UK STEWARDSHIP
CODE 2023
ANNUAL  
REPORT
April 2024
The Quality Growth Investor

CONTENT
MESSAGE FROM OUR CIO................................................ 3
PRINCIPLE 1.......................................................................  4
Signatories’ purpose, investment beliefs, strategy and 
culture enable stewardship that creates ­long-term value 
for clients and beneficiaries ­leading to sustainable 
benefits for the economy, the ­environment and society
PRINCIPLE 2....................................................................... 8
Signatories’ governance, resources and ­incentives 
support stewardship
PRINCIPLE 3.....................................................................  14
Signatories manage conflicts of interest to put the best 
interests of clients and beneficiaries first
PRINCIPLE 4.....................................................................  16
Signatories identify and respond to market-wide and 
systemic risks to promote a well-functioning financial 
system
PRINCIPLE 5....................................................................  29
Signatories review their policies, assure their processes 
and assess the effectiveness of their activities
PRINCIPLE 6...................................................................... 31
Signatories take account of client and beneficiary needs 
and communicate the activities and ­outcomes of their 
stewardship and investment to them
PRINCIPLE 7....................................................................  36
Signatories systematically integrate stewardship and 
investment, including material environmental, social and 
governance issues, and climate change, to fulfil their 
responsibilities
PRINCIPLE 8 .................................................................... 43
Signatories monitor and hold to account managers  
and /or service providers
PRINCIPLE 9....................................................................  45
Signatories engage with issuers to maintain or enhance 
the value of assets
PRINCIPLE 10................................................................... 53
Signatories, where necessary, participate in 
collaborative engagement to influence issuers
PRINCIPLE 11...................................................................  55
Signatories, where necessary, escalate stewardship 
activities to influence issuers
PRINCIPLE 12...................................................................  58
Signatories actively exercise their rights and 
responsibilities
CLOSING REMARK..........................................................  66
ESG team biographies
The Quality Growth Investor
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Franz Weis  
Chief Investment Officer (“CIO”) and Chair of Comgest’s Sustainability Committee
MESSAGE FROM OUR CIO
Comgest is pleased to submit its Annual Stewardship Report for the period 1 January to 
31 December 2023. 
This report sets out how we have applied the 12 Principles of the UK Stewardship Code throughout 
2023 and how we continue to invest in and develop our stewardship activities in line with our 
mission, our investment philosophy and our business model. We thoroughly support the Financial 
Reporting Council’s work in Stewardship and Governance.
As a quality growth, long-term investor, we look for companies that can deliver sustainable 
investment returns. We believe that value creation is enhanced when companies deliver social 
utility, while limiting negative impact to the environment. ESG analysis is therefore fully integrated 
within our fundamental research on each company and throughout our investment decision-
making process. As active owners, we strive to improve ESG practices through targeted company 
engagements and by voicing our opinions through responsible voting. Importantly, our interests are 
focused on the long-term and aligned with our clients because of our broad employee partnership 
model. 
Over the past year, we have witnessed a sharp increase in the volume of ESG information requested 
by our clients. Our segregated mandate clients are also integrating increasingly bespoke ESG 
tailoring to meet their needs and organisational goals. We continue to add resources to ensure we 
can meet these demands and add value to our clients in their ESG journeys. In 2023, as a signatory 
to the Net Zero Asset Managers (NZAM) initiative, we published our first climate-related targets.  
These targets allow us to both prioritise our engagement resources on companies facing the most 
significant climate risks and to assess the sustainability of their business models. 
We acknowledge that there is a need for ongoing learning and development. We continue to face 
a changing regulatory landscape and increasingly bespoke client needs. We have made further 
investments in ESG resources, servicing capabilities and operational infrastructure. We are also 
carefully ensuring that all teams at Comgest absorb and apply ESG knowledge. In this endeavour, 
training has been a key focus over the year and will remain so for the years to come.
The Quality Growth Investor
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Signatories’ purpose, investment beliefs, strategy and culture enable stewardship 
that creates long-term value for clients and beneficiaries leading to sustainable 
benefits for the economy, the environment and society
OUR PURPOSE
Comgest’s purpose has remained unchanged since the company was founded over 35 years ago: “to provide 
consistent, quality growth investment across global equity markets, and to promote a long-term, responsible and 
independent mindset – within the culture of our enduring partnership.”  
INVESTMENT BELIEFS
We engage in responsible investment because we 
believe it enhances our financial performance as long-
term investors and delivers multiple forms of value to 
our clients. Responsible investment has always been 
an integral part of our investment philosophy and 
approach because we believe that:
	– Markets may fail to correctly value businesses with 
strong and sustainable competitive advantage and 
persistent above-average earnings growth; 
	– The integration of ESG enables a better assessment of 
quality; and 
	– Sustainable value creation is enhanced when 
companies deliver social utility, integrity and 
differentiation.
We believe that a company’s responsible approach 
to environmental, social and governance issues 
will impact positively on the sustainability of their 
growth over the long-term. In assessing these factors 
carefully, the integration of our proprietary ESG 
research into our fundamental analysis enables 
Comgest’s Investment team to perform a more 
comprehensive assessment of “quality”. 
We also know that value for our clients derives not 
only from the financial returns we deliver or the 
service we provide but from the consistency and 
transparency of our responsible investment approach. 
This philosophy is fully reflected in our portfolio 
decisions. We build concentrated portfolios of 
typically 25 to 50 stocks, with a high active share and 
without reference to a benchmark (which by extension 
means that we consider risk in terms of absolute loss 
of capital rather than underperforming an index). 
We identify quality growth companies through years 
of fundamental research and engagement with their 
management, gaining deep insight into their business 
models, their culture and the social utility they 
generate. The relationships we build with investee 
companies in this way are further consolidated by the 
fact that we are long-term shareholders – our average 
holding period is 3 to 5+ years. 
Comgest has always integrated both qualitative and 
quantitative non-financial factors in its research and 
many of the criteria we use to assess company quality 
are related to ESG issues, as shown in  Figure 1.
STRATEGY AND CULTURE
Our objective is to maintain a quality product offering, 
consistently adhering to our strategy of investing 
in quality growth companies with a long-term 
investment approach. Our business model supports 
our investment beliefs. We regard our independent 
ownership structure as a key advantage to implement 
an unbiased and effective engagement and advocacy 
strategy. 
Comgest’s founders built the company around three 
core pillars, which continue to guide our actions:  
	– Freedom: to invest in line with our convictions and 
our values 
	– Transparency: to promote sharing as much 
information as possible both internally and 
externally, building knowledge and trust 
	– Collaboration: our flat organisational structure 
promotes autonomy and a team approach to 
decision making. Collaboration is incentivised by 
our broad partnership structure, with employees 
across all functions of the business having a shared 
stake in the company’s success. 
PRINCIPLE 1
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Our broad partnership structure was established from 
the founders’ belief that employees should have a stake 
in the company’s success. Comgest has always been 
100% owned by employees and founders. Today, there 
are over 200 employees at Comgest, of whom 180 are 
employee-shareholders, investing their own assets to 
build a stake in the company. Currently, all Investment 
team members with over five years of tenure are 
shareholders.
Comgest shareholders typically build their stakes in 
the company gradually over many years, with capital 
transferring to successive generations of employees 
over decades. As long-term owners of Comgest, we 
are determined to pass along the company to the next 
generation in better shape than when we first invested.
This partnership structure underpins the strategy and 
culture of Comgest, and ultimately the stewardship of 
our clients’ and our own capital:
	– It creates consistency and stability: we have 
maintained the same investment philosophy 
since Comgest was founded, through all market 
conditions; our employee turnover is low (7.5% 
in 2023), so we do not lose accumulated research 
knowledge and relationships with investee 
companies. 
	– It encourages us to think long term: we commit 
our own capital for many years, and this is aligned 
with the way we invest on behalf of our clients. 
We are prepared to spend the time necessary on 
thorough research to identify what we consider 
to be exceptional companies and to maintain our 
investments in them patiently to benefit from 
compound growth. 
	– It means that we have skin in the game: because 
we are long-term owners of Comgest, we have a 
strong incentive to be responsible owners of our 
portfolio holdings. We are acutely aware of ESG 
risks that – if they materialise – could destroy value 
for our clients and consider it our responsibility 
to engage with investee companies on any issues 
that we think could be prejudicial to their future 
sustainability.
 
Figure 1. Comgest’s Quality Growth Selection Criteria
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The Comgest Group¹ is committed to its time-tested 
strategy of selecting quality growth companies that 
we believe will prosper sustainably. Our long-term 
investment horizon, incentivised by Comgest’s broad 
partnership structure enables us to engage with 
companies over the long term, striving for continual 
improvement.  We seek to deliver value to our clients 
by utilising time-horizon arbitrage, looking beyond the 
short-term market “noise” to identify drivers of long-
term performance. We look to constantly improve 
and sharpen our stock selection process as well as the 
depth and breadth of our research. We believe that our 
strategy is best achieved with a team-based approach 
to investment decision-making, and we aim to maintain 
efficient and highly motivated operational and client 
servicing teams.
We are highly conscious of the trust that has been 
placed in our firm when clients invest with us. As 
employee-owners, we share our clients’ risks as well 
as their rewards. As our client base evolves, we seek 
to ensure that our investors share our values and 
that they understand the long-term nature of our 
investment philosophy.
CREATING LONG-TERM VALUE FOR CLIENTS
We endeavour to serve the best interests of  
our clients by:
	– Offering a single investment philosophy that 
is clearly expressed to and understood by our 
clients, and continually improving our capabilities 
to implement that philosophy
	– Interacting regularly with our clients to 
understand their expectations and to jointly 
evolve in our thinking about investment, 
stewardship and ESG practices
	– Making enhancements to our products and 
product range in order to tailor to evolving client 
needs
	– Ongoing evolution of our client communications 
and in particular our reporting; ensuring that 
we continue to meet our clients’ changing 
information needs 
We seek to deliver attractive long-term performance 
through our stock selection. Clients who choose 
to work with us can be confident that we will not 
dilute our investment approach nor embark on asset 
gathering beyond our implementation capabilities. 
We can adapt to bespoke needs where solutions 
are in line with our approach. To this end, we have 
created new investment vehicles, tailored segregated 
mandates and multiple new forms of investment 
reporting in response to client demands. These are 
further detailed in Principle 6. 
ASSESSMENT OF EFFECTIVENESS IN SERVING THE BEST INTERESTS OF CLIENTS
Our client base exhibits many examples of 
exceptionally long tenure, with some investors that 
we have been honoured to work with for over a 
decade, and others for more than two decades. The 
willingness of many of these longstanding clients to 
act as a reference for new business opportunities 
points strongly to the success of our mission and is 
testament to our quality and efficiency. 
The longevity of our business relationships also 
demonstrates that investors understand that 
our approach works best over the long term and 
requires patience during times of short-term 
underperformance. We believe long-term investment 
and responsible investment go hand-in-hand. Our 
average client tenure within segregated mandate 
portfolios since inception is six years. 
We monitor several key internal metrics to assess 
our effectiveness in serving the best interest of our 
clients, including client asset inflows and outflows, 
client retention rates and patterns emerging from the 
rationale leading to redemptions (e.g., performance-
related, asset allocation-related, product suitability-
related). 
1  The Comgest Group includes six asset management companies: Comgest, S.A. (Paris), Comgest Far East Ltd (Hong Kong), Comgest Asset Management International Ltd 
(CAMIL)(Dublin), Comgest Asset Management Japan Ltd (Tokyo), Comgest Singapore Pte Ltd (Singapore) and Comgest US LLC (Boston). Comgest also has the following 
service locations: Comgest Deutschland GmbH (Düsseldorf), Comgest Benelux B.V. (Amsterdam), Comgest Australia Pty Ltd (Sydney), as well as offices of CAMIL in 
London, Milan, Brussels and Vienna.
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The Quality Growth Investor

Feedback on effective servicing is requested directly 
during meetings rather than by automated, generic 
surveys. We regularly ask our clients if they are 
receiving all the information they need, if we can 
improve or if there is anything more that we can 
provide to assist them in monitoring their investment 
with us. We seek to learn from these discussions, 
to gain insight into our clients’ thinking, their key 
concerns and any changes in strategic direction. The 
Investor Relations team’s meeting notes are entered 
into our CRM system and regularly reviewed by 
the Head of Investor Relations who monitors client 
meetings for any issues or patterns that may arise, 
which are then addressed with the relationship 
management team members. We have considered 
issuing a broader, more formal survey to our clients, 
but as a boutique-style asset manager who remains 
close to its clients, we still believe the best assessment 
of our effectiveness is obtained via on-the-ground 
interaction with clients. 
We do utilise third-party surveys and studies to 
assess where Comgest stands relative to other asset 
management firms with respect to overall client 
experience. We also send client questionnaires at 
investor events to gather information and inform our 
relationship management strategy. 
The Investor Relations team conducts monthly 
world-wide meetings where client trends, needs and 
issues are discussed. These discussions may lead to 
changes to our reporting, ESG labelling of products 
and also amendments to the public fund prospectus 
documentation (e.g., the 2023 prospectus update for 
our Irish public funds included a range of ESG-related 
enhancements to tailor to evolving investor needs as 
well as regulatory requirements).
Effectiveness can also be demonstrated by the various 
external scores, categorisations and labels attributed 
to Comgest with respect to responsible investment:
	– In 2010, Comgest made an official commitment to 
responsible investment by becoming a signatory 
to the Principles for Responsible Investment (PRI), 
a voluntary international initiative launched in 
2006. In 2023, we received a 5-star rating in two 
categories: “Confidence building measures (100%)”, 
“Direct - Listed equity - Active fundamental (93%)” 
and a 4-star rating in the “Policy Governance and 
Strategy (87%)” category, above median in each of 
these assessment modules.2  
	– A selection of our strategies applies each year 
to receive leading European sustainable and 
responsible investment (SRI) labels: In 2023, 
Comgest’s “Plus” funds again received the Towards 
Sustainability (Febelfin), FNG and LuxFlag ESG 
labels, and 10 other public funds have received the 
LuxFlag ESG label.
	– Our products feature on numerous investor buy 
lists, in multiple geographic regions in their specific 
“sustainability” or “ESG” categories, demonstrating 
a product profile that meets investors’ needs 
according to their definitions for this category.
	– At the end of December 2023, Comgest had 25.3 
billion GBP under direct management, of which 19.2 
billion GBP was categorised as Article 8 under SFDR³ 
(funds that promote environmental and/or social 
characteristics), representing 75.9% of all funds and 
mandates managed by Comgest.
2  Please refer to the Assessment Report for further details on the ratings, which are based on the PRI Assessment Methodology.
³ SFDR refers to the Sustainable Finance Disclosure Regulation implemented by the European Union.
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The Quality Growth Investor

Signatories’ governance, resources and incentives support stewardship
Comgest is an independent group owned by its employees and founders. This ownership structure is central to our 
approach to stewardship: as an independent asset manager, we are free to implement our investment philosophy 
without the pressure to respond to short-term market movements; we are also free to decline to work with clients 
who do not share our beliefs and whose interests may therefore not best be served by working with us.
PRINCIPLE 2
OUR GOVERNANCE 
The governance structure of Comgest Global Investors, 
S.A.S, the Group holding company (shown in Figure 2), 
includes the following governance bodies:
	– The Board of Partners of Comgest Global Investors, 
S.A.S. serves as the strategic oversight body for the 
Group. 
	– The Executive Committee brings together the 
investment and operational sides of the business 
to ensure that strategic initiatives meet client 
and regulatory concerns and that the operational 
support is provided to manage risks and deliver on 
opportunities.
	– The Sustainability Committee maintains high-level 
oversight of all responsible investment-related 
activities and serves to assist the broader Comgest 
partnership and the Boards of the Group entities 
in the application of the Group’s Responsible 
Investment Strategy (“RI Strategy”). 
	– The Investment Committee is chaired by Comgest’s 
CIO and is responsible for overseeing portfolio 
management processes across the Group entities, 
including ESG integration.
	– While the Group level governance helps to ensure 
a common strategy and approach, the asset 
management entities of the Comgest Group are 
responsible for approving and implementing the 
policies in the day-to-day activities. 
Figure 2. Group Governance Structure
The Quality Growth Investor
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Comgest Sustainability Committee
Chaired by Comgest’s CIO, the Sustainability 
Committee members represent a wide variety 
of teams including Portfolio Management, ESG, 
Compliance and Risk, Marketing, Investor Relations, 
and Operations. 
The Sustainability Committee’s mandate and key 
objectives are to:
	– Assist in the further definition of the Group’s RI 
Strategy
	– Ensure the RI Strategy is adequately articulated in 
the Group’s policies, operations, and disclosures
	– Oversee the implementation of the RI Strategy
	– Address ad hoc sustainability matters that may be 
raised to the Committee
The Sustainability Committee also seeks to assist 
Group entities in their understanding of regulatory, 
market or commercial developments with respect to 
responsible investment and the recommended course 
of action.
The Committee convenes at least every two 
months and addresses an evolving agenda in line 
with the business’s activities. At each meeting, 
a recurring report is reviewed which includes 
material engagements, notable controversies and 
any reputational risk events. The Sustainability 
Committee prepares an annual report for the 
Executive Committee.
RESOURCING 
Comgest’s RI Strategy is implemented by the Group’s 
Investment team with the ESG team as coordinators 
and stewards of the ESG integration process, under 
the supervision of the CIO and the Group Investment 
Committee. The Investment team includes dedicated 
ESG analysts organised by region.
Investment Team
Comgest’s Investment team comprises 49 portfolio 
managers and analysts organised by geography, 
including five dedicated ESG analysts (Figure 3). 
With Comgest’s singular, quality-focused and 
long-term approach to investing, we regard ESG 
credentials as an important component within the 
team’s selection criteria. 
Team members have an average of 15 years’ industry 
experience. All members of the Investment team 
are considered to be key ESG resources as they are 
directly involved in ESG research as part of their 
fundamental analysis. They also conduct stewardship 
activities including responsibility for company voting 
and carrying out individual engagements, often 
together with a member of the ESG team.
Given the broad resource of the Investment team 
and the fact that each portfolio is concentrated (25-
50 stocks), significant time is allocated to the quality 
assessment of each investee company. Analysts 
typically cover 10-15 investee companies allowing for 
a great depth of insight and engagement. 
We believe that our approach of integrating ESG 
responsibility within the Investment team has 
important benefits in terms of stewardship. Comgest’s 
investment strategy is based on acquiring a deep 
knowledge of our portfolio companies and building 
relationships with their management over many years. 
Our structure ensures that investment professionals 
who have the deepest understanding of our portfolio 
companies, and the context in which they operate, are 
able to bring that knowledge into our proprietary ESG 
analysis. The Investment team members leverage the 
work of the central ESG team by using their guidance, 
training and specialist input.
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Dedicated ESG resources
The ESG team is responsible for the day-to-day 
implementation of the firm’s ESG framework, at both 
corporate- and portfolio-level. Since the hiring of our 
first ESG analyst more than a decade ago, Comgest’s 
dedicated ESG resources have evolved considerably 
and as of the end of 2023 comprised nine members 
who fulfil two distinct functions: Responsible 
Investment and Responsible Development. Both 
functions report directly to the CIO.
	– The Responsible Investment function is carried 
out by experienced investment professionals, 
each focused on company coverage within 
specific geographic regions. Importantly, they are 
embedded within Comgest’s Investment team, 
rather than operating as a siloed function. As an 
integrated part of the Investment team, the ESG 
analysts work alongside our company analysts 
attending company meetings, performing research 
and conducting proprietary ESG assessments. They 
also participate in proxy voting, individual company 
engagements and broad ESG research.
	– The Responsible Development function comprises a 
specialist team leading thematic and collaborative 
engagement on topics such as climate change, 
biodiversity, and human rights. The team oversees 
ESG strategy, advocacy initiatives, policies, 
regulation, internal training, and communication of 
Comgest’s RI strategy.
Our ESG professionals have significant asset 
management and specialist ESG expertise, with 
an average of 15 years’ industry experience. Their 
broad-ranging professional, cultural and educational 
backgrounds contribute to diversity of thinking and 
complementary skill sets. Biographies are available on 
our website, under 
 “Our ESG Story”. 
In addition to our proprietary research, the ESG 
team draws on extra-financial information sources, 
such as companies’ corporate social responsibility 
(CSR) reports, information and alerts from specialist 
providers, contacts with companies and their 
stakeholders, NGOs and media reports. Figure 4 shows 
the external providers – selected for the quality of 
their information and their geographical coverage – 
that are currently used by the team. 
A number of other Comgest professionals are involved 
in responsible investment implementation including 
members of the Middle Office, Project Management, 
Compliance, Risk, Legal, Data Management, Investor 
Services and Marketing & Communication teams.
Figure 3. Comgest Investment Team
Updated as of 01-Jan-2024.
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Figure 4. External Data and Information Providers
TRAINING
Company-wide ESG related training
Comgest is committed to ongoing ESG training to 
ensure that we remain well equipped to respond to 
the dynamic regulatory and investment landscape, 
the needs of our clients and the increasing 
availability of ESG data. 
In 2023, Comgest continued its company-wide 
internal ESG training programme to ensure that 
the knowledge base across all employees evolves as 
necessary. Over the year, our training programme 
covered a broad range of topics including ESG 
basics, the regulatory environment, biodiversity, 
climate and the strategy for implementation of our 
Net Zero commitment. 
Dedicated training sessions were also organised for 
several teams:
	– A dedicated ESG workshop during Comgest’s 
annual investment offsite “best practice seminar”. 
This gathers all Investment team members from 
around the world to learn from our experiences 
and share best practices. ESG training focuses on 
both broader topics such as climate change and 
sustainable finance regulation as well as specific 
issues relevant to a particular company or industry.
	– ESG Q&A sessions organised for Investment and 
Investor Relations teams to enable them to better 
understand client queries, the implementation of 
our ESG strategy, our climate policy as well as the 
ESG regulatory environment.
	– Bespoke training sessions were also organised for 
employees tailored to the implications for various 
functions of the company (e.g., Investor Services, 
Compliance, Legal, RFP, and Risk Management) on 
evolving ESG topics. The ESG team likes to include 
ESG case studies to bring topics to life and ensure 
interactive discussion throughout training sessions.
	– We also run training sessions and workshops with 
external experts and facilitators. For instance, 
employees are encouraged to join a Climate Fresk 
workshop to strengthen their knowledge on climate 
change.
ESG team training
The ESG team members keep their skills, knowledge 
and thinking up-to-date through their daily 
research as well as membership in the Responsible 
Investment Plenary and Corporate Governance 
Committee of the Association Française de la Gestion 
Financière (AFG – the French Asset Management 
Association). 
In addition, they regularly participate in external 
training (e.g., the IIGCC4), industry events and 
working groups as well as targeted seminars (e.g., 
those run by the PRI, industry groups and ESG data 
providers).
4 IIGCC refer to the Institutional Investors Group on Climate Change
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The Quality Growth Investor

