Step 1: Getting started with fact finding on green and ethical investment

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Advisers should be raising the issue of green and ethical investment in the fact finding process with all clients as a matter of course.


1.1 Basic fact finding

In order to 'know your client', advisers undertake some form of fact finding. This enables an adviser to explore the client's personal objectives and concerns. As such, the initial fact find should include an open-ended question about whether a client is interested in integrating social, environmental and/or ethical concerns into their financial decisions. There are numerous wordings that can apply, but one used by some advisers is:

“Would you like any social, ethical or environmental issues to be taken into account when looking at your investments?"

The aim of asking this question is to allow an adviser to decide whether or not they should look more closely at this subject with a client. This is the essential first step towards getting involved in this area.

There are several different ways to raise the issue of green and ethical investment. But it is normally less productive to ask a closed or leading question, such as:

“Do you want ethical investments?"

Some clients have not heard of ethical investment or may not have defined themselves as 'ethical investors', even if they do have concerns about issues like the environment or are interested in the business opportunities that social or environmental challenges may offer.

 

Public awareness of the existence of green and ethical investment is still low

According to consumer research in December 2006 (1), less than half of the UK public (46%) are aware of stock market funds that allow them to invest ethically.

 

 

 


1.2 The case for asking all clients an initial question during the fact finding process

There are several very strong commercial and other reasons why advisers should offer their clients the opportunity to buy green and ethical investments.

If you do not already ask an ethical fact find question, you should consider the following:

 

  • Does your current fact finding process tell you everything you need to know about your clients?

  • Can you give appropriate advice if you have not asked clients about their personal values and interests?

  • If you are competing with other advisers for a client, is there any disadvantage to being the only one who asks an ethical fact find question? Would you have a competitive advantage if other advisers raised the issue of the client's values or beliefs regarding green and ethical issues and you did not?

  • How might your clients feel if they learned about green and ethical investment from a source other than you?

  • If a client returned to you after six months saying that the investment you sold them was inappropriate because they should have been offered a green/ethical investment fund, what would you say and what action would you take?

 

These aspects are explored further below.


1.3 You should 'know your client'

There is currently no strict legal obligation for advisers to offer green and ethical investment advice, or for product providers to offer green and ethical investment.

However, every financial adviser has an obligation under the FSA conduct of business rules (COB) to know their customer. As a financial adviser, the FSA also requires you to treat customers fairly. These are broad principles, but understanding the needs and wishes of your clients, and not ignoring any ethical concerns they might have, would seem to be part of the process of providing appropriate advice.

You should not pre-judge client views and attitudes.

Some advisers take the view that 'our clients are not interested in this type of investment'. Opinions regarding who might be a stereotypical ethical investor are not hard to come by. But while it may be simple to recognise some of the people who are interested in this area, there is a growing recognition that it is not easy to spot everyone who could potentially be interested in green and ethical investment.

It is not safe to assume that all of your clients share exactly the same views and assumptions as you, their adviser. Even if your views are generally aligned, it is highly improbable that they are identical, especially regarding such matters as society, the environment or ethical issues.

It is also not safe to assume that a client's attitudes remain fixed over time. People change their views, as we can see with the rising interest in such issues as global warming. So when reviewing a client's portfolio and revisiting the fact finding process, it is important to check their attitude to green and ethical investments, even if they expressed a view about them last time you spoke.

A survey (2) in 2003 found that there were no substantial age, sex, geographic or socio-economic differences between responsible investors and other investors. Anybody might be interested in green and ethical investment, and it is not possible to make assumptions without asking.

 

The experience of an IFA who offers advice on green and ethical investment

 

'The experience among advisers in the market is that although there are those clients that would fall into the “woolly jumper and sandals brigade", the majority of clients are normal, completely average people. They range from socio-economic As and Bs to Cs and Ds. The majority actually fall into the A and B categories. It is usually those in this group who have assets on which they seek independent advice.'

 


1.4 You should protect yourself against possible complaints

Some people who have concerns about environmental or social issues have strong opinions. Unless you ask about, recognise and note a client's interest as part of the fact finding process, you are unlikely to know that you are dealing with a person with such opinions, and you could risk giving inappropriate advice. Clients who fall into this group may even move to specialist 'ethical' advisers once they find out that green and ethical investment exists.

The failure to ask an ethical fact find question is unlikely to trigger an immediate complaint, but if an adviser has failed to ask the question, it may lead to one further down the line.

As interest in social, ethical and environmental issues increases, the scope for complaints must therefore also be likely to increase. In this vein, it is worth noting that the Financial Ombudsman Service has received training in this particular area.


