."
  • The Ethos Foundation has announced that Ethos strengthens its sustainability expectations with its 2022 proxy voting guidelines: https://www.ethosfund.ch/en/news/ethos-strengthens-its-sustainability-expectations-with-its-2022-proxy-voting-guidelines. “The 21st edition of its proxy voting guidelines and corporate governance principles is an opportunity to strengthen the sustainability and diversity requirements of the Ethos Foundation. The criteria for approving a sustainability or a climate report submitted to shareholder approval have been detailed. In addition, the re-election of the chairperson of the sustainability committees of companies with high CO2 emissions whose transition plan is deemed unsatisfactory will be refused. Ethos has published this Thursday its proxy voting guidelines and corporate governance principles for 2022. […] On the other hand, and as already announced last year, Ethos stipulates that it will recommend opposing the re-election of the nomination committee’s chairperson – or the chairperson of the board of directors if such a committee does not exist – if the board of directors of the company does not include at least 20% of women.”
  • Les Temps reports about an Investigation into the culture clash that is tearing apart the powerful Sandoz Foundation: https://www.letemps.ch/economie/enquete-choc-culturel-dechire-puissante-fondation-sandoz (in French). “The Sandoz Family Foundation, one of the richest in Switzerland, is experiencing internal conflicts and the accumulation of positions that raise questions about its governance. The foundation told Les Temps that ‘any change provokes criticism’. This turmoil could have an impact on thousands of people.”
  • Il Sole 24 Ore reports about Tim, Carige and Civibank: those three ‘friendly’ IPOs suspended in limbo: https://www.ilsole24ore.com/art/tim-carige-e-civibank-quelle-tre-opa-amichevoli-sospese-limbo-AEN4Ie6 (in Italian). “The 2022 banking-financial year inherits from 2021 three ‘almost friendly’ Opa (or three almost friendly Opa): that of the KKR fund on Tim, that of Bper on Carige and the smaller one (but no less relevant for local politics) of Sparkasse on Civibank. All were self-described by the promoters as "friendly" and subject to the consent of the counterparty and/or prior due diligence on the accounts.”
  • Europa Press reports that CaixaBank, Telefónica and Enagás, among the Spanish companies honoured worldwide for their climate actions: https://www.capitalmadrid.com/2021/12/9/61252/caixabank-telefonica-y-enagas-entre-las-espanolas-distinguidas-a-nivel-mundial-por-sus-acciones-climaticas.html (in Spanish). “The Spanish companies CaixaBank, Telefónica, Enagás, Acciona, Ferrovial, Iberdrola, Cellnex, Inmobiliaria Colonial, Siemens Gamesa and Logista have obtained the highest rating in CDP’s annual climate action index by appearing on its so-called ‘A List’, which includes the 200 best companies in the world in the management of climate change out of the more than 12,000 companies assessed. CDP is a non-profit organisation that works with companies and governments to reduce greenhouse gases, protect forests and safeguard water resources.
  • Lawyerpress News reports that Repsol wins the Manuel Olivencia Award for Good Corporate Governance: https://www.lawyerpress.com/2022/01/19/repsol-gana-el-premio-manuel-olivencia-al-buen-gobierno-corporativo/ (in Spanish). “The Cuatrecasas Foundation, through an independent jury chaired by Matías Rodríguez-Inciarte, has decided to award the Manuel Olivencia Prize for Good Corporate Governance to distinguish the best governance practices of listed companies in Spain to Repsol. The award ceremony will be held on Thursday 17 March at the Palacio de la Bolsa de Madrid.”
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North America
United States
  • The Wall Street Journal reports that Costco Shareholder Vote Signals Focus on Supply-Chain Emissions: https://www.wsj.com/articles/costco-shareholder-vote-signals-focus-on-supply-chain-emissions-11643194803. “One of the year’s first shareholder votes on climate change points to a sharpened focus on supply chains among investors. Costco Wholesale Corp. shareholders voted Thursday for a proposal that called on the retailer to set out plans to reach net-zero greenhouse-gas emissions by 2050 or sooner, in line with scientific recommendations to limit global warming to 1.5 degrees Celsius. The resolution included difficult-to-track emissions in Costco’s supply chain, known as Scope 3 emissions, which the company said were the ‘overwhelming bulk’ of its emissions. The company’s board opposed the proposal. ‘While we seek and will continue to seek to influence our suppliers to reduce their emissions, we cannot directly control their actions,’ Costco said in its statement against the resolution. Shareholder resolutions aren’t legally binding in the U.S., but they can put pressure on companies to make changes and raise the possibility that investors could vote to remove executives if they refuse to take action.”
  • The Financial Times reports that Investors challenge concealment clauses at large tech groups: https://www.ft.com/content/61dead66-65cb-4e07-a12a-c079ff406aa1. “Seven of the largest US technology companies, including Alphabet, Amazon and Meta, are facing investor pressure to publish more information about their non-disclosure agreements and other concealment clauses in employment contracts.”