DIVERSITY 
As an equal-opportunity employer, we recognise 
the importance of all forms of diversity and we 
understand and value differences between people, 
including those of different age, gender, nationality, 
culture, ethnicity, disabilities and sexual orientation. 
We also seek cognitive diversity and strive to assemble 
teams of professionals with different educational 
backgrounds, personalities, skill sets, experience, and 
knowledge bases. We believe that diversity of skills 
and viewpoints leads to better informed discussions, 
greater creativity and open-mindedness and a more 
stimulating work environment. 
Our human resource practices deliberately seek out 
diverse profiles and our compensation system ensures 
that all employees are treated fairly. There are over 
30 different nationalities represented within our staff 
and we have achieved gender balance across the wider 
company, with 48% of our employees and 46% of our 
shareholder base being female. The firm seeks to 
have well balanced committees and working groups 
wherever possible, with equal female representation. 
Within our Investment team, 33% of the team are 
women, close to three times the industry average. 
Comgest’s Diversity, Equity & Inclusion (DEI) 
Committee comprises six members from various 
Comgest entities, is 50% women and includes 
representatives from a range of functions across the 
firm, including the Investment team. 
The DEI Committee is responsible for the development 
and implementation of DEI initiatives at Comgest as 
well as for reviewing ongoing external developments 
and initiatives across the industry. 
Comgest implemented several initiatives over 2023 
including: 
	– The DEI Working Group was formalised and is now 
the DEI Committee.
	– A formal DEI Policy was finalised and approved.
	– DEI awareness goals were introduced into the 
annual objective setting campaign. 
THE BENEFITS OF DIVERSITY
Diversity is one aspect of ESG criteria that we 
examine in our investee companies, because we 
believe that it is an important indicator of the 
potential for higher quality decision-making. 
The ESG team applies the same standards to 
itself as it does to other companies. 
We have built diversity within the ESG 
team across several dimensions, resulting 
in complementary skill sets: 67% of the 
team are women; the members of the team 
include six different nationalities, diverse 
professional experiences prior to joining 
Comgest; their educational backgrounds cover 
ten different tertiary education programs in 
four different countries ranging from Master’s 
degrees in Science to Financial Engineering 
to International Business Law. We believe it 
is important for ESG teams to contain a mix 
of individuals with both financial and non-
financial experience to stimulate broad and 
well-informed debates.
COMGEST’S DEDICATED ESG RESOURCES
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INCENTIVES
Comgest’s broad employee partnership structure and 
its remuneration policy are designed to incentivise 
long-term thinking and behaviour.
With this structure, employees who have been with 
Comgest for several years typically become partners 
of the firm, meaning they are personally invested 
in the share capital. Comgest employs a mix of 
short- and long-term employee incentives which are 
reflected in our bonus systems and equity ownership 
structure. Our underlying goal is for our incentive 
system to help drive long-term product performance 
and team stability. 
For the Investment team
All members of the Investment team are encouraged 
through their objectives and annual performance 
evaluation to properly implement the RI Strategy and 
systematically take ESG factors into account in their 
investment analysis and decision-making processes.
Variable compensation is based on a set of 
quantitative and qualitative criteria that favour 
processes and behaviour over outcomes. This is 
based on our belief that quality research inputs 
combined with sound methodology typically lead 
to positive outputs over the long-term, while short-
term outcomes can be random. The assessment 
incorporates responsible investment criteria including 
ESG integration, identification of sustainability risks, 
quality of engagement and participation in ESG 
training.
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PRINCIPLE 3
Signatories manage conflicts of interest to put the best interests of clients and 
beneficiaries first
As an independent Group (see Principle 1) owned by our employees and founders, Comgest is not affiliated with 
any brokers, counterparties or custodians. Comgest Group entities do not actively trade for their own accounts 
with the exception of the Group holding company which may seed or invest in Comgest funds. Employees do 
not sit on boards or hold other positions in our investee companies. This independence assists us in avoiding 
conflicts of interest and in carrying out Comgest’s activities based on our long-term objectives and in the best 
interests of our clients. 
Despite the foregoing, Comgest operates in an environment where it will face actual, potential or apparent conflicts 
of interest. We recognise that a policy for the identification, prevention or management of conflicts of interest is 
essential, and that a failure to identify and manage conflicts may lead to reputational and regulatory risk for the 
business.
Our Conflicts of Interest Policy is provided to our clients and is available upon request. The Comgest Group’s 
policies and procedures have been designed to identify and properly disclose, mitigate and/or eliminate applicable 
conflicts of interest. The Compliance department is responsible for identifying possible conflicts of interest that 
may arise, ensuring procedures are established to reduce the risk of occurrence and to manage any conflicts that 
do occur. In the event of a conflict of interest arising despite the organisational and administrative arrangements 
in place to prevent them, the matter would be raised to the Compliance department, the client or investor 
concerned would be informed (in an appropriate durable medium), and Comgest would endeavour to resolve the 
conflict in the best interest of all parties.
CONFLICTS OF INTEREST MAPPING 
As part of the conflicts of interest framework, 
a Conflicts of Interest Mapping (the ‘Conflicts 
Mapping’) is undertaken by the Group’s Compliance 
departments of the different Comgest regulated 
entities. The Conflicts Mapping looks to anticipate 
potential conflicts that could impact the Group, 
entities within the Group and clients. The Conflicts 
Mapping takes into account any circumstances 
of which Comgest is aware that may give rise to a 
conflict of interest as a result of the Group structure 
and business activities. 
The Conflicts Mapping looks to:
	– Identify and describe potential conflicts; 
	– Determine how each conflict is managed  
or mitigated; 
	– Describe disclosure obligations,  
where relevant; 
	– Cite policies or procedures that have been 
implemented in order to manage or avoid the 
conflicts; and
	– Identify the parties in conflict, whether internal or 
external to Comgest.
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CONFLICTS OF INTEREST LOG
When a potential conflict of interest is identified, a conflicts of interest assessment is undertaken. The assessment 
is conducted by Compliance and the relevant Board of Directors, where required. The Compliance departments 
maintain a Conflicts of Interest Log to document the assessment of, and response to the conflicts.
Areas of potential conflicts include:
	– Proxy voting: Potential conflicts may arise in 
relation to the proxy voting process. We have put in 
place a number of actions to minimise such risks. 
	§ Votes are based on pre-determined Proxy 		
	
Voting Rules and any deviations have to be 	
	
justified, thereby limiting the discretion of 	
	
fund managers/advisors and analysts. Clients 	
	
with segregated accounts may provide us with 	
	
their own voting rules. 
	§
Comgest is an independent company and we 	
	
only provide asset management services, 	 	
	
therefore, conflicts do not arise through other 	
	
	 activities or through relationships with 	 	
	
affiliates carrying out other activities. 
	§ Employees are required to report any positions 	
	
held in other companies (e.g., directorships). 	
	
With the exception of Comgest funds, 	
	
	
employees do not sit on boards or hold other 	
	
positions in the companies in which we invest. 
	§ We abstain from voting where a conflict of 	
	
	
interest may arise. For example, during 2023, 	
	
where Comgest’s open-ended public funds 	
	
were invested in other funds which are part 	
	
of Comgest’s product range, Comgest decided 	
	
not to exercise its voting rights at five general 	
	
meetings relating to these funds. 
	§ Read the  
 Comgest Group Active Ownership 	
	
Policy for further information.
	– Engagement activities: Conflicts may also arise 
in connection with our engagement activities. We 
endeavour to respect rules in relation to acting in 
concert with other shareholders and employees are 
appropriately trained to avoid risk of market abuse 
or access to insider information.
	– Sustainability risks and preferences: Comgest 
assesses if in the course of providing investment 
services a conflict of interest could arise 
which may damage the interests of a client, 
including their sustainability preferences or 
misrepresentation of investment strategies. 
Conflicts which may arise as a result of the 
integration of sustainability risks in processes, 
systems and internal controls are assessed as part 
of our Conflicts Mapping.
	– Personal dealing: Comgest’s Compliance 
departments maintain personal dealing rules 
which require employees to declare all securities 
accounts and to obtain pre-approval for dealing 
in securities that are defined as “reportable”. The 
Comgest Group prohibits employees from dealing 
in securities that are contained within the Comgest 
“Universe” of stocks (i.e., stocks that are eligible for 
investment in Comgest-managed portfolios).
	– Outside business activities: Comgest requires 
all employees to declare any outside business 
activities to Comgest’s Compliance departments 
in order to ensure that such activities do not raise 
any potential conflicts of interest with our clients or 
activities of the Comgest Group entities. Employees 
may be prevented from engaging in an outside 
business activity where a conflict would arise.
CONFLICT RESOLUTION
Comgest makes every effort to prevent conflicts 
of interest and, should they arise, to resolve them 
equitably in the interests of its clients. 
Where arrangements put in place by Comgest cannot 
prevent, with reasonable confidence, conflicts of 
interest from adversely affecting the interest of a 
client, Comgest shall disclose to the client the general 
nature and/or sources of the conflict of interest 
and the steps taken to mitigate those risks before 
undertaking business on behalf of the client. 
Notwithstanding the robustness of our policies and 
processes, we believe that our partnership structure 
is our most effective tool against conflicts of interest, 
because it creates strong alignment between our 
clients’ interests and our own. 
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PRINCIPLE 4
Signatories identify and respond to market-wide and systemic risks to promote a 
well-functioning financial system
As highlighted under Principle 1, our mission at Comgest is ‘to provide consistent, quality growth investment 
across global equity markets, and to promote a long-term, responsible and independent mindset – within the 
culture of our enduring Partnership’. It is therefore at the heart of our ambition as an investor to encourage well-
functioning financial markets which reward long-term investment and a keen awareness of financial and non-
financial risks. 
In delivering our highly active, quality-growth investment approach, we seek to identify market-wide and 
systemic risks affecting the commercial and financial landscape in which issuers operate. We do this through our 
own research, and we look to bring awareness to these risks through engagement with our investee companies 
and through our support for industry-wide initiatives.
OUR RISK MANAGEMENT PROCESS
As part of an annual risk assessment, the Comgest 
Group entities perform Risk Mapping which enables 
them to identify, assess, rank and take action on 
the risks inherent to the organisation, activities and 
products. It also allows Comgest to set its priorities, 
define a relevant compliance and internal control 
system, and allocate resources appropriately. 
Risks are identified and assessed during discussions 
with business-line experts including the Investment 
and ESG Teams, who are best placed to determine 
and assess the risks borne by the processes they 
use. Once identified, risks are classified into specific 
risk categories defined by Comgest. The mapping 
takes into account the identified risk, as well as any 
mitigating factors that would help to reduce this risk 
(e.g., procedures, controls and continuity plans).
Once a risk has been classified into a specific category, 
a business-line expert identifies potential risk events. 
Determining the causes of risks enables risk prevention 
levers to be identified and the appropriate controls, 
operating methodologies, etc., to be put in place.
This risk assessment method uses the  
following structure:
	– Identification of risks in each department;
	– Impact assessment;
	– Review of risk mitigation and controls to be applied 
to the raw risk;
	– Determination of residual risk score;
	– Drafting of action plans for further reduction of risk;
	– Determination of whether capital needs to be 
allocated, to cover the eventuality of the risk 
producing a financial loss for the company; and
	– Review by the relevant entity’s Risk Committee 
and subsequent approval by the relevant entity’s 
Board of Directors and submission to the Group-
level Risk Committee.
During the annual update, risks and risk categories 
are reviewed to determine whether any new risk 
categories or processes should be added or whether the 
application/rating of any existing risks has changed.
Since 2022, we have implemented a new risk category 
“Climate and ESG risks – transition” to our risk library 
to better capture the risks to the business, as it has 
to take on a number of new processes and practices 
to ensure that it manages Climate and ESG risks 
appropriately. This risk category looks to assess risks 
to the business resulting from failure to change and 
adapt to respond to Climate and other ESG issues 
and failure to respond to client and regulatory 
expectations in this regard.
We have considered the potential causes of this risk 
which we assess to be as follows:
	– Failure to understand the impacts of Climate and 
other ESG issues on the business and to adapt 
processes and controls accordingly; 
	– Failure of management to appropriately prioritise 
and allocate resources to ensure that the business 
adapts to this change appropriately;
	– Inability to manage client investment restrictions or 
objectives in relation to climate or other ESG issues;
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The Quality Growth Investor

