About
Responsible Investment Policy
Purpose & Scope
At Driehaus Capital Management LLC (“Driehaus”) we are a fiduciary with respect to our clients which means we act in the best interest of our clients. We believe material environmental, social and governance (“ESG”) factors will affect the sustainability of companies’ future earnings and profitability and therefore may impact the risk and return potential of our long-term investment prospects. We believe the linkage between ESG factors and corporate fundamental operating metrics will likely persist, if not increase, in the future. We therefore believe it is important to consider a variety of factors, including significant ESG risks and opportunities as a part of our fiduciary duty to our clients.
Driehaus is a signatory to the Principles for Responsible Investment (“PRI”) and, alongside other institutional investors worldwide, supports its mission to promote the incorporation of ESG factors into the investment process.
For the above reasons we integrate an analysis of material ESG factors relevant to potential investments we make. We also reasonably monitor our portfolio investments, to the extent practical, to track the progress of improvements.
This policy applies to the listed equity investments held by the strategies we manage for clients and market to prospective investors.
40+
Year heritage of providing active management to professional investors.
Portfolio Guidelines
ESG factors are one part of the overall investment analysis our investment teams conduct when determining the potential for companies to deliver differentiated earnings growth. Rigid constraints, guidelines and negative screening are not applied within our investment strategies.
We may, however, manage custom mandates with stricter ESG or Socially Responsible Investment constraints that meet client-specific guidelines and policies.
Engagement & Active Ownership
Driehaus’ engagement efforts with companies serve as a tool to further evaluate and explore risks, including material ESG risks, to enhance due diligence, and to reinforce industry wide efforts to encourage companies to embrace and disclose sustainable practices.
While we recognize the benefits of investor activism, as a fiduciary we do not delay in exiting investments where we are uncomfortable with the asymmetric return potential. Much of our engagement efforts are generated on a case-by-case basis and centered around the most relevant or material risks for a given company. Our ESG engagement priorities are generally set forth as follows but may change based on the investment team, the company, region, industry and country and other factors:
• Understanding management practices where disclosures are lacking
• Encouraging disclosure of material sustainability risks
• Understanding size, nature and trend of any controversy, as well as a company’s strategy to manage such controversies
• Addressing non-compliance with the UN Global Compact
• The severity of our risk concerns
Discussions with company management allow the investment team to learn about a company’s perspectives and approaches, provide said company with feedback, and raise any issues (including ESG issues) that have been identified during the research process.
Additionally, when a client authorizes Driehaus to vote proxies on their behalf, we generally vote in accordance with a third-party proxy solicitation service’s sustainability voting guidelines. Please see the Driehaus proxy voting policy for more information on proxy voting.
Responsibilities & Oversight
Our firm’s responsible investing activities are performed by the various portfolio managers and analysts in partnership with our risk management team. Direct oversight and accountability for responsible investing activities falls under the purview of the Investment Policy Committee (“IPC”). The IPC is responsible for ensuring the investment teams adhere to this policy. Driehaus’ CEO exercises ultimately accountability and authority over the firm’s responsible investing efforts. Please see Appendix A to this policy for more information about oversight.
Development and maintenance of this policy is the responsibility of the firm’s ESG Committee. The ESG Committee is responsible for reviewing the policy at least annually and amending it as necessary. The ESG committee is comprised of legal, investment, risk and marketing professionals.
Client Commitment
In addition to being a signatory of the PRI, Driehaus is supportive of trends related to the growing importance of ESG issues for example as an endorser of the Investor Stewardship Group. While Driehaus performs ESG integration across our investment strategies, we also manage strategies for clients who have wish to make sustainability a core objective of their investment strategy. Those sustainability-focused strategies may include exclusionary screens and/or specific sustainability criteria.
The Driehaus Commitment
We are committed to fostering and preserving a culture of diversity and inclusion with an emphasis on integrity, collaboration and community.