1.5 You can benefit from new opportunities and protect your client base at the same time

Advisers who do not explore with their clients whether they would be interested in green and ethical investment are increasingly likely to be missing valuable business opportunities. The ability to understand and discuss the main issues surrounding green and ethical investment can give you an important competitive edge.


(a) Many clients are interested in green and ethical investment

There is a great deal of evidence that a large and growing number of people are interested in green and ethical investing.

Recent market research (3) has found that:

  • Just under half of the public want to invest ethically, and just under one in five would be prepared to see some sacrifice in their investment returns in order to invest ethically.

  • About nine out of ten people questioned believe that it is important for companies to take social, ethical and environmental issues seriously.

  • Under half of those questioned were aware of the existence of green and ethical investment funds.

An increasing number of people are looking for advisers who will advise them on green and ethical investment (4).

There is also substantial and growing media interest in green issues, such as global warming, which both reflects and stimulates public interest in such matters.

 

Examples of evidence of public interest in green and ethical investment and related issues

 

In December 2006, consumer research (5) found that:

·         87% of respondents believe that it is important for companies to take social, ethical and environmental issues seriously. This view is held throughout the UK, but is especially strongly held in London and the South East – suggesting that it is more widely believed by more affluent sectors of society.

·         Nearly half (48%) of the UK public would like to invest ethically.

·         Nearly one in five (18%) would be keen to invest ethically, even if it meant a slightly lower return.

 

IFA Promotion, the organisation promoting the benefits of independent financial advice, says that consumers are increasingly seeking to invest their money ethically. It found that more than twice as many people searched for an ethical investment independent financial adviser in the summer of 2006, compared with the same period in 2005. (6)

Market research has shown that clients are looking to financial advisers to raise the issue:

 

·         65% of people said that advisers should ask whether or not they are interested in investing ethically. Only 22% of people questioned said advisers should only mention it if a client requests it. (7)

·         83% of the public believe that financial services companies should encourage the companies they invest in to take social, ethical and environmental issues seriously. However, only 8% of these people have ever received advice on green and ethical investment from a financial adviser. (8)

 

Know your client

“No adviser can ever say that every single one of their clients has morals, ethics and values that are identical to their own. Recognising that there are differences here is an important step in completing the 'know your client' process. Rather than imposing your own views on clients, you should take steps to find out what your clients think, and take that into consideration when giving advice."

Ethical Investment Association member


(b) The market for green and ethical investment advice

Potential green and ethical investors include:

 

  • Those investors who have already started to invest part of their funds in green and ethical investments or are looking to invest more in ways that are consistent with their beliefs. Such clients are actively seeking advice in this area.

  • The even greater number of investors who have taken an interest in buying ethical products (eg Fairtrade products, where Fairtrade has 20% of the UK ground coffee market (9)), but have not yet considered applied this interest to buying investments and financial services.


(c) The advantages for advisers of offering advice on green and ethical investment

Advisers have found that the benefits include:

 

  • Improved relationship with existing clients If a client considers that their adviser is taking into account their values and proactively taking an interest in them for more than just their money, they are much more likely to want to do business with the adviser again.

  • Increased referrals Clients are more likely to be happy with their investments if these are aligned more closely to the rest of their personal values. This regularly translates into increased referrals as well as good client retention.

  • Protection of the existing client base Offering green and ethical investment can protect against increased competition from other advisers. IFA Promotion reported in August 2006 that 840 (10%) IFA Promotion member firms included a focus on ethical investments, compared to 633 (8%) one year previously, and just 593 (6%) three years previously (10).

 

Case Study

 

If you can't offer green and ethical investment advice, your clients might go to someone who can

 

A client with over £200,000 accumulated in PEPs and ISAs approached a specialist ethical investment IFA after hearing about green and ethical investment on the radio. None of their existing portfolio was invested ethically, the client had never asked for green and ethical investment and their IFA had never mentioned the option.

 

The ethical IFA confirmed that while their existing holdings were in good funds with good companies, equally good investments could have been made in line with their ethical views. The result of the review was that all of their financial arrangements were moved to the ethical IFA, who transferred the investments onto an ethical/socially responsible investment footing.

 

At 0.5% pa fund-based commission on over £200,000, the earlier IFA lost over £1,000 of annual income. The client was not unhappy with the original IFA's advice or service. However, they were not prepared to stay with the original IFA, as they did not feel that the IFA had offered advice suitable to their requirements.