– Systems are not adapted in order to manage client 
restrictions or reporting requirements in relation to 
climate or other ESG issues;
	– Absence of data to meet client or regulatory 
reporting requirements in relation to climate or 
other ESG issues; and
	– Absence of staff knowledge or training.
This assessment allows us to design processes and 
controls to seek to avoid or reduce the likelihood of 
these risks arising.
RISKS INHERENT TO FINANCIAL MARKETS
We believe that there is a risk that benchmarks and 
indices can in some circumstances distort financial 
markets. The weight of individual index constituents 
may become detached from their fundamental value, 
while investors may be forced into short-term or “herd” 
behaviour in an attempt to track a stated benchmark. 
Comgest is an active, benchmark-agnostic investor, 
which we believe is consistent with our fiduciary 
duties and enables us to contribute to preserving the 
price discovery mechanisms that are essential to a 
well-functioning financial system.
MARKET-WIDE AND SYSTEMIC RISKS
Comgest is a fundamental investor, and our 
research focus is at the company level, rather than 
commencing our research at the macro-economic 
level. By conducting thorough, on-the-ground 
research, we are able to identify emerging risks 
that are affecting companies across our investment 
universe. This is especially true for systemic risks that 
are associated with ESG factors: as shown in Figure 1, 
these factors are specifically addressed in the research 
process. The collaborative nature of our Investment 
team’s organisation means that areas of concern 
uncovered by one regional team will be shared with 
their colleagues in other regions, which is particularly 
valuable in considering the risks affecting globalised 
sectors of the economy. This enables us to monitor 
and deepen our understanding of thematic risks.
Our response to these risks is first to provide 
transparency to our clients. We started reporting on 
environmental and carbon footprints in 2011 and have 
expanded on this over the years to include portfolio 
data on social factors, such as the effective tax rates of 
our portfolio companies. Our 
 Annual Responsible 
Investment Report also includes an assessment of the 
transition risks and physical risks related to climate 
change relevant to companies in our portfolios as 
well as the impact and dependency of our portfolio 
companies on biodiversity. 
Monitoring systemic and market-wide risks using 
specific ESG factors and key indicators is a necessary 
(but not sufficient) first step in our attempt to tackle 
critical matters like climate change, biodiversity loss 
and human rights violations. We think a broader 
view is mandatory to properly assess Sustainability 
Risks that could lead to future global disruptions that 
have never been experienced. Our research and risk 
monitoring process therefore places great emphasis 
on assessing “outside-in” risks (external factors 
affecting well-functioning businesses and global 
markets) as well as “inside-out” material impacts 
caused by our investments to environmental, social 
or global economic factors (using Principal Adverse 
Impacts for the latter).
CLIMATE CHANGE: ASSESSING CLIMATE-RELATED RISKS 
Rising temperatures have already led to irreversible 
impacts across ecosystems (i.e., terrestrial, freshwater, 
ocean) and human systems (i.e., water scarcity 
and food production, health and well-being, cities, 
settlements and infrastructure) worldwide. Every 
incremental aspect of global warming will increase 
the frequency and intensity of weather events and will 
translate into additional severe risks for businesses, 
people and nature. At the same time, curbing global 
greenhouse gas emissions will imply a far-reaching 
transition across all sectors translating into both 
transition risks and opportunities for companies.  
As long-term quality growth investors, we believe that 
understanding our investee companies’ climate-
related risks and opportunities and engaging with 
them on material climate issues strengthens our 
research and investment process to deliver durable 
earnings to our clients.
Material climate-related risks and opportunities are 
integrated into our analysis of companies and into our 
investment decision-making process. 
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Our company and ESG analysts, who are regularly 
trained on climate-related topics, are responsible 
for identifying and assessing these material climate 
issues.
As part of our company research, we use the   
 Task Force on Climate-related Financial 
Disclosures (TCFD) framework to assess the transition 
risks and opportunities as well as the physical 
risks for all the companies in our main investment 
strategies. This company-level climate analysis 
is based on fundamental ESG research as well as 
third-party data. External data we use includes  
 MSCI’s Climate Value-at-Risk (Climate VaR). 
Climate VaR, based on the TCFD recommendations, 
is a forward-looking and return-based methodology 
which includes both transition and physical risk 
assessments. It can be negative (cost) or positive 
(gain) and the horizon is the next 15 years. Transition 
risk assessments include both policy risks and 
technology opportunities.  
Comgest also measures the carbon footprint of our 
portfolios and mainly uses a Carbon to Value metric. 
Using MSCI data, the metric allows us to estimate 
scope 1, 2 and 3 greenhouse gas emissions (GHGs) of 
a given portfolio’s holdings per million of portfolio 
currency invested, with the enterprise value including 
cash as the attributing factor. 
By calculating carbon footprints, we can identify: (i) 
which companies emit the most GHGs in absolute 
terms; (ii) whether portfolio companies emit higher 
levels of GHGs than others in the same sector; 
and (iii) which companies fail to provide data on 
GHGs. These companies can then be prioritised for 
engagement.
Furthermore, Comgest uses forward-looking 
metrics to assess the climate alignment of our main 
strategies and investee companies, such as:
	– MSCI’s  
 Implied Temperature Rise (ITR) metric. 
The ITR, expressed in degrees Celsius, is designed 
to show the temperature alignment of companies 
and portfolios with global temperature goals.
	– The  
  Science-Based Target initiative (SBTi) 
coverage rate of portfolios tracks the percentage 
of companies that have committed to setting 
science-based targets (SBT) and companies having 
approved SBTs by the SBTi. 
	– The Net Zero Investment Framework (NZIF) 
coverage rate of portfolios tracks the percentage 
of companies classified as “aligned”, “aligning”, 
“committed to aligning” and “not aligned”.
To provide transparency to our clients, we include 
climate data in our monthly fund fact sheets, 
available on our regional websites, and give 
additional, detailed information on our climate 
action in our Annual Responsible Investment Reports 
and Quarterly Responsible Investment Reports. This 
includes sharing updates on our progress against our 
Net Zero Asset Managers (NZAM) initiative targets 
which apply to 100% of our listed equity AUM and 
were accepted by NZAM in March 2023.
CLIMATE-FOCUSED INTERNAL RESEARCH 
When material climate risks are identified, we 
carry out climate-focused internal research. For 
instance, in 2023, our Investment team, supported 
by our ESG analysts, ran an in-depth analysis of the 
climate-related risks faced by two European airline 
companies held in our portfolios: Ryanair and Wizz 
Air. These two companies have been identified as the 
largest contributors to our portfolios’ Climate VaR, 
especially considering aggregated transition risks.
Aviation accounts for approximately 2% of global 
GHG emissions5 and close to 4% of the EU’s 
emissions6. Furthermore, aviation is one of the 
fastest-growing sources of GHG emissions. Before 
the COVID-19 crisis, the International Civil Aviation 
Organisation forecasted that by 2050 international 
aviation emissions could triple compared with 2015. 
5 https://www.iea.org/energy-system/transport/aviation
6 https://climate.ec.europa.eu/eu-action/transport/reducing-emissions-aviation_en
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As international travel demand recovers following the 
pandemic, the challenge of achieving the European 
Green Deal’s 2050 target of reducing transport emis-
sions by 90% by 2050 becomes more complex. The 
aviation sector will have to contribute to the reduction 
and the fact that the EU has included the sector in 
the EU emissions trading system (EU ETS) since 2012 
sets the tone: decarbonisation is a must for airlines, 
whether it is proactive or reactive to tightening regula-
tions will depend on the companies. 
Assessing this climate transition risk and quantifying 
its financial impact is central to our Investment 
team’s work. The team developed two scenarios, with 
varying carbon costs: 
	– Scenario 1: Free allowances are maintained in the 
EU ETS and the tonne of CO2 is priced at €25 per 
tCO2.
	– Scenario 2: Free allowances are removed in the 
EU ETS and the tonne of CO2 is priced at €100 per 
tCO2.
In scenario 1, both companies face similar EBIT7  
impacts, where carbon costs represent close to 15% of 
EBIT. In scenario 2, carbon costs grow exponentially, 
and our analysts estimate that companies will 
have to raise fares between 10% and 15% to pass on 
the additional costs linked to losing access to free 
allowances and the raised cost of CO2 per tonne. 
If EU ETS carbon pricing represents the bulk of our 
quantification of the climate transition risks, fuel 
price increases linked to access to Sustainable 
Aviation Fuels (SAF) and the Kerosene Tax linked to 
the revision of the EU’s Energy Taxation Directive 
do not help in balancing the equation: an equation 
with increasingly unknown variables, as consumers’ 
behaviours change either due to price increases and/
or their willingness to reduce their personal carbon 
footprints. 
To fly through this turbulence of uncertainty, the ESG 
team defined the cardinal elements they wanted to 
see to validate and monitor the long-term investment 
thesis. These include, for example: 
	– Carbon intensity reduction progress versus target, 
using gCO2 per revenue passenger kilometre (gCO2/
RPK); 
	– On track delivery of fuel-efficient planes; 
	– Fleet average load factor; 
	– EU ETS carbon market price (€/tCO2); and 
	– Ramp up of SAFs, with underlying KPIs relating to 
access and cost. 
Tracking these KPIs not only guides our analysis of 
the companies, but also drives the dialogue we hold 
with them. SAF pricing and availability were part of 
our discussion with companies in Q1 2023. We further 
engaged with Ryanair in Q2 on reduction of free EU 
ETS allowances and their progress regarding SAF 
supply. 
Even if the companies remain exposed to high risks, a 
clear upside can be found in the fact that the bulk of 
airlines emissions is linked to scope 1 (i.e. their own 
operations). Both companies can be direct actors of 
their transition and proactively sustain ESG-related 
competitive advantages. 
For instance, Wizz Air has invested in the youngest 
European fleet and believes that 98% of its emissions 
reductions will be derived from fuel-efficient 
planes. These planes, which are 15% more fuel-
efficient, should represent 100% of its fleet in 2028.  
Furthermore, none of the company’s routes under 
a four-hour travel time can be replaced by a train 
and 65% of its passengers travel to visit friends 
and relatives, a category less prone to drastic flight 
reduction. 
For Ryanair, SAFs have become a differentiator as 
the company continues to invest in its Sustainable 
Aviation Research Centre. The company targets 
powering 12.5% of its flights with SAF by 2030 and has 
secured memorandums of understanding with several 
companies (Neste, Shell and OMV) to deliver on its 
target.
7 EBIT refers to earnings before interest and taxe
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MITIGATING CLIMATE-RELATED RISKS 
Companies assessed with having the highest 
climate-related risks are prioritised for individual 
and/or collective engagement. Our dialogue with 
companies allows us to (1) better understand how 
climate-related risks are managed, and (2) assess 
the various mitigation actions that companies have 
implemented or plan to implement. Our analysts may 
also request that companies implement further risk 
mitigation actions and track companies’ progress on 
these recommendations. If we deem that climate-
related risks are continually not being appropriately 
managed, we would consider that the company no 
longer meets our quality growth standards and 
would divest the holding. 
Additionally, our Group-wide exclusion criteria on 
thermal coal mining and coal-fired power generation 
allows us to manage portfolios with significantly 
lower climate risks than comparative indices. 
Furthermore, in 2023, we formalised our stance on 
the Oil & Gas sector (O&G). 
Exploration or development of new oil and gas fields, 
as well as the use of unconventional practices, have 
severe environmental impacts and face significant 
climate-related risks, notably transition risks (i.e., 
stranded assets risks). 
Although energy and utilities companies are usually 
absent from or significantly underweighted in our 
portfolios, we screen our portfolios on a quarterly 
basis, using MSCI data and Urgewald’s Global Oil & 
Gas Exit List (GOGEL), to identify all companies that 
are exposed to the following activities: 
	– Unconventional O&G extraction;
	– Upstream development and expansion; 
	– Midstream development; and 
	– Downstream development of gas-fired power. 
This screening process forms part of the overall 
ESG analysis of companies and contributes to our 
analysts’ assessment of ESG risks. Understanding 
companies’ exposure to O&G development is also 
taken into account to define engagement objectives. 
BIODIVERSITY
The loss of biodiversity undermines the ability of 
nature to provide ecosystem services on which society 
and businesses rely.  Biodiversity loss is a systemic 
risk: investors are exposed to physical risks when 
they invest in economic activities that depend on 
ecosystem services and to transition and reputational 
risks if companies that they invest in have a 
disproportionately negative impact on biodiversity. It 
is therefore necessary for investors to understand the 
extent to which the risks resulting from biodiversity 
loss will lead to financial risks, over what timescale, 
and how these risks contribute to the total risk profile 
of the investee companies and portfolios we manage.
We assess both the impact and dependency of our 
investee companies on biodiversity. The dependency 
and impact of companies on biodiversity can be direct 
(direct physical impact compromising production 
processes) or indirect (via the value chain). Comgest 
may invest in companies that have higher exposure 
to biodiversity related risks, such as deforestation or 
intensive agricultural production. In such cases, we 
specifically include biodiversity and its protection 
in our assessment of ESG risks to the company’s 
operations. 
Our analysis includes: the extent of the company’s 
impact on biodiversity; the measures being taken by 
the company to mitigate this impact (preservation, 
restoration, education of suppliers, procurement 
guidelines, etc.); and the targets and timeline that the 
company has set to reduce adverse impacts.
In 2023, we developed an internal assessment 
methodology to measure the impact and dependency 
of our investee companies on nature and developed 
a classification system (very high, high, medium, 
low and very low) using data from ENCORE8 for 
dependency and data from SBTN9 for impact 
assessment. These additional metrics assist our 
company and ESG analysts to better assess our 
investee companies’ impact and dependency on 
biodiversity. Companies identified as having material 
exposure to biodiversity risks may be identified for 
individual engagement or coordinated actions such as 
collaborative engagements and advocacy initiatives. 
We continue to evolve our assessment methodology 
in this area, as described in the further developments 
section.
8 Exploring Natural Capital Opportunities, Risks and Exposure
9 Science Based Targets Network
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THEMATIC FOCUS: DEFORESTATION
Establishing a Deforestation Policy
Deforestation and natural ecosystem conversion 
have been proven to be important drivers of global 
warming, biodiversity loss and severe human 
rights violations of indigenous peoples and local 
communities. With Comgest’s long-term investment 
horizon, it is clear that these environmental and 
human rights issues may have material impacts 
on the companies in which we invest. Halting 
deforestation plays a key role in reducing such 
impacts and risks for businesses, people and nature. 
In order to take an active approach in addressing this 
important topic, Comgest became a signatory to the 
Financial Sector Commitment Letter on Eliminating 
Commodity-Driven Deforestation. As a signatory to 
this initiative, Comgest has made commitments to 
assess exposure linked to deforestation and report on 
its progress.
In line with our commitment, Comgest established a 
Deforestation Policy in 2023 which sets out how we 
assess risks linked to deforestation and how we intend 
to mitigate the risks identified.
Assessing portfolio companies’ exposure to 
deforestation-related risk
Comgest is committed to carefully monitoring and 
managing deforestation-related risks within our 
investment processes.
Comgest uses data from multiple external providers 
(MSCI, Forest 500 and the CDP Forest Questionnaire) 
to assess our portfolio companies’ exposure to 
deforestation related risks. Comgest screens our 
investee companies to identify the ones that are most 
exposed to deforestation-related risks and assess how 
they are addressing and managing these risks. 
As part of our assessment of high-risk companies, 
we have identified 22 investee companies that 
are exposed to high deforestation-related risks, 
representing 10.6% of our AUM. 
Mitigating deforestation-related risks through active 
ownership
Following our assessment, Comgest launched in 2023 
a three-year engagement programme to engage with 
the high-risk companies.  
These companies are prioritised for individual and/
or collective engagement. Our dialogue with the 
companies will allow us to (1) better understand 
how deforestation-related risks are managed, and (2) 
assess the various mitigation actions the companies 
have implemented or plan to implement.
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ENGAGING ON HAZARDOUS CHEMICALS 
The widespread production and use of hazardous 
chemical, particularly per- and polyfluoroalkyl 
substances (PFAS), have been a pressing concern in 
recent years. PFAS is a family of around 4,700 man-
made chemicals, termed as “forever chemicals” due 
to their persistent nature, many of which are haz-
ardous to humans and the environment.
As a long-term quality growth investor, we believe 
that engaging with our investee companies enables 
us to understand their ESG risks and opportunities, 
which strengthens our research and investment 
thesis. These discussions can sometimes lead to 
improvements of the companies’ practices and 
earnings sustainability. 
Hazardous chemicals represent a notable ESG risk 
for some of our investee companies in the chemical 
sector. Companies in the chemical sector may be 
exposed to reputational risk as well as liability and 
insurance risks associated with controversies. In 
addition, countries around the world are adopting 
stricter regulations on hazardous chemicals, 
therefore companies heavily reliant on hazardous 
chemicals are facing transition risks. This also 
presents an opportunity for companies which 
properly manage these transitions risks by adopting 
good disclosure practices and setting clear targets.
To maximise the impact of the engagements that 
we carry out, we combine several approaches: 
individual engagement is ideal to discuss with 
companies the pressing and material topics 
impacting the business at hand and to maintain an 
ongoing dialogue; while collaborative engagement is 
useful to collaborate with like-minded investors in 
order to better understand our investee companies’ 
exposure to certain risks and encourage best 
practice. 
Individual engagement with Daikin
In June 2022, following a TV broadcast in France 
alleging that a chemical plant owned by Daikin had 
discharged PFAS in a river and contaminated the 
environment, which raised the question of health 
risks to local residents, our analyst reached out to 
the company to initiate a discussion. The company 
was not able to provide us with full information 
as an investigation by French environmental 
authorities was pending and prevented them from 
disclosing information until it was completed. We 
resumed our engagement in February 2023 to follow 
up on this controversy, however, the company still 
could not provide us with any major update.
While the controversy has not been fully resolved, 
to follow up on its overall efforts to reduce PFAS 
emissions and mitigate the relevant risks, we had 
two other meetings with the company in June 
and July 2023. We discussed the general risks 
facing Daikin in relation to potential changes in 
regulation regarding the use of certain chemical 
components as refrigerants in air-conditioning 
equipment. The company explained the various 
obstacles and challenges involved to entirely phase 
out PFAS and its efforts to work on solutions that 
would best reconcile the trade-offs between the 
various business and environmental parameters 
(global warming potential, PFAS capture, safety, 
cost, etc.). As a result of the engagement, we revised 
our estimate of the level of severity of the risks 
involved, now considering them to bear somewhat 
more uncertainty than previously perceived. We also 
downgraded the company’s ESG Quality Level in our 
proprietary ESG rating system, while continuing to 
assess and monitor the relevant risks.
CASE STUDY
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ENGAGING ON HAZARDOUS CHEMICALS (cont’d)
Collaborative engagements with LG Chem and 
Shin-Etsu
Recognising the industry-wide risk, we joined 
a collaborative engagement through Investor 
Initiative on Hazardous Chemicals (IIHC), in order 
to assess the hazardous chemical risks of chemical 
companies we invest in and to encourage them 
to improve their transparency and sustainability 
practices. For two consecutive years (2022-
23), Comgest co-led the engagements with two 
companies – LG Chem and Shin-Etsu. Since the 
engagements did not make significant progress in 
the first year, we continued our efforts to engage 
with these companies in 2023. 
During our engagement in 2022, LG Chem only 
provided us with a written response. In 2023, we 
reached out to the company again and succeeded 
in arranging a meeting where we discussed the 
details of its exposure to hazardous substances 
and chemical management strategy, as well as 
the challenges of entirely phasing out hazardous 
chemicals. 
In our engagement with Shin-Etsu in 2023, in 
addition to continuing the discussion on hazardous 
chemical substances and chemicals management 
from the 2022 engagement meeting, we particularly 
focused on emphasising the importance of 
disclosure and encouraging the company to 
engage with ChemSec, as it helps investors and 
stakeholders better assess risks and reduce 
possible misunderstandings caused by information 
asymmetry. As a result of the engagement, we 
received positive feedback from ChemSec on our 
engagement, as Shin-Etsu reached out to ChemSec 
for the first time to request a discussion. In 
November, ChemSec published the 2023 Chemscore, 
and Shin-Etsu was ranked 17th, a significant 
improvement from the previous year’s 44th position. 
In our follow-up emails, Shin-Etsu informed us that 
as a result of our engagement, they intended to 
improve the disclosure in their 2024 Sustainability 
Report. 
In 2024, we will continue to engage with both 
companies and follow up on their progress.
CASE STUDY
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ENGAGING WITH POLICYMAKERS
The European asset management industry has been 
through a lot of changes since the introduction 
of the Sustainable Finance Disclosure Regulation 
(“SFDR”). We understand there was a great need 
to align certain definitions and enhance the 
transparency around some practices to avoid the 
risk of proliferating unsubstantiated claims. In the 
past, this industry has been criticised, and at times 
fined, for mis-selling or misleading marketing. In 
hindsight, regulating multi-faceted, complex, and 
diverse claims around ESG issues was bound to 
require a lot of work and time, and the European 
Union may not have given itself enough time 
between the preparation and implementation of 
SFDR. It is fair to say that, in 2022, most market 
participants and observers were feeling SFDR fatigue 
and frustration. 
Based on this, we engaged with representatives 
from the PRI in the fall of 2022 to organise feedback 
channels so that we could share what in our view 
was honest and constructive feedback. We also 
took part in various working groups and meetings 
with other asset managers and representatives of 
the Autorité des Marchés Financiers (AMF – the 
French Market Authority) to identify what should 
be clarified, strengthened or removed based on our 
experience of what was useful and practical. We 
actively participated in two separate workshops set 
up by the PRI with representatives of policymakers 
from various jurisdictions. We made our views 
public in the media and at client events. We also 
went to Brussels to meet representatives of the 
European Commission with a small group of asset 
managers and asset owners. We further responded 
to the European Commission’s consultation on 
the implementation of the SFDR regulation in 
December 2023 with the hope that our responses 
and recommendations can help improve the SFDR 
framework. 
We have been very active in voicing our concerns 
because we believe that regulation can sometimes 
have unintended consequences which can negatively 
impact the responsible and sustainable investment 
market in Europe. 
CASE STUDY
GLOBAL GEOPOLITICAL AND POLITICAL RISKS
Among the market-wide and systemic risks that we 
consider to be most significant, the continuous rise 
of global geopolitical and political risks in various 
countries feature highly. The progressive inversion 
of globalisation has become a long-enough trend 
to have gathered a slow but powerful momentum. 
Ongoing tension between China and the U.S., as well 
as political instability in many countries is creating a 
multi-polar world, wherein singular events can trigger 
unpredictable but very costly chain reactions.
In 2023, the situation in the Middle East took a turn 
for the worse and, beyond the human tragedy, we 
have seen many supply chains being disrupted, which 
served as a reminder of the fragility of some of them. 
Over the summer of 2023, the BRICS summit turned 
into a BRICS+ summit with six new joiners coming 
to this club to forge an alternative world order 
reinforcing multi-polarity and dislocation risks to the 
global system because of its balkanisation. 
In 2024, amid the backdrop of a widespread 
democratic recession close to 40% of the global 
population, representing 60% of the global GDP and 
80% of the global market capitalisation, will hold 
important elections. 
With very large fiscal and current account deficits, 
potential political changes in certain influential 
nations could introduce market-wide and systemic 
risks if those changes were to jeopardise democratic 
institutions, trust in the currency or long-term 
solvency and the rule of law in these countries. 
While inherently hard to predict and model, these 
risks can be discussed and analysed using scenarios 
to illustrate the potential damage or resilience of 
companies and sectors around specific timelines, 
such as elections dates or other political events.
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PROVIDING FEEDBACK ON ESG LABEL REQUIREMENTS
ESG and SRI labels provide external assurances to 
investors who seek industry-recognised accreditation 
of ESG approaches and require targeted exclusion 
criteria. Our Comgest Plus fund range adopts our 
long-term quality growth investment philosophy 
while specifically adhering to requirements of leading 
ESG labels such as the Towards Sustainability Label, 
supervised by the Belgium Central Labelling Agency 
(CLA).
From November 2022 to June 2023, the CLA organised 
the revision process of the Towards Sustainability 
Label. Throughout this process, label holders were 
invited to provide feedback on the new labelling 
criteria. 
Comgest provided feedback during both rounds. Our 
interactions with CLA representatives were key to 
sharing our views on the operational feasibility of 
suggested changes and to highlight any difficulties we 
had foreseen, while embracing the overall objective 
of the revision, which was to further strengthen the 
label’s requirements in a rapidly evolving sustainable 
finance space. Overall, we deeply appreciated having 
been able to provide our input and noted that most 
of the questions and comments we raised were taken 
into consideration.
CASE STUDY
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ADHERENCE TO INTERNATIONAL STANDARDS AND SUPPORT FOR INITIATIVES
In addition to acting on the findings of our own research, we support a number of industry-wide initiatives that 
help us to deepen our understanding of market-wide and systemic risks and add our weight to efforts to respond 
to them. They also provide us with an external lens through which we can analyse our effectiveness in responding 
to such risks, as discussed below.
Participation in responsible investment working groups, committees and initiatives 
To assist both Comgest and our investee companies in producing transparent and informative reporting, we have 
adhered to or support the following initiatives:
INITIATIVE 
DETAILS
Association Française  
de Gestion (AFG)  
Comgest is a member of: 
	