  • Time argues that One Lesson From the Theranos Scandal: We Need Age Diversity on Corporate Boards: https://time.com/6132551/corporate-board-diversity/. “These boards are also too old and out of touch, rife with industrial-era yes-men who are beholden to their CEOs and ill-equipped for the digital age. Among companies in the S&P 500, the average board director is 63 and trending older, according to research from The Conference Board. Too many of today’s corporate directors lack the relevant experiences to meaningfully oversee executive teams, spot early signs of overreach, or steward their companies through coming business challenges.”
  • The Wall Street Journal reports that All U.S. Trial Convictions in Crisis-Era Libor Rigging Have Now Been Overturned: https://www.wsj.com/articles/all-u-s-trial-convictions-in-crisis-era-libor-rigging-have-now-been-overturned-11643310178. “A federal appeals court reversed the convictions of two former Deutsche Bank AG traders found guilty of rigging a global lending benchmark, overturning one of the U.S. government’s highest-profile court victories linked to the 2008 financial crisis. The decision Thursday dealt a blow to the legacy of an investigation into which Washington poured resources after the financial crisis, when prosecutors were criticized for not pursuing enough cases against individual traders and executives. The cases focused on how traders and brokers world-wide influenced the daily London interbank offered rate, known as Libor, which helped set the value of lucrative derivatives they traded and made banks appear healthier than they were.”
  • Reuters reports that McDonald’s ex-CEO pays $105 million to settle lawsuit over relationships with employees: https://www.reuters.com/business/retail-consumer/mcdonalds-settles-lawsuit-with-ex-ceo-easterbrook-over-alleged-lies-about-2021-12-16/. “The former CEO of McDonald’s Corp paid over $105 million and apologized to the company in a settlement over the burger chain’s allegations that he lied to cover up sexual relationships with employees. As part of the settlement, ex-CEO Steve Easterbrook returned equity awards and cash worth over $105 million that he received as a severance package in 2019, McDonald’s said in a statement on Thursday. McDonald’s sued Easterbrook in August 2020, nine months after reaching a severance deal, claiming he never gave directors a complete picture of his relationships with employees. The company said that when it fired Easterbrook, it only knew of one non-physical consensual relationship with an employee. But an anonymous tip after his ouster led to the discovery of dozens of sexually explicit photos of women, including three employees, that Easterbrook sent to his personal email from his company account.”
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Hong Kong
  • The South China Morning Post reports that Hong Kong’s first carbon-focused fund eyes investments in projects to improve China’s climate-change ratings: https://www.scmp.com/business/china-business/article/3163454/hong-kongs-first-carbon-focused-fund-eyes-investments. “Hong Kong and China Gas Company, the city’s sole piped-gas supplier, plans to raise up to 10 billion yuan (US$1.6 billion) with a partner for a new fund focusing on decarbonization projects as China bolsters its ambitions of getting greenhouse emissions under control. The IDG Towngas Clean Energy Fund will become the first known of its kind by a Hong Kong blue-chip company as China, the world’s top carbon dioxide emitter, steps up efforts to meet its carbon neutrality goal by 2060. Its partner IDG Capital is a venture capital firm focused on Chinese businesses.”
  • The South China Morning Post reports that Sustainable finance: ‘greenwashing’ concerns raised as Hong Kong airport floats US$4 billion bonds package to fund growth, decarbonization: https://www.scmp.com/business/article/3162333/sustainable-finance-greenwashing-concerns-raised-hong-kong-airport-floats. “Concerns about ‘greenwashing’ have been raised by a climate campaign group after Airport Authority Hong Kong (AA), which operates the city’s international airport, raised US$4 billion by issuing a package of bonds that includes a US$1 billion five-year green bond. Greenwashing refers to sustainability benefit claims without clear, agreed definitions on sustainable investment, which could sometimes lead to a false impression of the overall environmental benefits. Greenwashing refers to sustainability benefit claims without clear, agreed definitions on sustainable investment, which could sometimes lead to a false impression of the overall environmental benefits.”
  • The South China Morning Post reports that SPAC backed by Chinese brokerage CMB International becomes first to file for Hong Kong listing, under new regime for blank-cheque companies: https://www.scmp.com/business/banking-finance/article/3163778/spac-backed-chinese-brokerage-cmb-international-becomes. “A special purpose acquisition company (SPAC) sponsored by the asset management arm of Chinese brokerage CMB International has applied to float its shares in Hong Kong, becoming the first to test a new listing regime which became effective this month. Acquila Acquisition Corp will offer shares at HK$10 each (US$1.28), it said in a heavily-redacted draft prospectus filed with the stock exchange on Monday. […] The city will only allow large SPACs that raise at least HK$1 billion (US$128 million) to list on its main board, the highest requirement among all exchanges.”