 

  • New marketing opportunities Advisers should be able to identify affinity and niche marketing opportunities. People who are interested in social, environmental and/or ethical issues are often unaware of the existence of green and ethical investments.
  • Improved product persistency rates Green and ethical investors are more likely to be faithful to their investment and hold on to it through market downturns, as they may have invested for more than simply performance reasons. So ethical investors are widely believed to be more persistent than other comparable investors.


1.6 You can prepare yourself for future changes to the green and ethical advice environment

It is looking increasingly likely that future legal, regulatory or professional standards changes may make an awareness of green and ethical investment an increasingly important factor for adherence to professional standards or even compliance.  For example:

  • The Financial Services Skills Council has published an exam syllabus that includes ethical investment for the first time. Both the Chartered Insurance Institute (CII) CF2 and Institute for Financial Services (IFS) CeFA exams now have modules on ethical investment. All new advisers will therefore have a basic knowledge of ethical investment and the provision of advice in this area. (11)

  • The British Standards Institution (BSI) launched a new international standard for competence in personal financial planning, ISO 22222, in 2006. Financial advisers will soon be able to use the prestigious BSI kitemark for achieving this standard. However, it requires that the client data requested by a financial planner should normally include “attitudes to social, ethical, environmental and religious considerations". In their draft guidance on compliance, the BSI said that financial planners should have adequate processes in place to give appropriate advice where a client expresses interest in these areas. It highlights UKSIF's 'Investing Responsibly' toolkit, which forms the basis for this course, as an aid to help meet the standard's requirements. (12)

  • The 2006 government Pensions White Paper Personal accounts: a new way to save said the government expects that the new system of personal accounts will include SEE investment options. (13)

By identifying whether or not the issues behind green and ethical investment approaches are important to a client and developing skills in advising on this area, an adviser can be prepared for these types of future changes.


1.7 You can deliver added value for clients seeking green and ethical investment

There are a number of specific technical issues surrounding the provision of green and ethical investment advice. A number of your clients may not have enough knowledge and experience about this area or general investment issues to be able to make appropriate decisions without advice.

Along with knowledge of asset allocation, risk and reward, tax and choice of appropriate tax wrappers for clients, the ability to provide green and ethical investment advice is therefore an important part of every financial adviser's skill set and requires specific competencies.

 

Need for guidance

 

Some clients seem to assume that all investment funds screen their underlying investments for ethical issues. One market research study found that one in five respondents (22%) was not aware that most investment funds put their money into all types of companies, irrespective of their social, ethical and environmental policies. (14)

 


1.8 Advice opportunities – pension funds must provide a 'Statement of Investment Principles' (SIP)

Most advisers are involved in pension fund advice.

Occupational and stakeholder pensions are required to have a 'Statement of Investment Principles' (SIP) which must be made available to members on request. The SIP must set out the scheme's approach to ethical and socially responsible investment.

The rules, which were originally introduced by a regulation under the 1995 Pensions Act, state that trustees of occupational pension funds are to disclose the following in their SIPs:

  • The extent (if at all) to which social, environmental or ethical (SEE) considerations are taken into account in the selection, retention and realisation of investments; and

  • The policy (if any) directing the exercise of rights (including voting rights) attaching to investments.

The legislation did not oblige pension fund trustees to adopt responsible investment policies, but it has increased their transparency on the issue, and so has driven change.

Techniques for implementing responsible investment by occupational pension funds include 'engagement-only' approaches (see Step 3), thematic investment (eg in green private equity) and the introduction of screened green and ethical investment options where members can exercise individual choice, eg for defined contribution schemes.

 

Advising on pension fund investment

 

Advisers helping to select stakeholder pension products should request SIPs from stakeholder providers before making recommendations, so that they are able to advise any interested or potential members on this aspect of the scheme.


1.9 Advice opportunities – charities

Some financial advisers provide advice to charities. Like other institutional investors, charities often prefer the term 'responsible investment' to 'green and ethical investment'.

Responsible investment can help a charity to align its investments with its charitable objectives. Charities may increasingly seek advice on responsible investment, following recent clarifications in the law from the Charity Commission.

For trustees concerned that responsible investment could conflict with fiduciary duty, the Charity Commission in Investment of Charitable Funds states that “Trustees are free to adopt any ethical investment policy which they reasonably believe will provide the best balance of risk and reward for their charity". (15) It highlights that, as with any other investment strategy, trustees must discharge their duties with respect to investment. This includes having regard to the suitability of the particular investment. It goes on to say that “Where a charity has an ethical or socially responsible investment policy, the duty to consider suitability involves recognising the need for consistency with that policy". (16)

The Charity Commission recognises that an ethical investment policy may be entirely consistent with the fiduciary duty of maximising return on investment. It outlines three situations where trustees can allow an investment strategy to be governed by considerations other than pure investment return:

 

  1. Where investment in a particular type of business would conflict with the aims of the charity.

  2. Where certain investments might hamper its work by alienating supporters or beneficiaries.

  3. On moral grounds, provided the trustees are satisfied that this would not involve “a risk of significant financial detriment".