−AFG’s* Responsible Investment Plenary to contribute to the development of 
responsible investing within the French asset management industry, and 
	
−AFG’s Corporate Governance Committee to contribute to the development of the 
Corporate Governance Code for the French asset management industry. 
Topics include responsible investment regulations, ESG standards, sharing of best 
practices, governance codes, collaboration on response to French and European 
regulators’ consultation papers, advocacy as an industry association.
*AFG is the French asset management industry association.
Institut Français des 
Administrateurs (IFA)  
Comgest is a member of the IFA’s Prospective & Research working group which aims 
to identify and analyse emerging governance topics.
The Irish Funds Industry 
Association (Irish Funds)
Comgest is a member of the representative body for the international investment 
fund community in Ireland. Comgest contributes to working groups and discussions 
including on responsible investing.
Investment Company 
Institute (ICI)
The Investment Company Institute (ICI) is the leading association representing 
regulated investment funds. It aims to help strengthen policy and regulatory 
frameworks and to encourage sound governance, operational and fiduciary 
practices.
Supporting sustainability and responsible investment initiatives
INITIATIVE 
DETAILS
Principles for Responsible 
Investment (PRI) 
Comgest has been a signatory since March 2010. In 2023, we received a 5-star rating in 
“Direct - Listed equity - Active fundamental (93%)” and “Confidence building measures 
(100%)”, and a 4-star rating in “Policy Governance and Strategy (87%)”, above median in 
each of these assessment modules. 
Comgest’s latest PRI Transparency Report and Assessment Report can be found on our 
 website. 
Standards and initiatives related to climate 
The Comgest Group has chosen to adhere to or support, as appropriate, the following climate related standards 
and/or initiatives.
INITIATIVE 
DETAILS
Net Zero Asset Manager 
Initiative (NZAMi)
Comgest became a signatory to this initiative driven by an international group of asset 
managers committed to supporting the goal of net-zero greenhouse gas emissions by 
2050 or sooner.
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INITIATIVE 
DETAILS
Task Force on Climate-related 
Financial Disclosures (TCFD) 
Comgest has supported the TCFD since 2017 and encourages all portfolio companies 
to align disclosures to the TCFD recommendations. 
Climate Action 100+ 
Comgest has been a signatory to Climate Action 100+ since 2017, an investor-led 
initiative to ensure the world’s largest corporate greenhouse gas emitters take 
necessary action on climate change. 
CDP
Comgest has supported the Carbon Disclosure Project (CDP) since 2012 and 
participated in the following:
	
−CDP Non-Disclosure Campaign (since 2018)
	
−CDP SBTi campaign (since inception in 2021)
	
−CDP Transition Plan Campaign (2023)
	
−CDP Green Finance Accelerator (2023)
Say on Climate Forum  
pour l’Investissement 
Responsible (FIR)
French Sustainable  
Investment Forum
Comgest became a signatory to the FIR’s “Say on Climate” investor campaign which 
asks companies to present ambitious climate plans and targets, allowing investors to 
then vote.
Institutional Investors Group 
on Climate Change (IIGCC)
In 2023, Comgest became a member of this European group for investor 
collaboration on climate change.
Avoided Emissions Initiative
Comgest is one of the founding partners of this initiative aiming to standardise 
the calculation of avoided emissions. The 10 partners supporting the initiative 
are working with specialised consultants to develop a global database of 
greenhouse gas emission avoidance factors for low-carbon or green enabling 
solutions.
Standards and initiatives related to other environmental factors 
INITIATIVE 
DETAILS
Deforestation Free Finance   
Comgest joined this initiative in 2021 and is one of the signatories to the Financial 
Sector Commitment Letter on Eliminating Commodity-driven Deforestation. The 
signatories recognise the vital role of financial institutions in tackling deforestation 
and commit to adopt the roadmap proposed by the Deforestation-free Finance Project 
by 2025, aligned with a Paris Agreement-compliant 1.5°C pathway. 
FAIRR Initiative  
Comgest has supported the FAIRR Initiative since 2020 which is a collaborative 
investor network that raises awareness on ESG risks and opportunities brought by 
intensive livestock production.
In 2023, Comgest signed a FAIRR-led investor statement calling on the G20 Finance 
Ministers to repurpose their agricultural subsidies in line with climate and nature 
objectives. This statement follows the Global Biodiversity Framework agreed in 
Montreal.
Investor Initiative on Hazardous 
Chemicals (IIHC)
Comgest is an active member of this initiative, which aims to reduce the impacts on 
human health and the environment from the manufacture of hazardous chemicals, 
thereby reducing financial risks to investors in these companies from litigation, 
regulation and threats to their license to operate.
In 2023, Comgest co-led the engagements with two companies, and signed two letters 
together with members of IIHC:
	
−In Q1 2023, Comgest signed a letter to European Commissioners which urged the 
European Commission to protect the EU Taxonomy’s ambitious, proposed chemical 
criteria in order to encourage sustainable innovation and development of safer 
chemicals.
	
−In Q4 2023, Comgest signed a new letter targeting the world’s 50 biggest chemical 
companies following the release of ChemScore’s 2023 rankings. The letter called for 
a time-bound phaseout plan, increased transparency on production, and greater 
investment in safer alternatives.
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INITIATIVE 
DETAILS
Nature Action 100
Comgest joined this engagement initiative in 2023, which is focused on driving greater 
corporate ambition and action to reduce nature and biodiversity loss. Investors 
participating in the initiative engage companies in key sectors that are deemed to be 
systemically important in reversing nature and biodiversity loss by 2030.
Investor Policy Dialogue on 
Deforestation (IPDD)
Comgest has been a member of the IPDD Brazil since 2020, a collaborative investor 
initiative to engage with public agencies and industry associations in selected 
countries on the issue of deforestation.
Throughout 2023, many engagement activities took place with members of 
the Brazilian government, central banks, legislative representatives, and other 
stakeholders. The IPDD also organised several educational sessions on a variety of 
topics including a presentation on the risks for deforestation increase posed by Brazil’s 
temporal milestone bill, a presentation on Brazil’s environmental licensing bill and an 
overview of relevant EU regulations that could have impact on deforestation. 
Partnership for Biodiversity 
Accounting Financials (PBAF)
Comgest is a member of this industry-led partnership that enables financial 
institutions to assess and disclose impacts and dependencies on biodiversity of their 
investments. Joining this partnership will help Comgest be better equipped to assess 
and measure nature-related risks.
Standards and initiatives related to social, human rights and anti-bribery/corruption
INITIATIVE 
DETAILS
Access to Medicine Foundation 
Comgest has supported the Access to Medicine Foundation since 2019, an 
independent non-profit organisation which analyses how the world’s largest 
pharmaceutical companies are addressing access to medicine.
PRI Advance Platform
Comgest has endorsed the newly created PRI Advance platform focused on human 
rights and social issues since July 2022.
Investor Alliance for  
Human Rights
Comgest signed the Investor Alliance for Human Rights’ statement. The initiative is a 
collective action platform for responsible investment that is grounded in respect for 
people’s fundamental rights.
30% Club
France Investor Group 
Comgest has been a member of the 30% Club France since 2022. This collaborative 
engagement initiative is comprised of asset managers and asset owners and expects 
executive management teams of SBF 120* companies to appoint women to at 
least 30% of seats by 2025. The initiative also expects companies to be transparent 
regarding the procedures used to find and appoint new members to the executive 
management team and how that process ensures a diverse leadership committee.
*“SBF 120” refers to companies listed in the French stock market index, “Société des 
Bourses Françaises 120”.
 
  FURTHER DEVELOPMENTS IN 2024
As mentioned above, Comgest is a signatory to the 
Net Zero Asset Managers initiative and as such we 
track our annual progress. During 2023, we focused on 
identifying our engagement targets and commencing 
engagements. In 2024, we will look to enhance our 
reporting on our engagement threshold target and to 
further improve our engagement programme focusing 
on the material climate risks and opportunities we 
have identified as well as companies’ transition plans. 
In addition, Comgest continues to work on identifying 
further tools to better assess investee companies’ 
impact and dependency on biodiversity. In 2024, 
Comgest intends to implement a comprehensive 
Policy on Nature covering both biodiversity and 
deforestation. We will also continue to enhance our 
engagement activities and reporting on these topics.
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Signatories review their policies, assure their processes and assess the effectiveness 
of their activities
INTERNAL REVIEWS
Our Responsible Investment, Active Ownership and Exclusion Policies are approved by the CGI Executive 
Committee and the Board of Directors of the relevant Group entities. Prior to approval, these policies are reviewed 
by the ESG team, Compliance and the Sustainability Committee. The policies are reviewed annually and updated 
when changes are introduced. We adopt best practices where we can and follow the recommendations of the PRI, 
which gives us confidence in our approach.
APPROVAL OF THE ANNUAL UK STEWARDSHIP CODE REPORT
The Sustainability Committee and the Board of Partners review and approve our annual UK Stewardship Code 
Report before submission to the FRC. Prior to approval by the Sustainability Committee and the Board of Partners, 
the report is prepared by the ESG team and approved by the Compliance department.
INTERNAL AND EXTERNAL ASSURANCE
Comgest has implemented an industry-standard 
internal control framework for managing and 
monitoring organisational performance, using 
three levels of controls to manage risk and assign 
responsibility of key controls to the appropriate 
officeholders. 
The Investment team is the first line of defence 
in terms of respecting risk limits. All members of 
the Investment team have responsibility for ESG 
analysis, compliance with ESG related constraints/
limits on portfolios, engagement with investee 
companies and voting.
As part of the second line of defence, an oversight 
function is provided by the Compliance and Internal 
Control department, the Risk department and the 
Risk Committee.
The Compliance and Internal Control teams are 
responsible for ensuring that we conduct business 
in compliance with applicable laws, industry best 
practice and internal policies and procedures. 
Responsible investment processes and compliance 
with regulatory obligations/voluntary initiatives are 
included as part of the Compliance/Internal Control 
plans. Constraints linked to Comgest’s Responsible 
Investment Policy (e.g., exclusions) and contractual/
regulatory commitments are monitored by the Risk 
Department.
Risk oversight of our portfolios is organised around 
daily pre- and post-trade controls as well as monthly 
and quarterly controls.
Daily pre-trade controls are designed to prevent 
the occurrence of breaches and are performed 
using our internal portfolio management system. 
Post-trade controls are performed daily to identify 
any breaches after settlement of orders. The Risk 
department also performs a monthly review of the 
constraints applicable to our Article 8 products (as 
defined under the Sustainable Finance Disclosure 
Regulation). 
The local Risk Committee conducts an annual 
risk mapping process and looks at risk mitigation 
(insurance, controls, processes) as a tool for reducing 
the risk including both the occurrence and the 
potential financial loss. This includes operational 
risk linked to the implementation of responsible 
investment processes, reporting on responsible 
investment and climate and ESG transition risks. 
The Risk teams further cover ESG as a standard 
reporting item in their quarterly reporting to the 
Risk Committees.
The third line of defence is an independent function 
performing periodic and exception-based controls. 
As part of the third line of defence, responsible 
investment processes and compliance with ESG 
related regulatory obligations are included within 
PRINCIPLE 5
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the relevant entities internal audit programs. 
Certain processes are also reviewed annually as part 
of the ISAE 3402. 
In 2023, the Internal Control team performed a 
review of our proxy voting and all ESG-related 
processes including ESG integration in the 
investment process, exclusion lists, engagement, 
ESG assessment and ESG reporting. An audit 
covering ESG integration in the investment process 
and compliance with regulatory obligations was 
also conducted. Our third-party external assurance 
provider also reviewed our investment and proxy 
voting processes as part of its annual ISAE 3402 
review.
FAIR, BALANCED AND UNDERSTANDABLE STEWARDSHIP REPORTING
We produce a number of reports and materials 
containing ESG-related information, including 
quarterly and annual Responsible Investment 
Reports, Voting and Engagement Reports, ESG 
RFPs/questionnaires and general product 
information. To ensure that these are fair, balanced 
and understandable, they are submitted to our 
Compliance department, which is independent of the 
team preparing the communications. The Compliance 
team reviews, challenges and approves relevant 
materials being distributed externally. Our client 
base comprises a significant number of institutional 
investors and global consultants who also serve as 
an important source of information with respect to 
benchmarking the quality of information we provide 
and learning about evolving best practices. We seek 
regular feedback from clients and industry networks, 
and this information feeds into the continual 
improvement of our materials.
IMPROVEMENT OF STEWARDSHIP POLICIES AND PROCESSES
We constantly seek to improve and evolve our policies and processes in light of industry developments, regulatory 
changes and best practices. In 2023, several changes were implemented:
	– We made changes to our Active Ownership Policy 
(previously Voting & Engagement Policy) with key 
updates including further definition of engagement 
types (information exchange and objective-driven 
engagements) and details on how engagements are 
prioritised and monitored.
	– We further updated our Responsible Investment 
Policy with key updates including the inclusion of a 
Human Rights Policy, a Deforestation Policy and a 
Climate Policy.
	– We enhanced our Exclusion Policy.
	– We updated our Plus Funds Exclusion Policy with 
key updates including further monitoring of board 
gender diversity and GHG intensity metrics.
	– To ensure our Sustainability Committee members 
are kept informed of any ESG-related issues that 
may arise, we established monthly and quarterly 
reports to cover several topics including regulatory 
updates, material controversies and reputational 
risks, material ESG client activity, material 
engagements and entity level ESG-related risks.
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Signatories take account of client and beneficiary needs and communicate the 
activities and outcomes of their stewardship and investment to them 
Comgest works in the spirit of partnership and transparency with our clients, and the majority of our assets 
under management are managed on behalf of long-term oriented, institutional investors who, like us, are 
prepared to be disciplined and patient.  
The development of a trusted partnership with our clients is a key element in implementing our philosophy, and 
with this comes a duty to provide high-quality performance, servicing and reporting.
Figure 5 shows our asset breakdown by type of client and geography (please note that we only manage equity 
portfolios so there is no breakdown by asset class). 
Figure 5. Comgest Asset Breakdown
Source: Comgest, data as of 31-Dec-2023; rounded figures may not add up to 100%.
Banks /  
Financial institutions 
Sovereign wealth funds /  
Pension funds /  
Other international bodies
Asset management  
companies
Insurance companies
Foundations /  
Family offices
Platforms /  
Custodian banks
Europe
Global
Japan
Global Emerging Markets
Asia
US
China
Rest of the World
France
Germany / Austria
Benelux
UK
USA / Canada
Switzerland
Sourthern Europe
Japan
Rest of the World 
Middle East
Asia Pacific ex Japan
USA 
Japan
France
Netherlands
Switzerland
Other Europe
Ireland 
China
Denmark
Rest of the World 
Germany
Italy
India
Taiwan
South Korea
Clients by Type 
AuM by Strategy
Clients by Geography
AuM by Geography
27% 
 
