Responsible 
Investment 
Report
Q2 2023

Responsible investment at Ruffer
2
Overview of the quarter
3
Stewardship activities in brief
4
Engagements in focus
7
Voting in focus
11
About Ruffer
14
Contents
RESPONSIBLE INVESTMENT REPORT Q2 2023

2
Responsible investment  
at Ruffer
AT RUFFER, WE ARE COMMITTED TO BEING GOOD STEWARDS  
OF OUR CLIENTS’ ASSETS.
To do that, and to generate good investment performance, we need to analyse 
environmental, social and governance (ESG) issues. They represent both sources of 
value and investment risks. Incorporating these considerations into our investment 
approach forms part of our responsibility to our clients.
Whether it’s climate change or indigenous rights, executive pay or workforce safety, 
we believe our considered approach helps us make better investment decisions.
To the advantage of our clients’ portfolios.  
For the benefit of the companies we invest in.  
And to the good of the environment and society.
HOW WE DO IT
INTEGRATION  
ESG risks and opportunities are considered as part of our investment process.
ENGAGEMENT  
Directly engaging with companies is a part of our investment process.
VOTING  
Equity investing comes with rights and responsibilities. 
We take this seriously.
We are signatories and supporters of
RESPONSIBLE INVESTMENT AT RUFFER

Overview 
of the quarter
WHEN APRIL’S SWEET SHOWERS HAVE PIERCED MARCH’S 
DROUGHT TO THE ROOT (AS GEOFFREY CHAUCER PUT IT), 
PEOPLE’S THOUGHTS NATURALLY TURN TO A SUMMER OF 
OUTDOOR EVENTS. Back in Chaucer’s day, a pilgrimage was the hot
ticket. In these more modern times, it might be Wimbledon, the Chelsea 
Flower Show or Glastonbury. Henley, perhaps? Whatever floats your boat. 
For the responsible investment team, however, the second quarter holds 
other delights. With the bulk of annual general meetings held between  
April and June, this is peak voting season. 
Voting is very important for us – and for our clients. It allows us to express, 
on their behalf, our independent judgements on the various resolutions put 
forward by both management teams and shareholders. In this way, our votes 
can amplify the messages we convey directly to companies during  
our engagements throughout the year. 
In this quarter’s Responsible Investment Report, we delve into the thinking 
behind our recent votes both for and against resolutions on a broad range of 
environmental, social and governance issues. These are complex topics, and 
our decisions are taken only after deep research and serious consideration 
by the responsible investment team, with input from other experts – both 
internal and external – where relevant. The companies whose votes we focus 
on in this report are Amazon, BP and Glencore. 
As usual, we also give a full list of our engagements with companies over the 
quarter and provide more detail on some of the more noteworthy ones – this 
time, those with Volkswagen, steel giant ArcelorMittal and offshore drilling 
services supplier Noble.
RESPONSIBLE INVESTMENT REPORT Q2 2023

COMPANY 
SUMMARY
ADMIRAL GROUP
A meeting about the company’s remuneration policy, specifically to 
clarify the congruency of targets and performance metrics. 
AMBEV
A call to discuss the independence of board directors and express our 
concerns about the Chair of the Board and another director. We also 
expressed our intention to vote against the remuneration plan at the 
upcoming AGM as we think the proposed increase is excessive. 
ARCELORMITTAL
Co-signed a letter asking ArcelorMittal for further transparency on 
the pathway towards setting and achieving its climate targets. Later 
in the quarter, we met with the company individually to discuss 
progress made, including its health and safety issues and how the risk 
culture was being addressed through controls, systems and executive 
remuneration. We also discussed how ArcelorMittal could harness 
green steel as a competitive advantage and how it planned to align its 
reporting with a new European framework. 
ASHMORE GROUP
A meeting to discuss the revisions to the company’s 
remuneration policy. 
BP
Following on from our meeting last quarter, a discussion about capital 
discipline and allocation in light of the company’s changing aims. We 
also discussed CEO remuneration and a shareholder resolution at the 
upcoming AGM, given recent fatalities. 
DASSAULT AVIATION
A brief discussion ahead of the company’s AGM to clarify how 
land acquisitions from related parties are governed and to ensure 
succession plans are in place for family directors and directors 
associated with the controlling family shareholder. 
Stewardship  
activities in brief
RESPONSIBLE INVESTMENT REPORT Q2 2023

