We integrate ESG factors into our listed equity investment process with the aim of better understanding financial risks that the lens of conventional financial analysis may miss. Businesses involved in the most unsustainable activities are likely, over time, to be negatively impacted.
Before making an investment, we look at companies’ corporate governance, how they approach their most financially material sustainability risks, and whether they have been involved in any related controversies.
Once an investment has been made, we routinely monitor companies’ ESG characteristics to ensure that standards do not slip.
New ways of investing have given rise to a new vocabulary. One that includes terms like ESG (environmental, social and governance), impact investing, ethical investing, net zero, and sustainability.
To prevent confusion about these terms and mis-selling, the Financial Conduct Authority (FCA) has introduced Sustainability Disclosure Requirements (SDRs).
The key parts of the SDRs are:
1. An anti-greenwashing rule
Investment firms must be clear, fair and not misleading when they claim sustainability. Those claims must be consistent with the sustainability characteristics of the investment product they offer.
2. Investment labels
There are four investment labels that investment firms can attach to investment products; these are:
Sustainability Improvers
For funds that invest 70% or more of their assets in holdings that have the potential to improve environmental and/or social sustainability over time. E.g. companies that have committed to improving their business practices in relation to human rights.
Sustainability Impact
For funds that invest 70% or more of their assets in holdings that aim to achieve pre-defined positive, measurable environmental or social impact. E.g. renewable power generation.
Sustainability Focus
For funds that invest 70% or more of their assets in holdings that are environmentally and/or socially sustainable. E.g. sustainably managed forestry assets.
Sustainability Mixed Goals
For funds that invest in accordance with two or more of the objectives above.
Providers must determine the sustainability objective of each labelled product, with robust, evidence-based standards that are an absolute measure of environmental and/or social sustainability.
3. Naming
The SDRs only allow funds to use the term ‘sustainable’ in their names if they have an investment label. Only funds with the ‘sustainability impact’ label can mention ‘impact’ in their names.
Funds without a label, however, can still use terms such as ‘green’, ‘socially responsible’, ‘carbon neutral’ etc. in their name, if at least 70% of their holdings align with those descriptions.
4. Marketing
Firms can only use sustainability-related terms in their marketing where this is consistent with the sustainability approach of the product.
Funds that use sustainability-related terms in their marketing but don’t use a sustainable investment label must state this. They must also state why they don’t use a label.
5. Sustainability reporting
Firms that use a label or sustainability-related terms without a label must produce a fund-level and firm-level report at least once a year .
CCLA will publish its first fund-level report by 2 December 2025 and its first firm-level report by 2 December 2026.
At CCLA, we believe we have a duty to help address systemic risks that threaten communities, the environment and investment markets themselves. For that reason, we welcome the SDRs and have taken action to implement them across all our funds.