26% 
18% 
18%
7% 
5%
49%
21%
14%
7%
5%
3%
0.4%
0.3%
36%
17%
10%
9%
7%
6%
5%
4%
2%
2%
2%
18%
15%
12%
8%
8%
7%
6%
5%
5%
4%
3%
3%
2%
2%
2%
PRINCIPLE 6
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RESOURCING OF CLIENT SERVICE TEAMS
Comgest has invested in building highly experienced 
and well-resourced Investor Relations, Marketing 
Communications and Investor Services teams, now 
comprising over 40 professionals based in proximity 
to our clients across our international offices. 
Investor Relations team
We offer a dedicated and tailored approach to client 
service. Our 22-strong, multilingual Investor Relations 
team, based in nine different locations, is responsible 
for developing durable client relationships that enable 
us to understand and anticipate client needs. Our 
Investor Relations professionals are first and foremost 
dedicated to relationship management.
Clients are serviced across the Investor Relations 
team according to geography and/or language skills. 
The team maintains up-to-date knowledge of industry 
developments as well as client trends and sensitivities 
as they evolve in each market. The team members 
hold regular meetings with clients to discuss their 
servicing requirements.
Investor Services and Marketing Communications 
teams
The Investor Services and Marketing Communications 
teams are based in Paris, London, Düsseldorf, 
Amsterdam, Tokyo, and Milan, and produce all forms 
of client reporting, presentations as well as manage 
external communications, in multiple languages. The 
teams also respond to specific client information 
requests, working closely with the Investor Relations 
team.
UNDERSTANDING AND RESPONDING TO CLIENT NEEDS
The Investor Relations team seeks to ensure that 
interactions with clients address two key questions:
	–
Does the client or prospect have a clear 
understanding of our investment philosophy and 
beliefs and how are these are expressed in the 
portfolios?
	–
How can we improve the service we provide to the 
client?
The Investor Relations, Marketing Communications 
and Investor Services teams work closely with 
clients to ensure they receive the desired frequency 
of reporting, updates (performance/market/
firm) and face-to-face meetings. All interactions 
contribute to our understanding of client needs. 
At formal portfolio review meetings, the Investor 
Relations team proactively asks questions about 
client satisfaction levels with respect to information 
and servicing. These review meetings are regularly 
attended by senior members of Comgest’s 
Investment and ESG teams, so that our clients also 
maintain direct contact with the key stakeholders 
involved in the management of their portfolio. We 
receive valuable feedback through listening to a 
variety of contact points from our investors, such 
as reporting and back-office teams, operational 
due diligence teams, independent board members 
and investment committee members, as well as 
investment personnel. 
We believe that this personalised approach is 
appropriate for our business model and client 
relationships. 
Our client base requires an increasingly bespoke 
level of investment portfolio tailoring and service, 
which may involve segregated mandate solutions 
(28% of our AUM) and tailored reporting. We seek 
to ensure that we have sufficient resources and 
expertise in our client-facing teams to implement 
our chosen approach successfully.
We assess the effectiveness of the measures we 
have put in place to understand and respond to 
client needs through a number of key indicators for 
client satisfaction: 
	–
Client retention 
	–
On-time reporting statistics
	– Accuracy of reporting statistics
	–
Client event feedback survey results
	–
Number of client complaints
	–
Client feedback from direct interactions with 
clients across regions
	– Independent branding surveys that benchmark our 
reputation on servicing quality
The Investor Relations team meets monthly to 
discuss and analyse client developments. Our Investor 
Services, Marketing Communications and Investor 
Relations teams receive training and participate 
in offsites to improve their skills and knowledge, 
providing an opportunity to share best practices and 
exchange ideas.
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ALIGNMENT WITH CLIENTS’ STEWARDSHIP AND INVESTMENT POLICIES
We strive to work together with our clients as 
responsible stewards of their capital. This means 
sharing views, knowledge and developing an 
understanding of our clients’ specific priorities when it 
comes to responsible investment.
Tailoring to bespoke ESG needs
The development of a trusted partnership with 
our clients is a key element in implementing our 
philosophy. We consider it a privilege to manage assets 
on behalf of our clients and with this comes a duty to 
understand their priorities, their needs and to provide 
high-quality performance, servicing and reporting. 
	–
Our clients increasingly require bespoke 
investment strategies to meet their own 
stewardship goals. Comgest has been pleased to 
help clients develop and implement their own 
exclusion and voting policies, such as faith-based 
exclusions and increasingly, belief and climate-
based exclusions, e.g., fossil fuel exposure. To 
implement these strategies, we have invested in 
our internal processes to ensure that the portfolios 
are effectively monitored and delivered. We meet 
frequently with these clients to discuss outcomes 
and ensure that they are in line with expectations. 
	– We continue to evolve our responsible investment 
and active ownership policies based on feedback 
from client interactions which enable us to identify 
key trends on ESG related matters. For example, 
in 2023, following evolving industry practise and 
feedback from several clients, we enhanced our 
reporting on individual engagements to distinguish 
between those that are for the purpose of an 
information exchange and those that are objective-
driven initiatives. We have likewise added sub-
topics within our broader environmental, social or 
governance (“ESG”) categories.
	– Within our segregated client mandate accounts, 
some of our clients have stipulated that we 
implement certain bespoke engagement priorities, 
in which we act on their behalf. For example, 
in 2023, we implemented bespoke engagement 
priorities on board gender diversity and climate 
change for two of our segregated client mandates 
to align with their engagement priorities.
Working together to drive change
As part of our active ownership strategy, we are 
pleased to partner with our clients in order to drive 
positive change for example through combined 
engagement activity. 
For instance, in 2023, one of our clients signed up 
to support the Corporate Mental Health Benchmark 
established by the CCLA, the UK’s largest investment 
manager for charities and local authorities. As part of 
this initiative, the CCLA sent an email to our investee 
company Tencent (along with 100 other companies 
worldwide) requesting feedback on this benchmark. 
Tencent did not respond to the email, so our analysts 
contacted the Head of ESG at Tencent to provide more 
context and feedback on the benchmark. Tencent 
acknowledged that the physical and mental health 
of Tencent’s employees is critical to the company’s 
business and confirmed that the company was more 
than willing to provide feedback to the CCLA.
Following our engagement, we were pleased to see 
that Tencent’s ESG team had successfully provided 
feedback to the CCLA.
Knowledge sharing
Comgest is always pleased to exchange with our 
clients on evolving ESG topics. We participate in a 
number of knowledge-sharing activities with them, 
including dedicated training sessions and events.
For instance, in 2023, we held a knowledge-sharing 
session with a client focused on Principal Adverse 
Impact (PAI) reporting and how PAI indicators were 
incorporated in our investment decision-making 
process. We also provided our insight to several clients 
on our Net Zero Asset Management (NZAM) Initiative 
target-setting journey, as well as our overall approach 
to integrating climate change in our investment 
process and engagement efforts.
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COMMUNICATING STEWARDSHIP AND INVESTMENT ACTIVITIES AND OUTCOMES
Comgest considers the timeliness and quality of client reporting a core component of our asset management 
service. We follow a principle of maximum transparency, which we believe is essential to building trust and long-
term client partnerships. We provide a full suite of standardised reporting and are able to tailor our reports to 
specific client needs.
The expectations of our clients and other stakeholders for high-quality, relevant and timely Responsible Investment 
reporting have increased over time and their requirements will continue to grow, a trend that we welcome. We pride 
ourselves on our ability to provide bespoke investment and reporting solutions for investors. We continue to invest 
in our reporting tools and team resources in order to add depth to the degree of customisation available to clients. 
We also regularly add to our library of investment publications.
REPORTING:
	–
General reporting: fund factsheets and bespoke 
portfolio reporting with detailed performance 
information including attribution analysis, 
quantitative statistics, portfolio manager 
commentary, and ESG data. 
	§ Comgest’s standardised client reporting was en-
hanced in 2023 to provide further transparency 
on the ESG metrics of our portfolios. For examp-
le, in addition to the carbon and environmental 
footprints (shown in our factsheet since 2019), 
Comgest’s quarterly factsheets for most of our 
“Article 8” public funds now feature a dedicated 
ESG page with data that includes: SBTi portfo-
lio coverage, board gender diversity, voting and 
engagement statistics, and the fund’s alignment 
with sustainability preferences.
	–
Specific ESG reporting: Our global client base has 
a wide and expanding range of reporting standards. 
In recent years, we have seen a significant increase 
in client demand for responsible investment and 
stewardship reporting, and in response we have 
increased the quantity and depth of our ESG 
reporting capabilities. The below documents 
are available on our 
 website, unless specified 
otherwise.
	§ Quarterly Responsible Investment Reports 
(available to invested clients upon request), 
which detail:
	
 Voting activity and statistics, including votes 
against management and votes against 
Comgest’s Voting Policy.
	
 Engagement activities: the nature and extent 
of investee company interactions, including 
how we selected issues for engagement and 
the type of engagement(s) undertaken. Where 
possible within the timeframe, we will also 
report on the effectiveness of this engagement.
	
 Our involvement in industry and collaborative 
initiatives as part of our partnership strategy.
	§ Our Annual Responsible Investment Report is 
is a comprehensive report which is compiled 
at Group level for select strategies. The report 
covers the four core elements of TCFD’s recom-
mended climate-related financial disclosure 
(governance, strategy, risk management and 
metrics and targets). It also provides detailed 
information on our responsible investment 
approach, engagement and voting statistics and 
key ESG metrics at firm and strategy level. 
	§ Comgest’s pre-declared proxy voting intentions 
(where applicable)
	§ Regulatory reports including the Annual PAI Sta-
tements and the SFDR Annual Periodic Disclosu-
res 
	§ UN PRI Assessment Report 
	§
 Proxy Voting Dashboard: Summarises 
Comgest’s voting activity for each investee 
company. This dashboard is updated daily and 
voting results are visible with a 90-day lag. 
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–
Bespoke and ad hoc ESG-related responses to 
client questionnaires
	§ Regular bespoke ESG reporting, particularly for 
our mandate clients, includes a wide range of 
ESG information including analysts’ comments 
on controversies, ESG ratings according to client-
defined scoring methodologies, etc. In 2023, 17 
bespoke ESG reports were provided to a number of 
clients.
	§ Response to RFPs and DDQs: In 2023, Comgest’s RFP 
team responded to 54 dedicated ESG questionnaires 
(vs. 25 in 2022), and 201 questionnaires requesting 
detailed ESG content (vs. 194 in 2022) with many 
including a specific focus on areas such as climate, 
diversity, engagement, voting, and SFDR.  
	§ Ad hoc responses and reports prepared to address 
specific ESG information requests, e.g., regarding a 
specific stock, industry or topic.
	– Thought leadership
	§ The Investment team provides product-specific 
updates in relation to market and portfolio 
events to provide clients with insights into the 
research and analysis undertaken in the ongoing 
management of their portfolios. For example, 
in 2023, our ESG team published a paper titled, 
 ”ESG in focus: how salmon became catch of the 
day”, which examines the nuances associated 
with identifying sustainable business models, 
using salmon farming as an example of the 
complexities surrounding the implementation of 
ESG in investment decisions.
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Signatories systematically integrate stewardship and investment, including 
material environmental, social and governance issues, and climate change, to fulfil 
their responsibilities
As highlighted under Principle 1, we consider responsible investment to be part of our fiduciary duty as asset 
managers. We seek to protect the long-term interests of our clients by investing in companies whose financial 
returns are sustainable well into the future. We must therefore monitor the social and environmental impact of 
our investee companies to evaluate whether they support the conditions for sustainable growth and determine 
whether their governance structures are designed to treat all relevant stakeholders fairly.
OUR APPROACH TO ESG INTEGRATION
Comgest is focused on equity investing and adopts 
the same quality growth philosophy across all regions, 
public funds and mandates. As described under 
Principle 2, our ESG analysts are an integrated part of 
Comgest’s Investment team.
ESG factors are incorporated into the investment 
decision making process with the objective of 
improving the long-term financial outcomes of our 
clients’ portfolios, consistent with their objectives. 
This approach ensures that the Investment team is 
aware of an investee company’s sustainability risks 
and adverse impacts, including those that could have 
a material impact on returns. ESG analysis is entirely 
consistent with our quality growth investment 
philosophy and is fully integrated into our investment 
approach. ESG integration allows our Investment 
team analysts and portfolio managers to increase 
their understanding of the companies they research 
and identify areas where engagement could have 
most impact. 
Specific ESG issues that are most material will 
differ by region and type of activity: for example, 
companies with supply chains in Emerging Markets 
may be more vulnerable to the issue of child or 
forced labour. A company’s local laws and practices 
as well as regulatory standards around ESG issues 
are also important factors in our ESG analysis. 
Similarly, climate change is expected to have varying 
impacts around the world, with an increased risk of 
drought in countries such as South Africa or India, 
and an increased flood risk in countries such as 
China. Governance risk will likely be of heightened 
materiality in our ESG assessment of state-owned 
companies in Emerging Markets compared to Western 
competitors.
Our use of engagement to mitigate identified risks 
as much as possible and encourage best practices is 
further described in Principle 9.
ESG INTEGRATION PROCESS
Comgest’s ESG integration approach aligns well 
with our general approach of stock picking quality 
companies with a long-term investment horizon and 
ensures that sustainability risks and opportunities 
as well as adverse impacts are taken into account in a 
systematic manner.  Our process is described in detail 
in 
 Comgest’s Responsible Investment Policy
PRINCIPLE 7
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* ESG Quality Levels are assigned 
following the ESG analysts in-
depth review which takes place 
when a security enters a portfolio.  
While ESG quality levels cover a 
large majority of Comgest’s assets 
under management, a Quality 
Level may not be assigned for all 
investments, depending on the 
strategy.
1. BROAD SCREEN OF MARKET
Our investment process includes ESG criteria within our initial screening of the market for quality 
companies as described in Figure 1. This broad screen of the market is carried out by the company and ESG 
analysts in relation to financial and extra-financial quality growth criteria. This occurs on a continuous 
basis through evaluation by the Investment team, contact with companies as well as through industry and 
other sources, such as broker research and the occasional use of screening tools.
2. WATCHLIST
Where companies pass our initial screening, they are considered as potential investment ideas and are 
added to a ”watchlist”. The Investment team conducts the following activities for watchlist companies:
	– Fundamental analysis of companies, competition, markets and ESG factors
	– Assessment of growth potential using qualitative analysis and proprietary forecasts
	– Meetings with management, and potentially also competitors, suppliers, customers, and industry experts.
The integration of ESG analysis is an important research element in building conviction levels about the 
true quality and sustainability of the business model of a company. ESG research during this phase may also 
lead to identifying significant ESG-related competitive advantages and growth engines.
	–        
UNIVERSAL MUSIC GROUP
No investment made, with ESG a significant risk to the investment case.
ESG risk was a significant factor in the consideration of the investment case for Universal Music Group (UMG) and 
resulted in our Investment team deciding not to add the company to our Investment Universe (“Universe”).
The music industry is rife with abusive behaviour due to informal networking, freelancing and gender & age 
imbalance. Currently, all three major labels are facing investigations for harassment and discrimination. These 
industry-wide concerns, coupled with ongoing investigations, increased UMG’s reputational risks, and prompted 
us to question whether there were underlying cultural and workplace misconduct issues within the company. As 
a result, our company and ESG analysts had multiple discussions with industry experts and former employees, 
including individuals at senior management levels, to further assess the risks. However, following these 
discussions, we found ourselves unable to obtain a sufficiently high level of comfort with this company in light of 
our concerns. In fact, these discussions raised more questions than answers. We therefore decided not to add the 
company to our Universe for the time being, pending further updates that may change our view.
CASE STUDY
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3. UNIVERSE
Comgest’s Universe for each strategy represents a list of quality growth companies that have been rigorously 
selected and may be included in portfolios. 
When moving from the watchlist to the Universe of eligible investments, a risk assessment is summarised 
into what the company and ESG analysts believe to be the most material sustainability issues including 
those that could have an impact on a company’s performance and share price.  
We analyse how the identified ESG sustainability risks contribute to broad risk headings such as governance 
risk, reputational risk, regulatory and litigation risk, operational risk, demand shift risk, sourcing/supply 
chain risk and corporate culture risk, recognising that the materiality of certain ESG risks can vary from 
industry to industry and region to region.
As our ESG integration process progresses, we analyse matters where there is less certainty about the 
risks or an unavailability of data. In these cases, our direct dialogue with and knowledge of the company, 
experience and judgement is required when coming to an overall opinion.
	–        
FORTNOX 
(Sweden-based company that offers Internet-based business applications for companies, associations, as 
well as accounting and auditing firms)
No investment made, with ESG a significant risk to the investment case. 
Governance was a notable area of concern in this example and did not build the necessary conviction for the 
Investment team to add the company to the portfolio.
There has been a constant turnover of directors and the chair in this company in recent years. The previous 
CEO had left abruptly, and the current CEO had a chequered history with his previous employer, having been 
pursued by his former employer, IST, for misreporting deteriorating results to the Board. The chair and major 
shareholder, Hallrup, was found guilty of insider trading yet was elected chair three years later. In addition, 
we found that the remuneration package was vague, but also complex (warrants, options, issued by different 
entities). In March 2023, our company and ESG analysts held a meeting with the current CEO to further assess 
these risks and firm up our view on the company. The meeting did not fully address our concerns, and as a 
result, we decided not to add the company to our portfolio, while continuing to monitor and evaluate the 
company for any improvements in governance.
CASE STUDY
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4. VALUATION
The Investment team constructs conservative five-year earnings and dividend discount models for all 
Universe stocks, based on proprietary estimates. The discount rate used in valuations takes into account 
country risk, equity risk and ESG risks/opportunities identified throughout the process.
For companies that have been assigned an ESG Quality Level, a company-specific ESG discount rate is 
applied to the overall discount rate used in the company valuation process. Impacts can be either positive or 
negative, depending on whether the Quality Level reflects an overall ESG risk or opportunity. 
As displayed below, ranges of ESG discount rate component are different according to whether it is a 
Developed Market or an Emerging Market investment universe.
Discount rate components:
*For companies with an assigned ESG Quality Level
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Definition of the ESG Quality Level
As a result of our proprietary ESG assessment process, an overall ESG Quality Level may be assigned to each 
company, ranging from 1 (leader) to 4 (improvement expected) using an internal rating system as described below. 
The Quality Level reflects the consensus opinion of the company analyst and the ESG team.
Comgest ESG 
Quality Level
Discount Rate Impact
(DM = Developed Markets 
/ EM = Emerging Markets)
Summary Description 
1   ESG Leader
Lower
-50bps for DM
-100bps for EM
Meets Comgest’s “quality growth” selection criteria 
to qualify for the investment universe and Comgest’s 
governance criteria10 
	
−
Significant ESG-related competitive advantage(s) and/or 
growth engine(s)
	
−
Sustainability embedded in corporate culture
	
−
High quality disclosures regarding material 
sustainability risks 
	
−
Excellent mitigation of inherent ESG risks 
	
−
Excellent response to any other material ESG issues if 
they arise
2  Good ESG Quality
Neutral
No impact 
on the discount rate
Meets Comgest’s “quality growth” selection criteria 
to qualify for the investment universe and Comgest’s 
governance criteria
	
−
Acceptable level of disclosure regarding material 
sustainability risks 
	
−
Good mitigation of inherent ESG risks
	
−
Adequate response to any other material ESG issues if 
they arise 
	
−
May be exposed to significant ESG opportunities, but it 
does not meet the criteria to qualify as an ESG Leader
3  Basic ESG Quality
Higher
+100bps for DM
+150bps for EM
Meets Comgest’s “quality growth” selection criteria 
to qualify for the investment universe and Comgest’s 
governance criteria, but these companies exhibit one or 
more of the following elements:
	
−
Disclosure is suboptimal regarding material 
sustainability risks
	
−
A weakness is detected in the mitigation of inherent ESG 
risks or the company’s response to other material ESG 
issues
	
−
Recurring non-material ESG controversies
4  ESG Improvement Expected
Higher
+200bps for DM
+300bps for EM
Meets Comgest’s “quality growth” selection criteria to qualify 
for the investment universe and Comgest’s governance criteria, 
but these companies exhibit a clear need for improvement in 
one or more of the following elements:
	