COMPANY 
SUMMARY
DUPONT
A meeting to discuss the potential financial liabilities linked to 
litigation over PFAS (synthetic chemicals known as forever chemicals 
as they don’t degrade easily). We also explored the governance of 
integrating ESG strategy with corporate strategy. 
EPWIN GROUP
A meeting about the company’s recycling initiatives (via recent 
acquisitions) and the business case for reusing and repurposing 
materials in Epwin’s operations. 
EU COMMISSION
Co-signed a letter to the EU Commission, encouraging the removal of 
aeronautics as a specific activity under the EU Taxonomy.
JET2
A meeting to discuss the company’s use of carbon offsets to abate 
its emissions given the lack of support for sustainable aviation 
fuel, the nomination of female directors to the board and to senior 
management, and whether the board is considering linking the 
variable component of remuneration to ESG targets and metrics. 
JDE PEET’S
A discussion covering the level of independence on the board and 
across the board’s sub-committees, the company’s relationship 
with ESG ratings agencies such as MSCI, and the recommendation 
from Institutional Shareholder Services (ISS) to vote against the 
remuneration proposal. On this last topic, we concluded that the 
size and metrics of the long-term and short-term incentive plans 
were acceptable, so we plan to vote in favour of the policy. 
MARKS & SPENCER
A meeting focused on gaining a better understanding of the company’s 
unique management structure. The meeting ultimately reassured us 
that roles and responsibilities are clearly defined and there is a culture 
of challenge and honesty in the decision-making process. 
M&T BANK
An introductory meeting to discuss the company’s relationships 
with ESG ratings agencies, plans to disclose to CDP and progress 
on the development of a climate risk framework and measurement 
of financed emissions. 
5
STEWARDSHIP ACTIVITIES IN BRIEF

COMPANY 
SUMMARY
NOBLE
An introductory meeting to discuss how the company is 
incorporating sustainability post-merger and to understand how 
reducing carbon emissions is contingent on strong customer 
relationships. We also encouraged robust ESG disclosure and 
engagement with ESG ratings providers. 
PFIZER
A meeting covering a broad range of topics, including remuneration 
and gender diversity metrics, how the company ensures independence 
of its auditor, and succession planning for the lead independent 
director. We also clarified how the company was using power purchase 
agreements and carbon credits in its energy transition plan. 
PROSEGUR CASH
A meeting to discuss the company’s MSCI rating and the recent voting 
recommendations provided by ISS. 
RESONA
A discussion on the company’s initiative to reduce cross-shareholdings, 
which we support. We also wanted to understand the company’s 
sustainability initiatives, focusing on Net Zero targets, financing oil 
and gas projects, and gender diversity and inclusion. 
SHELL
A group call to discuss performance and sustainability outcomes for 
2022 and the remuneration policy for 2023. We also met with the 
Chair to discuss Shell’s energy transition strategy, whether it would set 
absolute Scope 3 emissions targets and its capital allocation strategy. 
We then met with the company again in response to the letter we sent 
to the CEO last quarter. 
STRIX GROUP
A discussion on the company’s products that help reduce energy 
consumption in small appliances and how this offering appeals to 
ESG-minded investors. 
SUNCOR
A meeting to discuss the company’s integration of ESG, the role 
of climate solutions within Suncor’s portfolio and its relationship 
with climate-focused initiatives. We also asked how the company is 
addressing safety problems in light of recent fatalities. 
RESPONSIBLE INVESTMENT REPORT Q2 2023

COMPANY 
SUMMARY
TENARIS
A discussion about the company’s strategy to reduce emissions, 
whether its 2030 target was sufficiently stretching and to encourage 
Tenaris to set a Net Zero goal or a science-based target. We also asked 
how the company engages with ESG ratings providers such as MSCI 
and ISS.
VELOCYS
A meeting to discuss capital allocation and strategy as the company 
pursues the production of sustainable aviation fuel. 
VIVENDI
An opportunity to question the effectiveness of the audit committee, 
given it is not independent, and to suggest a clearer split of the 
nomination and remuneration committees. We also questioned the 
structure and efficacy of the metrics used in the remuneration policy. 
VOLKSWAGEN
A comprehensive discussion that touched on the responsible sourcing 
of critical raw materials, human labour rights, executive remuneration, 
board independence and the company’s MSCI ESG rating. 
WESTGOLD RESOURCES
A formal communication to the Chair and the managing director to 
discourage further dilutive capital raises. 
YARA INTERNATIONAL
A meeting about the company’s progress on setting science-based 
emissions reduction targets, and the growth potential of the clean 
ammonia business. 
The views expressed in this article are not intended as an offer or solicitation for the purchase  
or sale of any investment. The information is fact based and does not constitute investment 
research, investment advice or a personal recommendation, and should not be used as the basis  
for any investment decision. ©2023 Ruffer LLP is authorised and regulated by the Financial 
Conduct Authority.
7
STEWARDSHIP ACTIVITIES IN BRIEF

