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Harbour’s Environmental, Social and Governance policy

Jorge Waayman | Posted on Jun 22, 2021


Harbour’s Environmental, Social and Governance (ESG) policy encompasses our approach to responsible investing including integration into our investment decision making process, stewardship practices and industry engagement. This policy has now been updated to reflect our constantly evolving approach with key developments such as a new section on sustainability outcomes, our guiding principles on proxy voting and further explanation of our exclusions process.

Sustainability outcomes

Investing for positive real-world outcomes has been a rising focus with the UN Sustainable Development Goals (SDGs) being a key framework to measure and track environmental and social impact. At Harbour, we seek to align our investments with the SDGs, acknowledging that not all these goals are applicable to companies under our purview in the listed space, by attempting to measure additionality in a company’s progress towards a particular SDG. In practice, this could be an electricity generation company investing in further renewable capacity to help progress the Clean Energy and Climate Action SDGs or a healthcare company delivering a new technological solution to reduce the incidence of communicable diseases to aid the Good Health and Wellbeing SDG.

Voting principles

Our role as fiduciaries and active owners is reflected through our investment stewardship practices in engagement and proxy voting. We have included guiding principles that help form our decisions on proxy voting resolutions, based on our view of strong ESG practices. However, we recognise that context is important which is why each company’s AGM resolutions are assessed on a case-by-case basis and there might be situations where our decisions will deviate from these general principles. The principles promote strong levels of independence and diversity amongst company Boards, appropriate disclosure on executive remuneration structures and transparency on climate change and human rights risk management. These principles, particularly on governance are consistent with recommendations in the NZX Corporate Governance Code which represents useful guidance for NZX issuers that we endorse.


Ethical values have long been incorporated in ESG approaches through negative screening processes but can be challenging to establish due to the concept of morality differing from person to person. Whilst we favour active ownership through corporate engagement and proxy voting as more effective catalysts for positive change, we recognise that it is important to avoid investing in companies involved in activities that are most likely to lead to significant harm in society such as tobacco and controversial weapons. These exclusions apply across all our internally managed funds and include the type of business activity i.e. manufacturing, distribution or sales and the revenue exposure thresholds. These exclusions are regularly monitored through the services from an external provider and then enforced in our compliance system to ensure no companies involved in any of the defined activities can be invested into across the funds.


Harbour’s approach to ESG considerations is multi-faceted and is neither a recent, nor a superficial part of the investment process. This policy describes the main aspects of our approach, but further information can be found from other sources such as our PRI transparency report, annual stewardship summary and ESG research articles available on our website.

Click here to see more information on our Responsible Investing and the full ESG policy


Harbour Asset Management Limited is the issuer and manager of the Harbour Investment Funds. Investors must receive and should read carefully the Product Disclosure Statement, available at We are required to publish quarterly Fund updates showing returns and total fees during the previous year, also available at  Harbour Asset Management Limited also manages wholesale unit trusts. To invest as a Wholesale Investor, investors must fit the criteria as set out in the Financial Markets Conduct Act 2013. This publication is provided in good faith for general information purposes only. Information has been prepared from sources believed to be reliable and accurate at the time of publication, but this is not guaranteed. Information, analysis or views contained herein reflect a judgement at the date of publication and are subject to change without notice. This is not intended to constitute advice to any person.  To the extent that any such information, analysis, opinions or views constitutes advice, it does not take into account any person’s particular financial situation or goals and, accordingly, does not constitute financial advice under the Financial Markets Conduct Act 2013. This does not constitute advice of a legal, accounting, tax or other nature to any persons.  You should consult your tax adviser in order to understand the impact of investment decisions on your tax position. The price, value and income derived from investments may fluctuate and investors may get back less than originally invested.  Where an investment is denominated in a foreign currency, changes in rates of exchange may have an adverse effect on the value, price or income of the investment. Actual performance will be affected by fund charges as well as the timing of an investor’s cash flows into or out of the Fund.. Past performance is not indicative of future results, and no representation or warranty, express or implied, is made regarding future performance. Neither Harbour Asset Management Limited nor any other person guarantees repayment of any capital or any returns on capital invested in the investments. To the maximum extent permitted by law, no liability or responsibility is accepted for any loss or damage, direct or consequential, arising from or in connection with this or its contents.