−
Disclosure regarding material sustainability risks 
	
−
Mitigation of inherent ESG risks
	
−
Response to other material ESG issues 
	
−
Exposure to significant and recurring ESG controversies
10 Comgest’s governance principles: long-term performance orientation, accountability and transparency, honesty and integrity, shared purpose and engagement
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The ESG Quality Level breakdown of investee companies assessed in our principal strategies as of 31 December 
2023 is shown in Figure 6.
Figure 6. ESG Quality Level in Principal Strategies11
11 ESG quality levels assigned may be subject to change at any time. The portfolios may include investments for which an ESG quality level has not yet been assigned.
5. IMPACT OF OUR ESG ANALYSIS ON POSITION SIZING / PORTFOLIO CONSTRUCTION
Based on team discussions, we select companies from the Universe to create concentrated portfolios, 
assigning weightings based on the relative attractiveness of each company. 
When adding a company to a portfolio, ESG integration contributes to all three components used in 
determining the weight of a holding:
	– Earnings visibility / overall quality of the business
	– Attractiveness of valuation at any point in time
	– Level of growth
Each of these three characteristics involves elements of our ESG integration process:
Due to rounding, figures may not add up to 100%.
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§
Earnings visibility / quality
The portfolio managers carefully consider the 
visibility of a company’s future earnings which 
depends on the overall ‘quality’ of the business 
according to our selection criteria. 
In this assessment, many ESG-related items come 
into consideration such as governance structure, 
stakeholder relationships, transparency of 
management, controversies and other material 
sustainability risks and adverse impacts. 
	§
Attractiveness of valuation
ESG considerations are taken into account within 
the company-specific discount rate used in our 
models (see Principle 7, item 4, “Valuation”), directly 
impacting the calculation of potential upside 
(financial return) with reference to a company’s 
prevailing stock market valuation. Lower ESG risk 
leads to higher potential upside, a factor considered 
in the position sizing process.
	§
Level of growth
The ESG profile of a company can impact our 
estimate of the level of growth. For example, for 
companies directly benefiting from a product or 
services that represents an ESG opportunity, the 
projected growth rate will take this into account. 
For companies with significant ESG risks that may 
materialise into financial risks over our 5-year 
investment horizon, we are likely to assign a lower 
confidence level to forecasted growth rates. 
Ongoing monitoring and approach to higher ESG risk profile companies
Investee companies across all strategies are 
then monitored on an ongoing basis from an ESG 
perspective. The purpose is to identify ESG events 
(controversies, change in corporate structure, 
change of board/management, etc.) which could 
affect a company’s ESG/quality profile, valuation 
and/or reputation. 
Where material events occur, the ESG assessment 
would be revised accordingly, and the investment 
case could be re-assessed. This monitoring is 
conducted systematically for all strategies using 
third-party tools that provide real time updates 
on changes in governance and new controversies. 
The ESG team provides an update to the relevant 
Investment teams on alerts they have received.
In order to collect and share ESG data and 
information more efficiently within Comgest, we 
have developed several in-house tools in recent 
years, including central “dashboards” hosting key 
information at a security and portfolio level. We 
also maintain a bespoke ESG assessment tool that 
summarises key metrics alongside our proprietary 
research on portfolio companies.
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Signatories monitor and hold to account managers and/or service providers 
OUTSOURCING AND VENDOR MANAGEMENT PROCESS
To effectively manage relationships with service 
providers, Comgest has outsourcing and vendor 
management policies and procedures in place which 
define the process for managing and monitoring 
relationships with service providers (including ESG 
data providers). This includes ensuring that the 
appropriate legal agreements and structures are in 
place to facilitate a comprehensive view and oversight 
of the service provider. 
Oversight is carried out through a combination of risk 
assessments, due diligence reviews and/or 
performance (service level) assessments, depending 
on the service provider and type of service offered. 
The business owner who engaged the service provider, 
is responsible for the assessment of performance and 
service level reviews, as well as participating in any 
due diligence as may be required. 
Comgest looks to ensure that appropriate action is 
taken where a service provider is not carrying out the 
functions effectively or in compliance with applicable 
laws and regulatory requirements.
ESG DATA PROVIDERS
As explained under Principle 2, in order to 
complement our proprietary research, we use a 
number of data providers to support our stewardship 
activities.
We have chosen these data providers because they 
offer wide coverage in terms of investee companies, 
which corresponds to our Universe. Furthermore, the 
methodologies they implement are aligned with our 
investment philosophy and values. Several of these 
data providers specialise in certain topics – additional 
expertise that we believe best serves our research and 
therefore our clients.
Comgest does not rely solely on our service providers’ 
data, however we apply our own analysis to the raw 
data supplied, valuing proprietary, fundamental 
analysis in our research process. 
We meet regularly with our providers to share 
feedback on their services, with clear indications 
of where they have met our expectations and areas 
requiring improvement. Our proprietary approach to 
ESG research means that we sometimes discover gaps 
or other findings in our providers’ output. We share 
these findings with them to help improve the quality 
of information they provide us and the market at 
large.
We seek to verify information from external providers 
and pay specific attention to any divergent or 
contradictory information concerning ESG issues or 
controversial activities. In such scenarios, we engage 
in direct dialogue with the company in question as 
well as various stakeholders to better understand the 
issues. Our own qualitative analysis often reveals 
the need to look beyond the data provided by our 
data providers. For instance, in November 2023, our 
ESG team identified discrepancies in one of our data 
providers’ reported EU Taxonomy data. Our team 
pointed out instances in which companies flagged as 
“NFRD12 eligible” had empty fields regarding reported 
EU Taxonomy data. The team also highlighted to the 
data provider instances where total EU Taxonomy 
reported turnover did not match the reported turnover 
data per environmental objective. After several 
discussions, and sharing the companies’ disclosures 
to support our comments, the data provider was able 
to confirm in December that several changes were 
made to correct the data on its platform.
PRINCIPLE 8
12 NFRD refers to the EU’s Non-Financial Reporting Directive
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Additionally, an annual survey is conducted to 
collect feedback from the ESG team on the team’s 
usage of data made available by data providers. This 
exercise allows Comgest to monitor data quality, 
identify challenges and, when necessary, assess 
services which no longer fit our needs and should 
be discontinued. The ESG team meets with and 
typically trials new providers each year to ensure they 
are up-to-date with the latest information sources 
available in the marketplace. We also discuss data 
provider quality in our interactions with clients and 
broader industry participants. We are not committed 
to using a single provider for any one area of our 
research and where any information gap is apparent 
with one provider, we will provide feedback and seek 
an alternative if necessary. This review also leads us 
to discontinue some data services should we assess 
they no longer fit our approach. This was the case 
in late 2023, when we terminated our subscription 
to data related to the United Nation’s Sustainable 
Development Goals (SDGs) from one of our providers 
because it no longer met our expectations.
Where Comgest identifies a lack of available data or 
standardised methodology, it may join other investors 
to further develop methodologies and contribute to 
the enhancement of solutions which aim to facilitate 
data collection and reporting. 
In 2023, Comgest joined the investor-led Avoided 
Emissions Initiative aiming to standardise the 
calculation of avoided emissions (see Principle 4, 
“Standards and initiatives related to climate”). The 10 
partners supporting the initiative are working with 
specialised consultants to develop a global database 
of GHG emission avoidance factors for low-carbon or 
green enabling solutions. This database will initially 
cover 80 solutions with related avoided emissions 
factors and is expected to be available by the end of 
2024. This standardised and transparent database 
will be made available to all stakeholders who need 
to calculate avoided emissions, including companies, 
consultants, financial institutions and data providers.
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PRINCIPLE 9
Signatories engage with issuers to maintain or enhance the value of assets
As described under Principle 1, given our concentrated and long-term investment approach we aim to remain 
invested in a company for many years. Therefore, maintaining strong relationships with investee companies is a 
key element of our investment process. We believe that active engagement can result in tangible improvements to 
a company’s operations and earnings sustainability and is therefore key to delivering long-term performance to 
our investors. Our Investment team engages with companies in a constructive and purposeful dialogue throughout 
the research and monitoring process, rather than simply in reaction to one-off events or news.  As described in 
Principle 6, we regularly report on the details of our engagement activities to our investors.
DEFINING ENGAGEMENT
We define engagement according to two primary activities:
1.	Information exchange: requesting and discussing 
sustainability information to inform our overall 
assessment of a company. Dialogue may also 
involve providing feedback to investee companies 
to share our opinions on industry best practices. 
These exchanges of information typically occur over 
the course of our ongoing, direct interaction(s) with 
investee companies.
2.	Objective-driven engagement: purposeful dialogue 
to achieve change in order to improve outcomes for 
stakeholders. For these engagements, we monitor 
the evolution carefully by specifying objectives 
and reporting on the ongoing status and eventual 
outcomes, as described below. 
METHODS OF ENGAGEMENT 
Types of engagement
Our engagements are performed either via individual or collaborative means, as follows:
	– Individual engagement
Most of our engagement activity is through direct, 
individual interaction(s) with companies. Typically, 
these engagements are carried out by an ESG analyst 
and the relevant company analyst/s within the 
Investment team. 
Our engagements are tailored to each company. 
Rather than approaching company meetings with 
a standardised checklist, we design our own set of 
questions corresponding to our assessment of the 
most material topics impacting the business at hand. 
In our experience, this can encourage companies to 
provide higher-quality, more informative responses. 
We believe it is important to commend companies on 
achieving ESG milestones throughout our engagement 
process, in order to encourage ongoing dialogue and 
further advances.
	– Collaborative engagement
In certain scenarios, teaming up with like-minded 
investors and other stakeholders can be a more 
effective means of achieving our objectives. 
Collaborative initiatives are typically led by our 
central team of ESG specialists. 
Comgest is selective about the collaborative 
engagements that we undertake. Our focus is on 
achieving results that may improve outcomes for our 
portfolio companies over our long-term investment 
horizon.
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Forms of engagement
Our interaction with companies can take several 
forms, including:
	– Written communication (emails, formal letters) 
with companies and other relevant stakeholders
	– Meetings, both virtual and physical, with (including, 
but not limited to): stakeholders such as investor 
relations, senior management, board members, 
sustainability teams, human resources and experts
	– Site visits, such as to company premises, 
operational locations, suppliers
	– Use of collaboration platforms
Our commitment to engagement does not differ 
between portfolios as active ownership is key to 
delivering our singular investment strategy. However, 
our methods of engagement can differ between 
the regions and companies in which we invest. For 
example, when seeking improvements on data privacy 
by big tech companies such as Facebook, Amazon 
or Alphabet, we have conducted more collaborative 
engagements, as the voice of many investors carries 
more weight than an individual shareholder with 
these companies. However, most engagement 
activities that we conduct are direct, across all regions.
OUR APPROACH TO ENGAGEMENT
1.	
We take a partnership approach to engaging with companies
Comgest considers our relationships with investee 
companies, clients and employees similarly: as 
a partnership. As a stable shareholder, we aim to 
develop a deep understanding of our companies and 
to develop open, transparent dialogue with them. 
When engaging on areas for improvement, as a 
starting point we typically prefer to discuss the topic 
directly with the company in an open discussion, 
rather than applying collective or public forms of 
pressure. In our experience, we find that investee 
companies appreciate our partnership approach 
to engagement and are therefore likely to be more 
responsive to our demands.
2.	 We prioritise our engagement efforts
We prioritise engagement with investee companies and other industry participants according to the following:
i.	 Materiality matters most
As part of our proprietary ESG analysis and formal 
ESG assessment of each portfolio company, the 
Investment team identifies material ESG risks and 
opportunities facing the business. While top-down 
analysis such as sector and geographic sensitivities 
can be a useful starting point to identify ESG risks and 
opportunities, our conclusions are always informed 
by our bottom-up research performed on each unique 
company. Stewardship activity is then prioritised by 
the materiality of our findings for each company. We 
also take into account the results of principal adverse 
impact (PAI) assessments.
	– Issues that we prioritise for engagement will 
naturally vary between geographic regions, 
industry sectors and individual companies, and 
are informed by our own research. We adapt our 
engagement focus to the strategy, product or 
company under analysis, for example:
	§ For businesses whose operations are highly 
dependent on access to natural resources (e.g. 
food, beverage or textile sectors) or businesses 
whose products cause high emissions (e.g. 
automotive and aviation industries), our 
engagement activity is likely to focus on 
managing environmental risk and mitigating 
environmental impacts within their ecosystem.
	§ For businesses whose operations may pose 
high health and safety hazards to workers or 
have significant socioeconomic impacts on 
local communities, such as the construction 
and chemical industries, our engagement 
activities will likely focus on managing social risk 
exposures and mitigating social impacts within 
their ecosystem.
	§ For products that focus on, or have exposure to, 
certain regions such as emerging markets, issues 
such as corruption or taxation policies may be a 
more common risk. 
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– Probability of success is important to assess in 
the context of materiality. Where there is an ESG 
matter that is material to the business case, and we 
believe that an engagement could tangibly help to 
address the ESG risk or opportunity, stewardship 
activity with this company will be prioritised versus 
other portfolio companies. 
	– Comgest’s ESG Quality Level 4 companies are 
companies that while investible within our quality-
growth portfolios, “require improvement” within 
their ESG profile, according to our proprietary 
analysis. We therefore prioritise seeking 
improvement in these companies by way of direct 
and collaborative engagement, exercising voting 
rights and participating in industry initiatives.
ii.	 Our commitments
Comgest is a signatory to a number of industry 
initiatives and collaborative activities which will 
lead to prioritising our stewardship activity with 
certain companies. For example, as a signatory 
to the Net Zero Asset Managers initiative, we are 
prioritising engagement on climate with companies 
who represent the top contributors to our financed 
emissions as a Group. 
iii.	Thematic areas of risk exposure
Comgest closely monitors three thematic risk areas: 
climate, biodiversity (deforestation) and human rights. 
We have developed individual policies for these topics, 
as outlined in 
 Comgest’s Responsible Investment 
Policy. 
These topics are considered material in relation to 
primary ESG risks and principal adverse impact 
mitigation. Companies with material exposure to ESG 
risks within these categories may be identified for 
individual engagement or coordinated actions such as 
collaborative engagements and advocacy initiatives.
iv.	 Support for bespoke client priorities
Within our segregated client mandate accounts, some 
clients have stipulated that we implement certain 
bespoke engagement priorities, in which we act on 
their behalf. 
We monitor and report on our engagement progress 
via our client reporting which provides detailed 
summaries of our interactions with companies as well 
as the objective and status of each engagement. 
3.	 We engage over long periods of time 
Achieving results from an engagement can take time. 
Sometimes, it is simply a long process to address 
structural issues or change a large company’s 
operational practices. In other cases, it is the 
repetitive raising of issues, consistently over several 
years, that eventually leads to a real change.
As stable shareholders, we are able to engage with 
companies over multi-year horizons and work 
with them in partnership as they try to adapt to a 
complex and changing sustainability landscape. Our 
engagement dialogue is forward-looking and long-
term. Our topics and priorities of engagement will 
evolve over time, in-line with the issues we identify as 
material to the long-term success of the company. We 
engage on important matters even when we know our 
opinion might not be well received.  
As long-term investors, we are comfortable knowing 
that engagement can yield results gradually, 
sometimes over many years, before we would consider 
that our activity has reached a conclusion. 
4.	 We engage ahead of annual general meetings (AGMs)
As part of our open dialogue with companies, we 
may engage ahead of general shareholder meetings 
to discuss, and sometimes influence, their proposed 
resolutions. 
5.	 We engage with all companies, even if they are an ESG Leader
We believe all companies can improve. Each business 
will have its own specific, and often evolving, 
sustainability challenges to address. We aim to 
identify these issues throughout our research 
and to ensure that we understand each company’s 
sustainability strategy.  Any material areas for 
improvement are highlighted within our ESG 
assessments.
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In the spirit of our ESG integration approach, Comgest 
is prepared to invest in companies with a lower ESG 
Quality Level where there is an identified opportunity 
for improvement, and we believe the company is 
willing to engage on those measures. In such cases, 
the heightened ESG risk of the company is reflected 
in the higher discount rate applied to the valuation, 
which impacts the Investment team’s projected 
upside on the stock. The position size is thus likely to 
be smaller until such improvements become tangible. 
Where companies identified for improvements have 
not demonstrated progress towards those measures, 
Comgest may further escalate its engagement with 
the company or eventually choose to divest. 
While companies with lower ESG Quality Levels 
may lead to higher levels of engagement activity, we 
nevertheless identify topics to engage upon right 
across our range of companies including among our 
ESG leaders.
ENGAGEMENT OBJECTIVES, MONITORING AND ASSESSMENT OF OUTCOMES
Setting objectives
For each objective-driven engagement, we set 
clearly defined targets. This could be, for example: 
“improve disclosure by reporting via the CDP water 
questionnaire” or “improve governance structure by 
increasing board gender diversity to be at least 30% 
women”.
Monitoring progress and outcomes
Through our interactions with a company, we monitor 
their achievement of milestones and improvements 
that clearly indicate progress towards our objectives. 
Engagements may remain ongoing for several years. 
If there is clearly no improvement or reactivity on 
the part of a company, we may decide to escalate as 
described in Principle 11. 
There are four potential stages identified within our 
engagement monitoring:
1.	 Ongoing: engagement initiated, the company 	
	
has acknowledged our concerns, and we are 		
	
awaiting progress
2.	Escalation: insufficient response to our concerns, 	
	
we initiate other engagement actions to 	
	
	
encourage change (see Principle 11) 
3.	Success: the company implements measures to 	
	
address our concerns, engagement is completed.
4.	Failure: Unsatisfactory action taken within target 	
	
engagement time horizon (maximum five years). 	
	
This may lead to divestment depending on the 	
	
materiality of the topic.
Following the engagement
If an engagement is considered successful, the team 
members involved in the engagement may also 
share their experience and findings across the ESG 
and Investment teams to ensure that any future 
engagements may benefit from the team’s collective 
experience, by applying relevant engagement 
techniques and learnings.
If an engagement is considered unsuccessful but the 
topic is considered material in nature, we may deploy 
escalation techniques as described in Principle 11. 
An unsuccessful escalation may result in divestment. 
If we decide to continue to own the company, 
knowledge gained from the engagement experience 
will be incorporated in our ESG Assessment of the 
company and may weigh on the resulting ESG 
Quality Level assigned. In addition to the qualitative 
learnings gained by the Investment team throughout 
the process which may impact the level of conviction 
that the team maintains on each company, the ESG 
Quality Level impacts the discount rate used in our 
valuation models and therefore directly feeds into the 
portfolio construction process.
At all times, our engagement work will inform 
our ongoing ESG research and views held for each 
company. We seek to learn from our experiences 
with the objective of continually improving our 
engagement techniques. 
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OUTCOMES OF ENGAGEMENT
In 2023, we engaged with 96 companies and carried out 137 engagement actions. Statistics on these activities are 
provided in the charts below. The most common topic of engagement was climate change.
Figure 8. Engagement activities across Comgest’s portfolios 
Asia ex Japan
Europe
Japan
North America
Rest of World
Region Breakdown
36%
25%
26%
4%
9%
Topic Breakdown
Environment
Social
Governance
Overlapping ESG issues 
42%
5%
9%
43%
Information Exchange
Objective-driven 
Engagement
Engagement Type Breakdown
52%
48%
Sub-topic Breakdown: Environment
Climate change
Water
Biodiversity: Use of natural 
resources
Biodiversity: Waste and 
pollution
Biodiversity: Deforestation
Environment: Other
30%
5%
4%
4%
6%
0%
Sub-topic Breakdown: Governance
Human rights
DEI
Human Capital Management
Health & Safety
Customer or Product  
safety related
Data Security
Social: Other
4%
3%
7%
3%
2%
1%
0%
Sub-topic Breakdown: Social
Conduct culture and ethics
Ownership, control and 
shareholders rights
Remuneration
Board effectiveness: DEI
Board effectiveness: Other
Management related
Governance: Other
Disclosure
6%
0%
7%
4%
5%
4%
2%
3%
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–        
CASE STUDY
EXAMPLE OF A SUCCESSFUL ENGAGEMENT: BB SEGURIDADE (BBSE)
(Leading insurance group in Brasil)
In March 2023, ahead of its AGM, our ESG analyst 
corresponded with BBSE’s Chief Financial Officer 
(CFO) and Investor Relations (IR) representative to 
send an application for Mrs. Maria Carolina Ferreira 
Lacerda as a candidate for the Independent Board 
Member position at BBSE.
As Mrs. Isabel Ramos had been an independent board 
member at BBSE for over nine years, we wanted to 
propose a new candidate. After conducting some 
market research, we held discussions with Ms. Maria 
Carolina Ferreira Lacerda, a Brazilian professional 
with a good reputation in the market and whose 
impressive resume includes current independent 
board memberships at PagSeguro, Hypera Pharma 
and Rumo (companies we know well), among others. 
For the past 16 years, she has also held executive 
positions at financial institutions (i.e., UBS, Deutsche 
Bank, Unibanco and Merrill Lynch). 
Ms. Ferreira Lacerda made a strong impression on 
us. Hence, after a series of calls which our ESG and 
company analysts had with her in February 2023, 
we sent Mrs. Maria Carolina Ferreira Lacerda’s 
application as a candidate for the position of 
independent board member at BBSE to the CFO and 
to the IR.
The company welcomed our proposal and the 
resolution for Ms. Ferreira Lacerda’s election was 
included in the agenda of their AGM held on April 28, 
2023. Following the AGM, we were pleased to see that 
the resolution was passed.
 