Engagements  
in focus
Noble provides offshore drilling services for oil 
and gas exploration and production companies. 
We met with Noble’s sustainability team this 
quarter to learn how the company is considering 
ESG issues within the business. 
Following the completion of its merger with 
Maersk Drilling in October 2022, Noble is 
prioritising the establishment of a robust 
baseline before setting decarbonisation 
targets. We expressed our preference for all 
the companies we invest in to set targets to 
reduce their operational emissions, at the very 
least. That being said, Noble finds itself in an 
interesting position – the industry standard 
is for the customer (not the operator) to take 
responsibility for the supply of and payment for 
fuel used during drilling campaigns. We wanted 
to understand this relationship, focusing on how 
Noble works with its customers to promote more 
sustainable operations – by either improving 
energy efficiency or using more sustainable fuels 
to operate the drilling rigs.  
The company is making clear to its customers 
that there is a business – as well as a moral – 
case for reducing energy consumption on its 
rigs. Noble is already committed to installing 
energy efficiency equipment across its fleet and is 
conducting feasibility studies to operate some of 
its rigs using alternative fuels. This work is being 
completed in cooperation with its customers 
and is a part of Noble’s wider research and 
development effort.  
Installing energy efficiency equipment and 
analytics tools will serve to collect and measure 
emissions data. The conversation turned to 
Noble’s intentions for disclosure and ESG 
reporting, and we learned that the company 
has a reporting workstream set up, with a 
comprehensive ESG report planned for release in 
2024. We expressed our views in favour of more 
disclosure through platforms and frameworks 
like CDP, the Task Force on Climate-related 
Financial Disclosures and the Global Reporting 
Initiative and explained how we, as investors, use 
these resources to conduct ESG analysis of our 
holdings. We also encouraged the company to 
engage with ESG ratings providers such as MSCI, 
especially as Noble scores poorly on safety.
Though operating in an indisputably ‘dirty’ 
sector, Noble emphasised its commitment 
to the energy transition by pointing to its 
Decarbonisation Taskforce and Steering 
Committee equipped with resources to drive 
operational changes. We are still learning 
about this company after its emergence from 
bankruptcy and the recent merger, and we 
hope to see it evolve towards more sustainable 
practices over time.  
NOBLE
RESPONSIBLE INVESTMENT REPORT Q2 2023

9
ENGAGEMENTS IN FOCUS
We have long held Volkswagen in the portfolio 
and have engaged with the company over many 
years. We continued this dialogue during 2023, 
meeting with the investor relations team to 
address our concerns about governance and 
Volkswagen’s supply chain. 
Given the company’s extensive supply chain, 
we discussed at length the responsible sourcing 
of critical raw materials and how Volkswagen 
monitors its supply chain. With over 60,000 
suppliers, Volkswagen focuses on those providing 
most of the purchasing volume and has a 
certification process in place for all suppliers. 
The company reports annually in a separate 
Responsible Raw Materials Report, detailing its 
progress on risk management and transparency 
in its raw materials supply chain. In 2021, the 
company also joined a pledge for a moratorium 
on deep sea mining and publicly committed not 
to source minerals from the deep seabed.
Also within the supply chain, we were concerned 
about ongoing allegations of the use of forced 
labour, specifically the hiring of ethnic 
minorities in China through so-called labour 
transfer programmes. Earlier this year, MSCI 
deemed the issue a failure to comply with the 
United Nations Global Compact, which can have 
negative ramifications. The company confirmed 
an internal review has been conducted but 
MSCI requires a third-party audit before it will 
revisit its assessment. Given China’s strategic 
importance to Volkswagen, the company is 
sensitive to maintaining good relations with 
Chinese authorities and is unlikely to submit 
to a third party assessment. We discussed the 
company’s wider relationship with MSCI and 
other ESG ratings agencies and its intention to 
provide enhanced disclosure. 
On remuneration, we asked for an explanation 
for the increase in executive pay, which seemed 
high. We also discussed the board structure, 
as the current CEO of Volkswagen is also the 
CEO of Porsche. We were informed that robust 
governance measures were in place to avoid any 
conflict of interest, which reassured us, given 
that the CEO’s dual role is unlikely to change 
in the near future. With respect to the audit 
committee not being fully independent, we 
expressed our preference for new appointees. 
We plan to continue our dialogue with 
Volkswagen and will use future meetings to 
discuss energy transition opportunities in the 
context of the company’s wider corporate strategy. 
VOLKSWAGEN

