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Sustainable Investment Policy

Last updated: February 2026

Our guiding principle is that sustainable investing is not a trade-off between sustainability and financial return; rather, it should enhance financial return and create sustainability outcomes.

We have four main pillars to our sustainable investment policy.

A) Intent—not terminology—is what matters

Sustainable investment and ESG investing approaches are ever-evolving, and so are the terminology and data that come with them. There are a range of words that we, as investment practitioners, like to put before “investing,” including “impact,” “socially responsible,” “sustainable,” and “ESG (environmental, social, governance).” Each of these definitions shares some similarities and some differences, but most crucially, they mean different things to different people. As such, we prefer not to get too concerned with definitions and simply consider ourselves “sustainable investment” practitioners.

What we think matters is the intent you bring to making investment decisions. We make sustainability a core part of our investment decision-making (please see part D for how), and this allows us to create strong financial and sustainability outcomes.

B) Risk Avoidance

Sustainable investing can help an investor avoid certain risks, which we believe enhances the opportunity for financial returns. It also means that we construct a portfolio that seeks to avoid highly controversial companies, which helps us sleep better at night. When we see enough smoke from a company, we get worried there might be fire, so we stay away.

Some of the questions we ask ourselves in this assessment include:

  • Are there social or environmental issues that could lead to regulation?
  • Are there stranded-asset risks? What are the unpriced externalities?
  • Is there a history of poor governance? Does the company have a history of poor behaviour—whether in business practices, environmental impact, worker treatment, or otherwise?

C) Sustainability outcomes can be measured quantitatively or qualitatively

The data available from companies around sustainability is getting better, but it will never be perfect. However, we strive to ensure that perfect is not the enemy of good, and we pursue the following quantitative and qualitative sustainability outcomes.

  1. Seek a scope 1 and scope 2 portfolio carbon footprint that is materially lower than the benchmark, as represented by CO2 per \$1m of investment (quantitative measure).
  2. Maintain active and ongoing portfolio exclusions based on dynamic revenue-threshold analysis, including companies exposed to weapons, tobacco, gambling, alcohol, or fossil fuels (quantitative measure).
  3. Actively research companies for controversial business practices.
  4. Actively vote our proxies, with a particular focus on supporting ESG disclosure, positive environmental impact, diversity in leadership, reasonable executive compensation, and fair treatment of employees (quantitative and qualitative measure).
  5. Use our position as investment managers to help evolve best practices for sustainable investment and to communicate this with stakeholders, including investors, company management, and regulators (qualitative measure).
  6. In our thematic strategy, we provide capital to well-managed companies making breakthroughs across three sustainability themes: (1) energy transition, (2) urban development, and (3) human health and wellness (qualitative measure).

D) There is not a “one-size-fits-all” approach to sustainable investment

Different investors use different investment approaches on the financial side, such as value investing, growth investing, passive investing, etc.  The same holds true for sustainable investing, where there are a range of approaches a fund manager can apply. 

The approaches we use at ACS Group are:

  • Exclusionary Screening: Divesting from industries and companies that are negative for people and planet. We believe that avoiding the most problematic industries and companies helps us avoid stranded assets and very harmful industries, such as the tobacco industry or the fossil fuel industry.
  • ESG Integration: Using environmental, social, and governance data in our decision-making. We have a proprietary 20-category ESG quality assessment that we conduct on investment opportunities, which provides a range of critical inputs in making an investment decision. We avoid providing a numeric ESG “score” to a company, as we fear this creates false precision.
  • Thematic Investing: Investing on the basis of sustainability trends—social, industrial, demographic, or otherwise. This allows us to take a top-down look at investment opportunities and identify opportunities with large structural tailwinds. For example, health care companies will be increasingly important as the population ages.
  • Active Ownership: Entering into a dialogue with companies to drive improvement on ESG issues. We strive to make deeper change in a targeted number of areas, as opposed to a broader, surface-level approach.

We will review and update our Sustainable Investment Policy regularly and at least semi-annually.