You can find Harbour's full ESG/Responsible Investing Policy here.
ESG (environmental, social and governance) considerations play a central role in Harbour’s investment philosophy.
Harbour is a market leader for integrating ESG research into our investment process.


ESG considerations are important for two reasons:

As a responsible corporate citizen, with a fiduciary duty to our clients, we have an obligation to consider all types of risk. This includes the environmental, social and governance risks associated with the companies we invest in.

As active investors, we believe that ESG risks and opportunities are often not fully reflected in the market price for securities. We are able to use this knowledge to invest to achieve better outcomes for our clients.

At Harbour, we employ a strategy of integration and company engagement. This means our team researches all the companies we invest in and actively checks for any environmental, social or governance (ESG) risks that may apply to them. It helps our Portfolio Managers develop an understanding of each company, and influences not only whether we invest in companies, but also how much. It helps us to unearth companies which may be great opportunities for long term growth, as well as companies with potentially hidden risks.

We are able to use our role as a shareholder to engage with company leadership, highlight any concerns we may have and use our influence to encourage better behaviour. 

Our annual Corporate Behaviour Survey researches how companies rate on issues like:


  • Carbon emissions
  • Energy use
  • Waste
  • Environmental policies and risk management


  • Health and safety
  • Modern slavery
  • Stakeholder relations
  • Diversity


  • Board composition
  • Executive remuneration and incentives
  • Ethics
  • Anti-competitive practices

Harbour has been a UNPRI signatory since 2010. 

PRI logo

Harbour is also a member of the RIAA.

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Policy Submissions

Harbour’s engagement program not only focuses on constructively working with companies in our investment universe, but also contributing to public policy/regulatory consultations to positively influence policy settings relating to ESG considerations. 

Date Link to submission Submitted to
Dec 2019 Climate change-related financial disclosure submission Ministry for the Environment & Ministry for Business, Innovation and Employment
Oct 2019 Submission on green bonds and other responsible investment products Financial Markets Authority
Aug 2019 Clean Car Standard & Clean Car Discount submission Ministry of Transport
Jul 2018 Zero Carbon Bill Submission Ministry for the Environment
Jun 2018 Response to NZX Listing Rules Review, second round NZX
Nov 2017 Response to NZX Listing Rules Review NZX
Oct 2016 Submission to NZX Corporate Governance Code Review NZX



Active Ownership

We demonstrate our responsible investing philosophy and fiduciary duty by keeping active in our investments through our extensive engagement programme and proxy voting process. 

Harbour’s engagement strategy over 2019 was largely focused on climate change. This follows from a growing sense of urgency to address one of the greatest risks facing the world today. This is evidenced by compelling scientific reports and policy initiatives such as the IPCC report, Zero Carbon Bill and Paris Agreement which highlight the need to move to a lower emissions economy. Corporates will have to play their part to help achieve the targets outlined by our Government with investors being a driving force behind it.

In order to prioritise our engagement strategy, we first conducted a study assessing the current state of play in carbon reporting across the NZ listed market. This research allowed us to analyse the emissions disclosure and performance in aggregate as well as identify the leaders and laggards that would form prime candidates for engagement.

Our engagement strategy also continued to include companies with contentious ESG issues such as executive remuneration, board composition and lack of disclosure particularly around company AGMs.

These targeted engagements were also supplemented by the general ESG engagement we conduct across our whole NZ investment universe each year as part of our Corporate Behaviour Survey process.

The Corporate Behaviour Survey is our primary way to comprehensively assess how well each company in our NZ investment universe is addressing ESG considerations with engagement playing a key part. More information can be found in our ESG policy at

Engagement Breakdown

During the year we conducted 23 ESG related engagements on ad hoc issues in addition to the 61 engagements we conduct annually as part of our Corporate Behaviour Survey process.

For the ad hoc engagements, these were primarily focused on NZ companies with 19 out of the total 23 conducted. This reflects the fact that our portfolios are either constrained to the NZ market or have a proportionately larger weighting to NZ companies compared to Australia.

There were a variety of different ESG issues covered in these engagements and in some cases involved multiple interactions with the company. As part of our engagement strategy we engaged with 8 companies on climate change that were either lagging or leading in their efforts. We continued to engage on AGM resolutions relating to board composition through 5 director election engagements, 3 on executive/director remuneration and the remaining 7 on issues such as general ESG disclosure, culture and community engagement.

Outcomes from these engagements were generally constructive with many of the companies receptive to our concerns and planning to make changes to improve on the issues identified. We are cognisant that some of these issues are long term in nature and take time to enact change. Therefore, we are both patient and confident companies will eventually make the appropriate adjustments, but we will continue to monitor and liaise with them until these are made.


Overall, the year has involved significant progress in our research and engagement on climate change through the project conducted on carbon disclosure across the NZ market, engaging several companies held in portfolios lagging in their climate change reporting/performance and learning more through engaging leading companies and attending multiple industry events on the topic. We will continue our work on climate change going forward as it remains a prominent issue in the ESG space affecting the market and now that we have established a baseline of disclosure, we will aim to improve the depth of our research and engagements. In particular, we further resourced a fixed term staff member to conduct a research project analysing electric vehicle adoption in a sample of NZ’s largest listed companies which will play an important role in the transition to a lower carbon economy.

In addition, we continue to engage companies as any material ESG issues arise, particularly on contentious areas proposed during company AGMs. This also includes maintaining our dialogue with companies that we have identified as lagging in an issue such as board independence, remuneration or ESG disclosure, by constructively working with them in the long term to achieve the best outcomes for shareholders.