We are long-term investors in ArcelorMittal, 
a global leader in steel production, and have 
engaged with the company for many years, 
both collaboratively (as co-lead investor of the 
Climate Action 100+ initiative working group) 
and independently. We met the company twice 
this quarter, to discuss ESG progress, health and 
safety, and the energy transition. 
The first meeting, with the investor relations 
team, provided an insight into the ESG progress 
the company has been making over the past few 
months. Given the nature of operations in the 
steel-making industry, we addressed health and 
safety considerations and how these risks are 
being managed in certain jurisdictions more 
prone to accidents, especially in light of a large 
number of fatalities last year. The company 
assured us that it is working with consultants 
and implementing controls and systems, and 
its 2023 investment programme will focus on 
upgrading equipment and acquiring new tools, 
as well as offering training to employees and 
contractors. The ties between health and safety 
performance and executive remuneration have 
been strengthened, featuring in both short-term 
and long-term incentive plans. 
Historically, the main focus of our engagement with 
ArcelorMittal has been the company’s transition 
to Net Zero. The company has committed to 
reducing its European CO2 emissions by 35% 
by 2030 and to be carbon neutral globally by 
2050. We also discussed how ArcelorMittal could 
harness green steel as a competitive advantage and 
how it is preparing to align its reporting with a new 
European framework.  
Our second meeting was with the head of 
ArcelorMittal’s XCarb innovation fund, 
which seeks to invest in the development of 
breakthrough decarbonisation technologies. 
We discussed  the strategy of the fund and how 
its investments are driving ArcelorMittal’s 
decarbonisation strategy. The company has 
invested almost $160 million in disruptive sectors 
such as hydrogen production, clean energy,  
long-duration energy storage and novel 
steelmaking processes. We encouraged the 
company to better articulate to investors how its 
venture capital activity is shaping ArcelorMittal’s 
understanding of transition pathways and the 
implementation of its Net Zero plan. We look 
forward to seeing further details of ArcelorMittal’s 
progress and targets in its next Climate Action 
Report and we will analyse where we can urge the 
company to make further improvements.
ARCELORMITTAL
10
STEWARDSHIP ACTIVITIES IN Q2 2023

Voting in focus
Voting and engagement make up the twin pillars of stewardship and, whilst we 
engage with companies year-round, voting season is generally concentrated in the 
second quarter. We take our voting responsibilities seriously. The opportunity to 
vote enables us to encourage boards and management teams to consider and address 
areas we are concerned about, or to show our support. We review relevant issues 
and exercise our judgement, based on our in-depth knowledge of each company, 
and we aim to be clear, consistent and thoughtful when casting our vote. We have a 
proxy voting policy and supplement this with internal voting guidelines that provide 
context for voting decisions. 
GLENCORE
We voted to approve the 2022 Climate Report, 
despite ISS’s recommendation to vote against. 
Questions persist over the company’s alignment 
with the Paris Agreement, and ISS raised 
concerns about its investment in the energy 
transition, and its advocacy and lobbying 
activities. In our view, running off its coal assets 
over time is necessary if it is to align with the 
Paris Agreement, as the carbon reduction from 
the closure of coal assets would far outweigh any 
transition investments. However, we recognise 
that much of Asia relies on both thermal and 
metallurgical coal for its energy and industrial 
needs, and this demand is unlikely to change 
in the short term. Glencore’s track record in 
reducing its emissions so far seems to be tracking 
the company’s stated plans, so we are satisfied 
with its progress. 
We also voted in favour of a shareholder 
resolution on the next climate action transition 
plan, in line with ISS and against management. 
The proposal seeks clarification and information 
in Glencore’s next climate report, including 
disclosure of how projected thermal coal 
production and associated capital expenditure 
aligns with the Paris Agreement and the extent 
of any inconsistencies with the IEA Net Zero 
scenario timelines. We think the proposal to 
request additional information on the transition 
plan is the most appropriate next step. 
RESPONSIBLE INVESTMENT REPORT Q2 2023