  • The South China Morning Post reports that Most ESG decisions by Hong Kong and mainland China executives primarily driven by compliance, PwC survey shows: https://www.scmp.com/business/banking-finance/article/3162805/most-esg-decisions-hong-kong-and-mainland-china-executives. “Hong Kong has raised the bar for banks, publicly listed companies, asset managers, and insurers to comply with ESG disclosure requirements by 2025. Under these rules, companies must add ESG factors to the financial metrics of their business operations in regulatory disclosures and consider both in strategic and capital allocation decisions. […] The survey, which was released at the Asian Financial Forum (AFF) on Monday, explored the perceptions of business leaders towards the prospect of ESG investing, and the role Hong Kong can play to facilitate future development in this area. […] ‘The vast majority still think failing to address ESG issues would bring adverse impacts or disruptions to their business,’ Elton Yeung, vice-chairman of PwC China, said at the AFF during the presentation of the survey. ‘This is a warning sign that despite recognizing the importance of ESG, many organizations are struggling to know what actions and decisions they should take.’”
  • Mint reports that Indian companies finally jump on the ESG bandwagon: https://www.livemint.com/companies/news/indian-companies-finally-jump-on-the-esg-bandwagon-11640194380818.html. “If there is one common thread that ran through the ambitions of Indian companies in 2021, it was a race to adopt environmental, social and governance (ESG) norms, following mounting pressure from investors and regulators. India ranks a lowly 120 among 165 countries in its progress towards achieving all 17 SDGs (sustainable development goals), lower than SAARC counterparts Sri Lanka, Nepal and Bangladesh.”
  • IiAS argues that Promoter CEO: A company’s most important asset: https://www.iiasadvisory.com/institutional-eye/promoter-ceo-a-company-s-most-important-asset. “Companies have been expressing their commitment towards ESG metrics over the past several months. Several have successfully demonstrated their commitment to the society at large during the COVID-19 crisis. Even so, the labour exodus, letting go of people, and asking staff to take pay cuts has had the harshest impact on corporate India. Several corporate leaders like Mukesh Ambani and Uday Kotak stood in solidarity, forgoing their remuneration and ensuring that their employees were put ahead of themselves. But corporate India is a contradiction at several levels, as it is here too: several promoters that put themselves ahead of their employees and increased their compensation despite the stress faced by their employees.”
  • Reuters reports that PTC India Financial shares slump after directors quit on corporate governance issues: https://www.reuters.com/markets/stocks/ptc-india-financial-tanks-17-after-directors-resign-corporate-governance-issues-2022-01-20/. “PTC India Financial Services Ltd (PFS) (PTCN.NS) shares fell more than 18% on Thursday in their worst day since May 2015 after three of its independent directors resigned, citing lapses in corporate governance. The non-banking financial company said on Wednesday evening that it had received resignation letters from directors Kamlesh Shivji Vikamsey, Thomas Mathew and Santosh Nayar. In his letter, Mathew said independent directors had flagged serious lapses in corporate governance and compliance to the company on multiple occasions.”
  • AsianInvestors report that Sweden’s AP7 excludes Chinese firms: https://www.asianinvestor.net/article/insto-roundup-swedens-ap7-excludes-chinese-firms-temasek-takes-up-sias-unders/470439. “The pension fund, which has SEK722.5 billion ($88.2 billion) in assets, excluded Beijing-based Chinese electricity company Huaneng Power International for acting against the goals of the 2015 Paris Agreement on climate change by expanding its coal operations. Beijing-based Power Construction Corp. of China was excluded for involvement in the violation of environmental norms at the Selous Game Reserve in Tanzania, which is a World Heritage site.”
  • The Financial Times reports that ESG ETF growth accelerates in Asia: https://www.ft.com/content/fda0b70e-36dd-4125-8e49-aac712a2f424. “Australia, China and Taiwan were the dominant regional players with 86.8 per cent of total ESG ETF assets in Asia Pacific in 2020. ESG ETF growth has been particularly strong in Australia which saw assets in the sustainable funds jump from $156.2m in January 2016 to $4.9bn in June 2021. The Cerulli research found that Generation Z was the most concerned about ethical investing, with 55 per cent likely to invest in a fund that integrates ESG considerations. China also saw strong growth, with assets jumping from $15m in 2016 to $3.3bn as of June 2021. There were a number of launches in 2021 following President Xi Jinping’s commitment in September 2020 to achieve carbon neutrality in the country by 2060. While there were only four new ESG ETFs in 2020 in China, 11 were launched in the first half of 2021, with more than half of them incorporating low-carbon or new-energy themes.”
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Daniele Vitale
Head of Governance UK & Europe > Corporate Advisory
T +44 (0)20 7019 7034 M +44 (0)7747 697 136 F +44 (0)870 702 0158
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