      
 
  
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–        
EXAMPLE OF AN ENGAGEMENT WITH SIGNIFICANT PROGRESS: KEYWORDS STUDIOS
(Ireland-based global provider of technical services to the video game industry)
In April 2023, we engaged with Keywords’ Chair 
of their Remuneration Committee to discuss their 
proposed pay package ahead of the AGM in May 
2023. We advocated for changes in the Long-term 
Incentive Plan (LTIP) as we considered that adding 
additional metrics besides relative total shareholder 
returns (TSR) such as returns-based KPIs may better 
reflect management performance and balance M&A 
in their growth strategy plan. We encouraged the 
decrease of new share issuance to fund acquisitions 
and our feedback was taken on board. Additionally, 
we encouraged Keywords to accelerate the change 
of auditor. The company acknowledged our views, 
committing to implementing those changes over 
time. As a result of the engagement, we voted in 
favour of the proposed remuneration package while 
continuing to advocate for LTIP change, better 
disclosure and change of auditor. 
The engagement continued in October 2023, during 
which time we discussed the new 2024 Remuneration 
Policy with the Chair of Keywords’ Remuneration 
Committee. The proposed changes to the executive 
remuneration did not come as a surprise as we had 
discussed with them extensively in the previous 
engagement meeting. We took comfort in the fact 
that some of our ideas were included in the new 
policy, including the changes to the LTIP, which is 
now more balanced as it no longer relies solely on 
relative TSR, 
but now also includes organic revenue growth, 
adjusted cash conversion, a return on capital 
employed (ROCE) underpin as well as ESG targets 
such as carbon emissions and diversity. In addition, 
while we found the annual bonus somewhat small 
(maximum 30% of base salary), we did not view the 
increase in maximum opportunity level (to 125%) 
negatively, as long as targets are stretched and 
disclosed retrospectively.
While acknowledging that the changes were not 
perfect, we believed that they moved in the right 
direction. During the meeting, we continued to call 
for a more balanced LTIP, based not only on TSR, but 
also on effective capital allocation (return on capital) 
and revenue metrics that take into account organic 
and M&A-stimulated growth. We also supported an 
increase of the annual bonus of the CEO Bertrand 
Bodson, provided that the targets are ambitious and 
disclosed. Finally, while we supported the inclusion 
of non-financial metrics in the incentive plan, we 
deemed the carbon component immaterial given that 
Keywords is not a high-climate impact business. The 
Chair duly noted our views and appeared favourable 
to further refining the Pay Policy as a consequence. 
We will monitor the publication of the company’s 
new Remuneration Policy in 2024.
CASE STUDY
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Differentiating our engagement approach by region: Environmental disclosure remains a priority engagement 
objective in our Emerging Markets strategies.
As noted in our report from last year, a lack of 
environmental disclosure is often an obstacle we face, 
especially in Emerging Markets where companies tend 
to be generally less pressured by regulators to disclose 
climate risks, opportunities and impacts. Hence, 
requesting this data is often the starting point of our 
engagements and guides our selection of companies 
we engage with through collaborative campaigns. 
This is notably the case for the CDP Non-Disclosure 
Campaign (NDC) which Comgest has been supporting 
on an annual basis since 2018. During the 2023 
Campaign, 45% of the companies we targeted were 
based in emerging markets. 
We see our role as helping these companies 
understand the importance of enhancing 
transparency on their environmental practices, as 
well as assisting them in navigating the CDP reporting 
process or, when necessary, connecting them with 
local CDP teams. Our engagement is not solely carried 
out through the NDC; we may discuss the topic during 
individual discussions with companies before and 
after the campaign. One example in the 2023 CDP 
is our engagement with Vinamilk, the largest dairy 
company in Vietnam.
In May 2023, ahead of this year’s campaign, our 
analysts contacted Vinamilk’s Investor Relations 
Director, to find out why despite Vinamilk’s 
comprehensive disclosures on environmental-related 
data in their annual Sustainability Reports, the 
company does not disclose via CDP’s climate change 
questionnaire. The company explained that they 
have considered the CDP disclosures but first need to 
ensure that they have sufficient internal resources to 
provide all the data at an acceptable level of quality. 
After we insisted on the benefits of CDP disclosures, 
they held an internal discussion and decided to send a 
questionnaire to their key stakeholders to investigate 
their preferences and gather feedback on Vinamilk’s 
disclosure according to various ESG-related standards. 
Prior to sending the questionnaire, the company also 
asked us about our views on CDP, TCFD, and MSCI. 
A week later, Vinamilk sent us the questionnaire as 
promised, which we answered in detail.
In June 2023, as a lead investor, we sent a letter to the 
company to request the submission of a response to 
CDP’s climate change and forests questionnaires. We 
then followed up with the company through several 
email exchanges on their plans to respond to the 
questionnaire. During our exchanges, we also offered 
the company some sample answers and guidance 
on certain questions that they found challenging to 
answer. Following the engagement, we were pleased to 
see that the company started its reporting journey by 
submitting their first Climate Change questionnaire 
in 2023.
In February 2024, following the release of the 
2023 CDP scores, the company informed us that 
they received a “C” score on the climate change 
questionnaire and expressed appreciation for our 
support during the engagement. This first score 
represents a key step in the company’s transparency 
journey and an encouraging assessment of the 
company’s practices. With a C score, the company is 
positioned within Asia’s regional average score and 
part of the only two Vietnamese companies which 
have received a CDP score.
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PRINCIPLE 10
Signatories, where necessary, participate in collaborative engagement  
to influence issuers
We identify engagement themes through common issues arising from our bottom-up engagement with companies 
as well as through the top-down priorities we have established as a responsible investor. Our areas of focus will also 
take into account the results of our principal adverse impacts assessment.
As described under Principle 9, although most of our engagement activity is through direct, individual interaction 
with companies, in certain scenarios teaming up with like-minded investors and other stakeholders can be a more 
effective means of achieving our objectives. 
Comgest closely monitors three thematic risk areas: climate, biodiversity (deforestation) and human rights. These 
topics are considered material in relation to primary ESG risks and principal adverse impact mitigation. Companies 
with material exposure to ESG risks within these categories are prioritised for collaborative engagements and 
advocacy initiatives. Please see below the list of collaborative engagements for 2023.
Examples of collaborative engagements undertaken in 2023
SPONSOR/ 
TITLE
REGION
OBJECTIVE 
OUTCOME
CDP Non-
Disclosure 
Campaign
Global
As per the last five years, Comgest 
participated in the 2023 CDP Non-
Disclosure Campaign, a collaborative 
engagement campaign that encourages 
companies to disclose more standardised 
environmental information to allow for 
better comparison. In 2023, as a lead 
investor, we engaged with 31 companies by 
sending letters to request the submission of 
CDP Climate Change, Water and/or Forest 
questionnaires.
Overall, five of these companies (16%) 
replied to at least one CDP questionnaire. 
Although the 2023 campaign is now over, 
we will continue to engage with these 
companies and to request increased 
transparency on their environmental 
practices, especially those who have not 
submitted a CDP questionnaire.
CDP Science-
Based Targets 
Campaign 
Global
Comgest has participated in the CDP 
Science-Based Targets Campaign since 
it started in 2021. This campaign aims to 
accelerate the adoption of science-based 
climate targets by companies. We sent follow 
up emails to eight companies in the 2022-
2023 Campaign and to three companies in 
the 2023-2024 Campaign. Where material, 
we also use individual engagement meetings 
with companies to encourage them to set 
SBTs.
During the 2022-2023 Campaign, 1,060 
companies were targeted. 99 new 
companies joined the SBTi as a result. In 
addition to the Campaign, we observed 
that 18 new companies held in our 
portfolios had their SBTi targets approved 
during 2023, bringing the total number 
of companies we invest in with approved 
targets to 95 companies as of December 
2023. If we also consider the 43 companies 
which have committed to set SBTi targets, 
approximately 40% of the companies we 
held at the end of 2023 had joined the SBTi.
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SPONSOR/ 
TITLE
REGION
OBJECTIVE 
OUTCOME
Investor 
Initiative on 
Hazardous 
Chemicals 
(IIHC) 
Global
The IIHC is a global network of institutional 
investors, coordinated by the NGO 
ChemSec, that aims to reduce the adverse 
impacts of hazardous chemicals and 
thereby its members’ exposure to the 
financial risks to which they are linked. As 
member of the initiative, in 2023, Comgest 
continued to participate in collaborative 
engagements and co-led the engagements 
of two companies.
In 2023, as co-lead investor, we held 
engagement meetings with LG Chem and 
Shin-Etsu.
Overall, we were satisfied with the progress 
made following our engagements with both 
companies and we will continue to monitor 
their progress and engage with them in 
2024.
30% Club 
France 
Investor 
Group 
France
30% Club France Investor Group is a French 
chapter of the business campaign aiming to 
boost the number of women in board seats 
and executive leadership of companies all 
over the world. Comgest joined this initiative 
in September 2022 and led an engagement 
with one company during 2023.
In 2023, we led an engagement with 
Capgemini and we will continue to 
participate in this collaborative engagement 
initiative in 2024.
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Signatories, where necessary, escalate stewardship activities to influence issuers 
As outlined in Principle 9, maintaining an active dialogue with investee companies is a key element of our 
investment process. Where companies identified for improvements have not demonstrated progress towards 
those measures over time despite our engagement with them, Comgest may escalate our engagement with the 
company or eventually divest.  
ESCALATION APPROACH 
Our approach to escalation does not differ across funds or geographies apart from where local laws and practices 
require, such as with respect to filing shareholder resolutions.  
Our goal when voting and engaging with companies 
is to maintain a transparent dialogue with companies 
in order to achieve improvement. We like to work 
in partnership with our investee companies on 
engagement issues. It is therefore only if none of 
our engagement methods have yielded success, 
and it becomes clear that we will not achieve our 
engagement objectives through active dialogue, that 
we may be compelled to escalate our concerns. This 
occurs when we are not satisfied with responses from 
multiple interactions with the company, typically 
involving also multiple representatives of the 
company.
As highlighted in Principle 7, during our proprietary 
ESG assessment process, when assigning ESG Quality 
Levels from 1-4 (1 being a leader, 4 being a company 
that requires improvement) to investee companies 
we seek to identify sustainability strengths and 
weaknesses. Our ESG Quality Level 4 companies often 
require more attention as their category indicates 
“improvement required”. Our analysts will typically 
increase engagement efforts with these companies 
and closely monitor their progress against our ESG 
milestones.
METHODS OF ESCALATION 
When faced with a lack of responsiveness on the part of companies in response to an engagement action, some of 
the next steps we may take include the following:
	– Raising our concerns to the board, including 
independent board members. We also use our 
voting rights at AGMs and may convey our voting 
intentions to boards and executive committees 
ahead of AGMs in order to highlight our stance 
on a particular matter of disagreement. In certain 
scenarios, we may also decide to pre-declare our 
voting intentions publicly on our website.
	– Collaborating with other investors on the 
engagement can be a more efficient form to 
achieve desired outcomes from escalation activities 
by creating a united front and amplifying the 
weight of our requests.
	– Sending formal letters to the company or Board 
to make our stance more official (individually or 
collaboratively).
	– In rare cases, we may consider informing regulators 
or the press of our stance or file a shareholders’ 
resolution in cases where we believe the company 
kept ignoring the interests of minority shareholders.
	– Divestment
PRINCIPLE 11
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–        
Amazon
US-based multinational technology company engaged in 
e-commerce, cloud computing, online advertising, digital 
streaming, and artificial intelligence
Linde
UK-based industrial gases and engineering company
2023 PRE-DECLARATION OF VOTING INTENTIONS
 
      
 
  
As an active manager, we consider voting as a key lever to influence and exercise our stewardship responsibilities. 
We view pre-declaring our voting intentions as an opportunity to strengthen ongoing engagements that we deem 
important. 
In 2023, we pre-declared our voting intentions for 2 shareholder resolutions:
Shareholder Resolution: Provide comprehensive 
disclosure on GHG emissions.
US – Annual General Meeting 
Comgest’s vote intention: For Shareholder 
Resolution
Comgest Rationale: Comgest is a signatory to the 
Net Zero Asset Managers initiative and commits 
to supporting the global goal of net-zero GHG 
emissions by 2050 across all our listed equity assets. 
Engagement is a key lever that we use to deliver on 
our climate commitments and anchor our action in 
real-economy decarbonisation.
We recognise that measuring full value chain 
emissions is challenging. However, carrying out this 
assessment and providing comprehensive disclosures 
on GHG emissions is an indispensable foundation to 
develop both science-based decarbonisation goals 
and credible transition plans. We therefore support 
comprehensive disclosure of scope 3 emissions, 
notably via the CDP climate change questionnaire. 
We also expect transparency on what emissions 
are covered by net-zero claims, and in the specific 
case of Amazon, for the company to follow through 
with its commitment to set targets approved by the 
Science-Based Targets initiative (SBTi).
Comgest’s vote intention: For Shareholder 
Resolution
Comgest Rationale: Comgest is a signatory to the 
Net Zero Asset Managers initiative and commits to 
supporting the global goal of net-zero GHG emissions 
by 2050 across all our listed equity assets. Success 
in achieving our climate targets relies on the world 
achieving a net-zero economy and numerous 
stakeholders, including governments and companies, 
following through on their commitments. Linde 
represents a substantial percentage of Comgest 
financed emissions. Hence, we are closely following 
the company’s progress on climate alignment 
and are encouraging their management to take 
all necessary actions to foster transparency in 
the implementation of their climate strategy, 
including reporting on lobbying in line with the 
Paris Agreement. Our vote, and this pre-declaration 
statement, is part of our ongoing engagement 
activities with the company and we look forward to 
future dialogue opportunities with Linde on climate-
related issues.
Shareholder Resolution: Report on lobbying in line 
with Paris Agreement.
UK – Annual General Meeting 
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TIME HORIZON AND CONDITIONS THAT COULD LEAD US TO DIVEST 
As long-term investors, we have always been comfortable knowing that engagement can yield results gradually, 
sometimes over many years, before we would consider that our activity has reached a conclusion.
Where we see no prospect of the company enacting change and if our concern is material in nature, we may sell 
our position. Once an engagement that has been identified to be of material concern commences, we define a 
maximum horizon of five years for our efforts to incite change before exiting, in the best interest of shareholders.
	–        
CASE STUDY
ESCALATION FOLLOWED BY A DOWNGRADE OF THE ESG QUALITY LEVEL: DSV
In early October 2023, we initiated a dialogue with 
transport and logistics company DSV because of 
deteriorating workforce KPIs (turnover, sick leave, 
fatalities). During our meeting, their Investor 
Relations representative noted that strengthening 
the company’s safety culture had become a top 
priority, especially in its newly acquired warehouse 
operations. We questioned why the company did 
not link health and safety metrics to pay when 
approximately 45%-50% of its workforce are exposed 
to high-risk warehouse operations. As a result of 
the engagement, we maintained the company’s ESG 
Quality Level 3. However, we continued to assess its 
health and safety performance in the context of a 
potential downgrade.
In late October, we engaged with DSV’s Chairman 
of the Board of Directors on the company’s CEO 
succession and newly announced joint venture 
in the NEOM project in Saudi Arabia, of which 
we raised concerns about potential human rights 
abuses. The NEOM project has been under scrutiny 
for social issues. DSV emphasised that its Code of 
Conduct applies to all direct and indirect employees 
and suppliers, and that it will be the guiding 
principle when doing business with NEOM. DSV 
acknowledged our comment that transparency on 
human rights and other social metrics (Health & 
Safety, integrity, worker conditions) will be essential 
to assure investors that DSV conducts business in a 
sustainable manner. Following this engagement, we 
assessed that DSV’s ESG risk exposure has increased, 
and we decided to downgrade the company’s ESG 
Quality Level from 3 to 4.
In late November 2023, we had another meeting with 
DSV’s Investor Relations representative to follow 
up regarding the NEOM project in Saudi Arabia. We 
were satisfied to hear that the elevated social/human 
rights risk is “top of mind” for management and the 
Board. We learned that DSV aims to hire workers 
directly. If unable to do so, it will conduct serious due 
diligence on the third-party recruitment agencies to 
ensure that workers’ rights are respected. Finally, 
DSV confirmed the company will provide its workers 
with company-owned accommodations that adhere 
to strict UN standards. We believe this will help to 
mitigate any potential violations, provide better 
oversight, and thus mitigate any reputational risk of 
human rights controversies.
Following the meeting, we sent a letter to the Board 
of Directors to encourage best practice for human 
rights governance regarding their joint venture with 
the NEOM project in Saudi Arabia. We expressed 
our concerns about the elevated human rights 
risk, potential reputational damage, and lack of 
accountability at the management and Board level in 
terms of social risks and business ethics.
We received confirmation of receipt of the letter from 
Investor Relations who reported that DSV is working 
on a human rights due diligence report/presentation 
related to the joint venture and investors’ input 
would be highly appreciated. We continue to monitor 
this issue and we will review the report/presentation 
as soon as it is available.
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Signatories actively exercise their rights and responsibilities
As an active investor and signatory to the PRI, Comgest’s objective is to vote systematically at all shareholder 
meetings held by all investee companies when this is technically possible to do so. We have designed our Active 
Ownership Policy based on our own beliefs as well as commonly accepted best practices and high governance 
standards. Our portfolios are invested in equities across the world, in both developed and emerging markets. Given 
the heterogeneous nature of these markets, their business practices, legislation and degrees of maturity, Comgest’s 
Voting Principles can differ across regions.  Full details can be found in our  
 Active Ownership Policy. 
COMGEST’S VOTING PRINCIPLES
1.   Reflective of our philosophy and fundamental 
investment beliefs 
We exercise our right to vote at shareholder 
meetings in accordance with corporate governance 
values and voting principles that have been 
determined with reference to regulations, 
industry standards, best practice, and the firm’s 
international experience. Our proprietary voting 
policy guidelines have been developed – and are 
expected to evolve – with our general engagement 
priorities in mind.
Comgest believes that a one-size-fits-all model 
of governance is not realistic, however we also 
believe that a number of fundamental principles 
nonetheless apply to all organisations that aim to 
be successful quality growth companies.
2.   Systematically vote whenever possible  
We believe that exercising our right to vote on behalf 
of our investors is an important element of our role 
as stewards and of our active ownership strategy. To 
vote is to have voice and it can be a driver of change. 
Comgest’s objective is to vote systematically at all 
shareholder meetings when technically possible. 
3.   Promote specific governance  
characteristics 
Comgest looks for and encourages our investee 
companies to apply the following 4 principles in their 
governance systems: 
	– Long-term performance orientation
	– Accountability and transparency
	– Honesty and integrity
	– Shared purpose and engagement
Our voting policy aims to encourage and reinforce 
the inherent values contained within these four 
principles. In making our investment decisions, we 
look for companies that are led by executive directors 
and guided by non-executive directors who embody, 
demonstrate, and perpetuate these values.
4.   One share, one vote
We consider the principle of “one share, one vote” to 
be fundamentally sound and we are therefore not 
generally in favour of multiple share classes with 
various voting rights that allow some categories of 
shareholders to have more voting power than others.
5.   Adapt our votes to company specificities, 
depending on stage of development, 
geography and sector
Voting decisions are very carefully considered for each 
General Meeting. We recognise that the companies 
in which we invest operate at varied stages of 
development, in sectors with differing dynamics and 
in geographies with specific business cultures and 
practices. It may therefore not always be appropriate 
to apply our Voting Rules rigidly and we may diverge 
from them in exceptional circumstances. If so, we 
look to ensure that our decision remains in line with 
Comgest’s overriding Voting Principles and document 
the reason for our divergence.
PRINCIPLE 12
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6.   Votes against company management recommendations 
Comgest may vote against company management 
recommendations when it feels that this is in the 
company’s and the shareholders’ best interests. In 
such cases where the risk identified is considered 
material, Comgest will typically explain to the 
company concerned its reasons for doing so, ahead 
of the AGM. Additionally, in our ongoing dialogue, we 
will seek to guide management where necessary while 
encouraging compliance with international standards 
of governance and corporate best practice. Under 
certain circumstances, we may decide to abstain 
from voting on a resolution where the proposal or 
disclosure is deemed to be lacking in some way, 
but not ultimately harmful. This may occur when 
Comgest was not given sufficient opportunity to 
address questions in relation to the matter with 
the company.  Where this is the case, Comgest will 
typically follow up with the company to subsequently 
address the point.
VOTING AGAINST / OVERRIDING COMGEST’S VOTING POLICY
We may elect not to follow our own standard voting 
policy where we consider that it does not take into 
account the specific circumstances of a company, and 
therefore may not be appropriate. This occurred in 
2.5% of cases in 2023.
For clients with whom we manage a dedicated 
segregated mandate (where these clients have 
delegated proxy voting rights to us), we either apply our 
own voting policy or the client’s specific voting policy. 
For our pooled funds, Comgest retains full voting 
discretion and applies its voting policy. Clients cannot 
influence voting on pooled funds. However, we do 
consider clients’ feedback and industry practice when 
reviewing and updating our Active Ownership Policy 
to ensure our voting and engagement standards are in 
line with client and industry expectations.
SECURITIES LENDING 
Comgest does not engage in stock lending for any of 
our portfolios.
For segregated accounts where clients engage in 
stock lending, we will monitor the votes where stock 
lending is in place and ensure that if the stock is 
recalled before the voting cut off that the available 
shares for voting have been updated on the proxy 
voting platform. 
VOTING PROCESS
We apply our own voting policy and do not delegate 
or outsource votes. Comgest’s voting rules (the 
“Voting Rules”) derive directly from Comgest’s 
Voting Principles detailed above. Specific Voting 
Rules have been defined on a regional or country 
basis in collaboration with the Institutional 
Shareholder Services (ISS) team dedicated to 
proxy voting policy customisation. Our Voting 
Rules are aligned with our approach to responsible 
investment. Comgest’s ESG team is responsible for 
overseeing implementation of the Group’s Voting 
Principles and reviews its Voting Rules every year 
on a region-by-region basis.
Voting recommendations reflecting the Voting 
Rules are produced by ISS for each general meeting. 
These recommendations in written form comprise 
the key documentation for the voting process.
To make the voting process as efficient as possible, 
Comgest uses the ISS web-based proxy voting 
platform which notifies Comgest of any general 
meetings of investee companies and enables 
Comgest to vote electronically in every country 
in which we invest, where technically possible. In 
addition, Comgest’s centralised Proxy Voting team 
is responsible for identifying general meetings 
in advance and ensuring that votes are cast in a 
proper and timely manner.
	
