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Q4 2024 Engagement case study: Ethylene Oxide
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Topic: Ethylene Oxide mitigation strategy.
Our objective: Limiting material negative social or environmental impacts.
Company objective: Steris to phase out the use of Ethylene Oxide (EtO) from its product portfolio.
Desired outcome:Â Successful development of alternative technology to safely and effectively mass sterilise heat sensitive medical devices. Removing the reliance on ethylene oxide entirely.
Background:Â Steris uses EtO for the mass sterilisation of medical devices sensitive to heat and moisture. Chronic exposure to EtO can lead to health impacts including damage to the central nervous system and brain and an increased risk of cancer. US Regulators are implementing measures to limit emissions by more than 90% to reduce health impacts1. This creates an operational and legal risk to companies like Steris and its competitors and creates the need to expand lower-emission sterilisation alternatives. For example, in 2024, Steris was named in an EtO litigation case on claims for personal injury in the local area of a sterilisation plant.
Activity:Â On news of the lawsuit, WHEB initially downgraded the fundsâ position in Steris. We then engaged with the companyâs Investor Relations to evaluate its risk mitigation strategy for EtO-related litigation.
Engagement outcome:
M4 - company provides evidence that the issue is being managed in line with the policy or strategy, demonstrating concerns have been addressed
Steris is ahead of the curve on EtO compliance and had anticipated the EPAâs April 2024 regulatory changes. While the company stands to gain from smaller competitors exiting the market, it is not increasing its EtO capacity and remains selective in choosing customers.
Steris is aiming to reduce its reliance on EtO in its product portfolio, however a disconnect persists between the EPAâs stricter emissions limits and the FDAâs sterilisation requirements. Despite this tension, effective sterilisation of medical devices is essential and currently, there are no viable alternatives to EtO currently in development.
A related lawsuit was resolved in Q1 2025. Meanwhile, the Trump administration is pursuing a delay or weakening of EPA enforcement, creating both potential upside and ongoing regulatory uncertainty.
We have since upgraded our position on Steris.
1 As of March 2025, the Trump adminstration is now considering a two-year complaince exemption as part of itâs deregulatory agenda https://www.medtechdive.com/news/epa-emissions-standards-eto-medical-device-sterilizers/742435/
Foresight Group LLP does not offer legal, tax, financial or investment advice and the information on this website should not be construed as such. We recommend investors seek advice from a regulated financial adviser. The opportunity described in this document may not be suitable for all investors. Any such investment decision should be made only on the basis of the Fund scheme documents and appropriate professional advice.
Foresight Group LLP acts as investment manager and is authorised and regulated by the Financial Conduct Authority with Firm Reference Number 198020 and has its registered office at The Shard, 32 London Bridge Street, London SE1 9SG.
OEICs
An investment in FP Sustainable Future Themes Fund, FP Foresight Global Real Infrastructure Fund, FP Sustainable Real Estate Securities Fund, FP UK Infrastructure Income Fund or FP WHEB Sustainability Impact Fund and Liontrust Diversified Real Assets Fund (together the âFundsâ) should be considered a long-term investment that may be higher risk. Portfolio holdings are subject to change without notice.
The Authorised Corporate Directors FundRock Partners Limited (registered office at Hamilton Centre, Rodney Way, Chelmsford, England, CM1 3BY) and Liontrust Investment Partners LLP (registered office 2 Savoy Court, London WC2R 0EZ), are authorised and regulated by the Financial Conduct Authority with Firm Reference Numbers 469278 and 518552 respectively. The Funds are incorporated in England and Wales.
ICAVs
An investment in the WHEB Sustainable Impact Fund and the WHEB Environmental Impact Fund (together the âFundsâ) should be considered a longer-term investment that may be higher risk. Portfolio holdings are subject to change without notice.
The Manager of the Funds is FundRock Management Company S.A., authorised and regulated by the Luxembourg regulator to act as UCITS management company and has its registered office at Airport Center Building, 5, Heienhaff, L-1736 Senningerberg, Luxembourg.
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