12
AMAZON
We voted against two directors whose tenure 
breaches our internal threshold. Over-tenured 
directors can lead to entrenchment, which 
in turn can compromise independence and 
diminish a board’s effectiveness in representing 
the interests of shareholders. We voted in 
favour of ratifying the named executive officers’ 
compensation, against ISS’s recommendation. 
Our view is that the company does not want 
employees to focus on short-term returns or 
discrete criteria at the expense of long-term 
growth and constant innovation and reinvention, 
a position we endorse. 
There were a number of shareholder proposals 
on the slate at this year’s AGM and, for the most 
part, we voted in line with ISS. We supported the 
request for a report on customer due diligence to 
determine whether customers’ use of Amazon’s 
products and services with surveillance, 
computer vision or cloud storage capabilities 
contributes to human rights violations. Such a 
report may highlight some concerning issues 
that, if addressed, could protect Amazon from 
reputational damage in the future. We also 
supported the request for a report on the impact 
of climate change strategy consistent with Just 
Transition guidelines as disclosure can help 
shareholders evaluate the effectiveness of the 
management of environmental and social risks. 
Other disclosures we supported included a report 
on climate lobbying, a report on gender and 
racial pay gaps, a third party audit on working 
conditions, a report on efforts to reduce plastic 
use and a study on the risks associated with 
the use of the company’s Rekognition computer 
vision platform. 
We did not support requests for a report on 
climate risk in retirement option plans, greater 
disclosure on government requests, a tax 
transparency report, a cost benefit analysis of 
diversity, equity and inclusion programmes, 
amendments to the company’s byelaws, pay 
disparity disclosures, an animal welfare 
standards report or to establish a public  
policy committee. 
VOTING IN FOCUS

BP
We voted against a shareholder resolution 
calling for BP to align its existing 2030 
emissions reduction aims covering Scope 3 
emissions with the goal of the Paris Agreement. 
ISS also recommended a vote against; whilst 
acknowledging the merits of the proposal, it 
noted that the proposal would represent a change 
in strategy, implying a potential constraint on 
the board’s ability to develop and implement 
strategy. BP has, in our opinion, outlined a 
credible transition strategy with appropriate 
decarbonisation targets that reflects demand for 
oil and gas derived energy whilst allocating up to 
$8 billion more to its ‘transition growth engines’. 
Although BP has tightened and reduced its 2025 
and 2030 aims, it has retained its 2050 Net Zero 
target. BP argues the transition is uncertain, 
so locking into one, fixed strategy (through 
investing or divesting the wrong asset) will not 
help to generate shareholder value. 
The resolution asks BP to align its 2030 Scope 
3 aims with Paris. We agree with ISS that this 
would require a wholesale shift in strategy, which 
we believe is unnecessary given the board has 
opined on Net Zero and already published its 
plan. Secondly, BP has no control over what global 
Scope 3 emissions should be under the Paris 
Agreement, as the world continues to emit carbon 
and the Scope 3 reduction will probably have to 
be steeper the nearer society gets to 2030. This 
burden is unfair, particularly in the context of BP 
making long-cycle investment decisions and the 
fact that its downstream Scope 3 emissions will be 
significantly influenced by future developments 
in energy and transportation infrastructure and 
government policy. 
RESPONSIBLE INVESTMENT REPORT Q2 2023

About Ruffer
OUR AIM IS TO DELIVER CONSISTENT POSITIVE RETURNS —  
WHATEVER HAPPENS IN FINANCIAL MARKETS.
To invest well, we need to take on risk. With risk comes great responsibility.  
Our preoccupation is with not losing money, rather than charging headlong for growth. 
It’s by putting safety first that we have made good money for our clients. Through boom 
and bust. For over 28 years. If we keep doing our job well, we will protect our clients’ 
capital – and increase its real value.
ESG factors form one part of our fundamental analysis. We have a collaborative research 
process between the research analysts, members of the responsible investment team, 
and responsible investment specialists. To fulfil our duty to act as responsible stewards 
of our clients’ assets, we use our judgement to determine when to engage and how 
to vote at shareholder meetings to best protect the economic interests of our clients, 
while remaining cognisant of the impact on all stakeholders. Engagement with the 
companies we invest in not only gives us an opportunity to deepen our understanding  
of the business, but also is an effective tool to achieve meaningful change.  
OUR RESPONSIBLE 
INVESTMENT 
FRAMEWORK
MACRO
MICRO
STAKEHOLDERS
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We believe that investing responsibly will lead to better  
long-term outcomes for our clients.
14
RESPONSIBLE INVESTMENT REPORT Q2 2023

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