– Step 1: Identification of the general meeting 
on the ISS proxy voting platform: cut-off date, 
record date, whether share blocking or stock 
registration is required.   
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– Step 2: Lead analyst is informed of the agenda for 
the general meeting and voting recommendations 
in accordance with Comgest Voting Rules. Comgest 
assigns responsibility for analysing resolutions to 
the lead company analyst for each stock concerned.  
We believe that this is the most efficient means of 
ensuring that we have all the information necessary 
before we vote on what are often complex and 
diverse themes.  
	– Step 3: Lead analyst gives their voting 
recommendation to the Proxy Voting and ESG teams.  
 
Where the lead analyst’s recommendation is in line 
with Comgest’s Voting Rules, the vote is automatically 
processed. Where the lead analyst recommends a 
deviation from Comgest’s Voting Rules, they send 
information supporting this assessment to the Proxy 
Voting and ESG teams. The Proxy Voting team liaises 
with the ESG Team or relevant portfolio managers, 
as necessary, for a decision prior to submitting 
the vote. In cases where the voting decisions are 
not in line with voting recommendations based on 
Comgest’s Voting Rules, the reason for the divergence 
is documented.
	– Step 4: The Proxy Voting team enters the voting 
decisions where required into the ISS proxy 
voting platform.  
	– Step 5: The Proxy Voting team reviews the 
completed proxy voting activity via the meeting 
dashboard and archives provided by ISS to ensure 
that all votes have been cast appropriately. The Proxy 
Voting team also provides ISS a daily file from our 
internal portfolio management system so they can 
perform a reconciliation against the ballots they 
have received to ensure no ballots are missing for 
which Comgest has voting rights.   
VOTING STATISTICS
In 2023, Comgest voted at 445 general meetings, 
representing over 98% of all general meetings held by 
investee companies, or over 99% excluding meetings 
at which Comgest declined to vote to avoid conflicts 
of interest (please refer to Comgest’s 
 Active 
Ownership Policy for more information). 
Comgest did not vote at 1 general meeting held by 1 
company because voting was not considered to be in 
the best interest of investors.
Overall, Comgest voted on 5203 resolutions 
concerning 350 companies in 36 countries.
Comgest voted against, or abstained from voting on, 
at least one resolution at 278 general meetings.
Comgest exercised its voting rights on 5203 
resolutions out of a total of 5220 votable 
resolutions, representing 99.67%.
Comgest voted on 134 shareholder resolutions.
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COUNTRY
VOTABLE
MEETINGS
VOTED 
MEETINGS
%
Kazakhstan
4
4
100.00%
Luxembourg
3
3
100.00%
Mexico
9
9
100.00%
Netherlands
11
11
100.00%
Norway
2
2
100.00%
Philippines
1
1
100.00%
Portugal
1
1
100.00%
Russia
4
4
100.00%
South Africa
4
4
100.00%
South Korea
10
10
100.00%
Spain
2
2
100.00%
Sweden
3
3
100.00%
Switzerland
11
11
100.00%
Taiwan
4
4
100.00%
USA
47
47
100.00%
United Kingdom
15
15
100.00%
Vietnam
26
26
100.00%
ESG Themes 
BREAKDOWN OF THEMES
%
Environmental
0.10%
Social
1.17%
Governance
98.37%
ESG
0.36%
Resolutions are largely driven by Governance topics, 
even if we have seen Environmental and Social (E & 
S) resolutions gaining space over the past few years. 
Most of the E & S resolutions were shareholder 
resolutions.
13 Voting in response to say on frequency vote options
General Meetings by Country
COUNTRY
VOTABLE
MEETINGS
VOTED 
MEETINGS
%
Bermuda
2
2
100.00%
Brazil
28
28
100.00%
Cayman Islands
19
19
100.00%
Chile
1
1
100.00%
China
44
44
100.00%
Cyprus
1
1
100.00%
Denmark
7
6
85.71%
Faroe Islands
1
1
100.00%
Finland
1
1
100.00%
France
12
12
100.00%
Germany
13
13
100.00%
Hong Kong
2
2
100.00%
India
69
69
100.00%
Indonesia
1
1
100.00%
Ireland
14
9
64.29%
Israel
1
1
100.00%
Italy
2
2
100.00%
Japan
73
73
100.00%
Jersey 
(Channel IsL, UK)
3
3
100.00%
Exercise of Voting Rights 
BREAKDOWN OF VOTES
%
For
80.8%
Against
16.1%
Abstentions or Withholdings
2.4%
Other13
0.7%
In Line with Management
83.1%
Against Management
16.9%
In Line with Comgest Policy
97.5%
Against Comgest Policy
2.5%
For Shareholder Resolution
62.7%
Against Shareholder Resolution
37.3%
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The following reports which contain information on our voting statistics are made available to clients: 
	– Annual Responsible Investment Report: A 
description of our voting behaviour, including 
an explanation of our most significant votes; a 
description of how Comgest cast votes in the 
general meetings of companies in which it held 
shares on behalf of clients.
	– Quarterly Responsible Investment Reports: A 
summary of the voting activity related to Comgest’s 
portfolios. These reports are available upon request.
	– Quarterly Fund Factsheets: In certain regions, our 
pooled fund factsheets display quarterly statistics 
on our engagement and voting activity.
	– On-demand Voting Reports: For segregated 
mandates, Comgest can provide specific voting 
reports upon request.
	–
 Voting Dashboard: Summarises Comgest’s voting 
activity for each investee company. This dashboard 
is updated daily and voting results are visible with 
a 90-day lag.
SIGNIFICANT VOTES
Comgest provides a rationale for voting decisions that we consider significant, such as votes against management, 
votes on shareholder resolutions, votes withheld, votes that are not in line with our voting policy, votes that 
represent a significant shareholding, influence, freefloat, or votes connected to an escalation strategy. Below is an 
illustrative selection of significant votes during the year 2023.
Examples of Votes Against Management/Abstention 
LINDE: VOTE AGAINST MANAGEMENT (EGM, 18-JAN-23) 
	
−
Amend Articles of Association (Outcome: Pass – Dissent Level: 6.0%)
	
−
Approve Common Draft Terms of Merger (Outcome: Pass – Dissent Level: 6.0%)
	
−
Approve Scheme of Arrangement (Outcome: Pass – Dissent Level: 6.0%)
	§ Rationale: We decided to vote against the resolutions proposed by Linde on the Frankfurt de-listing, as we see 
many benefits of a Frankfurt listing, including a euro currency listing and trading hours aligned with European time 
zone(s).
KEYWORDS STUDIOS: VOTE TO ABSTAIN (AGM, 26-MAY-23)  
	
−
Re-Appoint BDO LLP as Auditors
	§ Rationale: We have expressed our reservations several times about keeping BDO as an auditor given its long 
tenure with Keywords and its controversial reputation. Keywords have sought to replace them but have decided to 
postpone the tender by another year given the difficulty they faced in finding an auditor willing to accept the job at a 
reasonable cost.
	§ Outcome: Pass (Dissent level: 0.7%)
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HERMÈS INTERNATIONAL: VOTE AGAINST MANAGEMENT (AGM, 20-APR-23) 
Despite the fact that we generally like family-owned companies, we note that they have some shortcomings around 
governance matters that should be addressed. In such instances, we express our dissent by voting, as in the case of the 
Hermès 2023 Annual General Meeting, where Comgest voted against nearly half of the resolutions (14 out of 29). As 
an example, we voted against the below items relating to its remuneration policy, re-election of a board member and 
approval of a special report on related-party transactions:
	
−
Approve Remuneration Policy of General Managers (Outcome: Pass – Dissent Level: 8.4%)
	
−
Approve Compensation of Axel Dumas, General Manager (Outcome: Pass – Dissent Level: 7.9%)
	
−
Approve Compensation of Emile Hermes SAS, General Manager (Outcome: Pass – Dissent Level: 7.9%)
	§ Rationale: The discretionary power to set executive remuneration lies in the hands of the General Partner (Emile 
Hermès SAS), which is the same legal entity as one of the General Managers and is controlled by the family of the 
other General Manager (Axel Dumas), leading to an important conflict of interest. The structure of the statutory 
remuneration seems biased as the methodology used to fix the base salary is inherently inflationist (indexed upward 
only on previous year results) and the variable remuneration is nearly uncapped.
HERMÈS INTERNATIONAL: VOTE AGAINST MANAGEMENT (AGM, 20-APR-23) 
	
−
Re-elect Renaud Mommeja as Supervisory Board Member
	§ Rationale: We voted against this resolution as the nominee is a non-independent member of the Audit Committee.
	§ Outcome: Pass (Dissent level: 4.9%)
	
−
Approve Auditors’ Special Report on Related-Party Transactions
	§ Rationale: The company did not provide sufficient information on the consulting agreement entered into with 
a public relations firm, Studio des Fleurs, and its transactions with the architectural firm, RDAI. It is therefore 
impossible to ascertain whether the continuation of this agreement is in the best interest of shareholders.
	§ Outcome: Pass (Dissent level: 7.2%)
DASSAULT SYSTÈMES: VOTE AGAINST MANAGEMENT (AGM, 24-MAY-23) 
	
−
Approve Remuneration Policy of Corporate Officers
	§ Rationale: We voted against the company’s remuneration policy for the following reasons: 1) the unusual process 
of the company’s capital association for the CEO (granting performance shares to the CEO each year as part of a 
gradual process to associate him with the company’s capital) and the LTIP grant to the Vice-CEO that could lead to 
significant payments; 2) the termination payments could result in rewarding failure; and 3) the LTIPs will vest fully 
in case of retirement, without any proratisation.
	§ Outcome: Pass (Dissent level: 17.8%)
	
−
Approve Compensation Report of Corporate Officers
	§ Rationale: We voted against the company’s remuneration report considering issues remain in terms of disclosure on 
the CEO’s remuneration report along with the recurring significant dissent at the last AGMs.
	§ Outcome: Pass (Dissent level: 17.7%)
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Votes Against Comgest’s Voting Policy
LOCALIZA RENT A CAR: VOTE AGAINST COMGEST’S VOTING POLICY (AGM, 25-APR-23)
	
−
Approve Remuneration of Company’s Management
	§ Rationale: The remuneration policy is clear and well defined in our view. It relies on corporate KPIs (ROIC14 is the 
ultimate KPI, as well as organisational morale and employee engagement) and individual KPIs related to the position 
held by each individual (e.g. volume, customer satisfaction, credit rating). We therefore voted in favour of the 
remuneration policy.
	§ Outcome: Pass (Dissent level: 9.3%)
INNER MONGOLIA YILI INDUSTRIAL GROUP: VOTE AGAINST COMGEST’S VOTING POLICY (EGM, 15-AUG-23)
	
−
Approve Stock Ownership Plan Management Rules
	§ Rationale: This is a renewal of the 2014 programme, which has supported sustainable interest alignment between 
the long-term interest of the company’s main talent pool (300-400 employees in total) and the sustainable growth 
of the business. The programme is essentially part of their remuneration policy, which replaces 100% cash bonus 
allocations with a combination of cash and stock reward (based on positive EBIT growth). A similar programme was 
issued in 2014 and, at that time, investors were worried about additional cost from the programme. Comgest has 
been an investor in Yili for the past 10 years, and we think the programme has not incurred additional cost as it 
was intended to replace a full cash base pay with cash + shares with no incremental cost. Since Yili also has stock 
options as a long-term incentive plan, this programme is used for regular compensation. Hence it doesn’t have KPIs 
as strict as an option programme does. Furthermore, we understand that senior management can receive no more 
than 30% of the allocation per year, so most of the allocation goes to middle level talent. We therefore believe that 
implementing the programme is more beneficial than not implementing it and we decided to vote in favour of this 
programme. 
	§ Outcome: Pass (Dissent level: 18.0%)
DEXERIALS: VOTE AGAINST COMGEST’S VOTING POLICY (AGM, 23-JUN-23)
	
−
Elect Director and Audit Committee Member Taniguchi, Masato
	§ Rationale: Japan’s “Board with an Audit Committee” board structure allows companies to have an insider as an Audit 
Committee member. Dexerials currently sees more value in having one full-time insider as an Audit Committee 
member versus all three Audit Committee members being part-time Independent Outside members because they 
believe that would ensure “effectiveness of audits”. Dexerials can benefit from having such an insider who has much 
more knowledge about Dexerials’ organisation and governance system, businesses, global networks, etc., which 
will help deepen discussions and make appropriate judgements without delaying the activities conducted by the 
Audit Committee. Furthermore, we confirmed with Dexerials that the current insider Audit Committee member, 
Mr. Kuwayama, who will be replaced by Mr. Taniguchi, has been able to provide insights to the Audit Committee. 
Some examples of his contribution are listed below:  a) advising to reinforce security risk management for one of 
the company’s sites, knowing that this would lead the company to sell the property to a third party and to remain 
as a tenant; b) handled highly sensitive workplace harassment issue thanks to knowledge and relationship with the 
relevant employees; and c) suggesting to conduct additional interviews to improve Audit Plans so that they can cover 
the points raised by the board.
	§ Outcome: Pass (Dissent level: N/A)
14 Return on invested capital
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Shareholder proposals
COSTCO WHOLESALE CORPORATION: VOTE FOR SHAREHOLDER PROPOSAL (AGM, 19-JAN-23)
	
−
Report on Risk Due to Restrictions on Reproductive Rights
	§ Rationale: Access to abortion is being challenged at the state and federal level in the US. Abortions are now banned 
in at least 13 US states and severely restricted in 5 additional states. About 46% of Costco’s workforce are women, 
and one-third of Costco’s US employees live in those states and will face challenges to get access to abortion and 
other reproductive care. Employers like Costco will bear a cost, as women who cannot access abortion are three 
times more likely to leave the workforce. Given that several states ban abortion coverage in all state-regulated 
private insurance plans, and the federal protection to a right to abortion that was initially recognised in Roe v. 
Wade15 has been overturned, the likelihood that the company’s female workforce will be impacted has increased. 
The additional information on the potential risks to Costco caused by such policies and how the company plans to 
address such risks would be beneficial to shareholders, we therefore supported this resolution.
	§ Outcome: Fail (Dissent level: 13.3%)
AMAZON: VOTE AGAINST SHAREHOLDER PROPOSAL (AGM, 25-MAY-22)
	
−
Report on Climate Risk in Retirement Plan Options
	§ Rationale: It seems unlikely to us that the company is facing a large risk of losing employees due to a lack of 
sustainable funds given the low pick-up of the one it offers. Plan participants have choices that are not limited to 
the default plan option, including ESG-themed investment options and thousands of investments (mutual funds, 
individual stocks and ETFs) through its self-directed brokerage option. We therefore voted against this resolution.
	§ Outcome: Fail (Dissent level: 14.7%)
15 https://supreme.justia.com/cases/federal/us/410/113/
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CLOSING REMARK
Stewardship has always been integral to Comgest, and we remain committed to engaging and reporting on our 
stewardship activities as part of our fiduciary responsibility to clients and in seeking better outcomes for society 
at large. Further reports, policies, affiliations and membership details can be found on the  
 ESG section of  
 comgest.com under  
 “Our Policies” and  
 “Our Commitments”. 
For detailed information on Comgest’s ESG Team, please visit 
 “Our ESG Story” on our website
For more information, visit:
AMSTERDAM
BOSTON
BRUSSELS
DUBLIN
DÜSSELDORF
HONG KONG
LONDON
MILAN
PARIS
SINGAPORE
SYDNEY
TOKYO
VIENNA
comgest.com
PICTURE CREDITS
© gettyimages 
Comgest employee images: © Comgest
Comgest is an independent, international asset management group, which since its creation in 
1985, has pursued a long-term “Quality Growth” and responsible investment style. Comgest serves 
investors around the world who share its ­long-term investment horizon.
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