 

In line with pension fund disclosure, the amended Statement of Recommended Practice (SORP) 2005 for Accounting and Reporting by Charities (17) states that charity trustees should explain as part of the financial review section of their annual report 'where material investments are held, the investment policy and objectives, including the extent (if any) to which social, environmental or ethical considerations are taken into account'.

 

 

Advising on charitable investment

Useful sources of further information for advising specifically on charitable investment are:

 

·                Investment of Charitable Funds, particularly Section F. (18)

·                The guides produced by the EIRIS/UKSIF Charity Project. (19)


1.10 The financial performance of responsible investments

There is a theoretical view of investment performance which holds that by limiting the range of possible investments, green and ethical investment strategies will lead to underperformance. Some advisers cite this view as a defence for offering investment strategies solely aimed at maximizing returns.

Performance issues are covered in greater depth later, but some of the key arguments against this are that:

 

  • There are now many years of practical experience demonstrating that green and ethical funds need not underperform. “Investing ethically does not mean that you have to sacrifice investment performance", according to the Investment Management Association in their Guide to Ethical Investment, July 2006. (20)

  • A significant number of investors may not want profit maximization at all costs. As described earlier, nearly one in five members of the public surveyed stated that they would be “keen to invest ethically, even if it means a slightly lower return", according to December 2006 consumer research. (21)

  • Companies that improve their corporate social responsibility and sustainability (eg with regard to climate change) may perform more profitably in the long run. (22) Investor engagement may encourage this.

  • Green and ethical investment funds can give investors the chance to get involved with emerging social and environmental investment themes at an early stage, before many conventional investment funds have identified the investment opportunity. This happened with environmental technologies such as solar power and fuel cells.

 

Self test question

What types of pension scheme are required to provide a 'Statement of Investment Principles'?

 

Step 1 – Key learning points

Getting started with green and ethical find finding

·                Financial advisers should ask all their clients during the fact finding process whether they would like green and ethical investment issues to be considered.

·                A significant proportion of clients are actually or potentially interested in green and ethical investments for at least some of their holdings.

·                There is a strong business case for advisers to offer green and ethical investment advice as part of their normal activities.


Footnotes

1        72 Point Ltd for F&C Asset Management Plc, December 2006.

2        NOP World/Friends Provident, between 1-3 August 2003.

3        72 Point Ltd for F&C Asset Management Plc, December 2006.

4       See press release from IFA Promotion

5        MORI/Friends Provident, 10-15 June 2004.

6        IFA Promotion – see note 4.

7        MORI/Friends Provident – see note 5.

8        NOP World/Friends Provident, between 1-3 August 2003.

9        Jean Marie Krier: Fair Trade in Europe 2005 – Facts and Figures on Fair Trade in 25 European countries, published by the Fair Trade Advocacy Office in Brussels.

10      MORI/Friends Provident – see note 5.

11      See the Financial Services Skills Council's exam syllabus

12      Press release at http://www.uksif.org/cmsfiles/uksif/uksif-ISO22222-PR.pdf.

13    See Chapter 5, Investment and accessing savings 

14      NOP World/Friends Provident, between 1-3 August 2003.

15      Section F of Charity Commission. Investment of Charitable Funds.

16      Paragraph 56 of Charity Commission. Investment of Charitable Funds.

17      Statement of Recommended Practice (SORP) 2005, Accounting and Reporting by Charities.

18      Charity Commission – see note 15.

19      The guides, all available at www.eiris.org, are:

Investing Responsibly: A practical introduction for charity trustees (2005), a joint publication of EIRIS, UKSIF and NCVO. This explores current practices and suggests five steps for charity trustees considering a responsible investment policy.

Responsible investment approaches to non-equity investments: An introduction for charity trustees (2006).

The Responsible Investment Approaches of Common Investment Funds – A guide for charity trustees (2006).

20      Click here for the Guide to Ethical and Socially Responsible Investment Funds.

21      72 Point Ltd for F&C Asset Management Plc, December 2006.

22      See research at www.sristudies.org, such as Corporate social and financial performance: a meta analysis, 2003