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How the new investment landscape we find ourselves facing is a more demanding global context for investor stewardship.
In the last quarter, geopolitical uncertainty has intensified. The populist push-back to sustainability agendas has gained momentum, while regulatory support for sustainable investing is being rolled back in both the US and EU.
Navigating these complexities is increasingly difficult for both companies and investors, reinforcing the importance of effective stewardship. But with this challenge comes an opportunity for investors to reassess what makes engagement truly effective.
Constructive engagement is harder where Environmental, Social and Governance (ESG) issues have become politicised. Just days into President Trumpâs second term, new Executive Orders targeted diversity, equity and inclusion (DEI) programmes1. Disney is already facing an investigation2, despite 99% of its shareholders supporting its approach3.
The SEC has also reversed its stance on mandatory climate risk disclosures4 and is weakening tools like shareholder proposals5 and collective initiatives6. As a result, material information may become harder to access, just as investor appetite is growing. Support has also been withdrawn from initiatives like the Climate Action 100+ and the Net Zero Asset Managerâs Initiative (NZAMI).
These barriers arenât new. The overturning of Roe v. Wade in 2022 similarly politicised a core workforce issue. WHEB responded by encouraging companies to protect employee wellbeingâa principle that remains as important as ever.
Meanwhile, global regulation continues to evolve. In the EU, the review of the Sustainable Finance Disclosure Regulation (SFDR) could raise the bar for investor disclosures. However, persistent gaps in corporate reporting remain a major challenge. Proposed reforms to the Corporate Sustainability Reporting Directive (CSRD) â which would exclude around 80% of companies and delay implementation â risk making matters worse, just as investors need more, not less, transparency from companies.
NZAMIâs recent decision to pause all activity, in response to signatories leaving7, may yet serve as a reminder that investor expectations of what engagement alone can achieve had, perhaps at times, become unrealistic.
However, challenging conditions can also create opportunity. In our view, NZAMIâs pause is more of a case of strategic recalibration, rather than outright retreat. Investor stewardship should take note and follow suit.
The landscape may be shifting, but investorsâ stewardship responsibilities endure. Global market forces demand that we recalibrate how we engage, what we prioritise, and how we define success. Stewardship must be sharper, more strategic, and grounded in long-term value.
WHEBâs use of engagement targets â all based on maximising long-term impact in businesses where that impact is embedded in the product â means weâre naturally incentivised to focus on whatâs material and relevant for a companyâs long-term success. And that, in turn, helps us navigate the politicisation of the sustainability agenda.
The WHEB strategy remains committed to stewardship that is ambitious yet pragmatic, proving that even under pressure, meaningful engagement is not only possible, but also essential.
Rachael Monteiro
Stewardship and Climate Manager
Foresight Capital Management
For further information, please get in touch with your regular Foresight contact or the client team on the details below:Â
1 https://www.whitehouse.gov/presidential-actions/2025/01/ending-illegal-discrimination-and-restoring-merit-based-opportunity/
2 https://www.fcc.gov/sites/default/files/Carr-Letter-to-Disney-DEI-03252027.pdf
3 An anti-DEI shareholder proposal that challenged Disneyâs parsiticaption in the Human Rightâs Campaigns Corporate Equality Index â a benchmarking tool assessing corportate policies, praxctices and benefits pertinent to lesbian, gay, bisexual, transgender and queer emploees â received only 1% support https://www.reuters.com/business/media-telecom/disney-investors-reject-proposal-withdraw-hrcs-diversity-index-2025-03-20/
4 https://www.sec.gov/newsroom/press-releases/2025-58
5 The SEC rescinded Staff Legal Bulletin 14L, which had strengthened shareholder rights by limiting companies' ability to exclude ESG proposals. It reinstated earlier guidance allowing companies to exclude proposalsâlike climate targetsâon the grounds of micromanagement. https://www.sec.gov/rules-regulations/staff-guidance/staff-legal-bulletins/shareholder-proposals-staff-legal-bulletin-no-14l-cf?
6 The SEC also updated guidance on Schedules 13D and 13G, potentially creating new hurdles for investors who cross the 5% ownership threshold and coordinate on ESG-related efforts, by increasing the risk of being deemed a âgroupâ subject to disclosure. https://www.sec.gov/about/divisions-offices/division-corporation-finance/exchange-act-sections-13d-13g-regulation-13d-g-beneficial-ownership-reporting-021125#:~:text=Feb.,New%20Question%20103.12
7 In an effort to halt more signatories leaving, the NZAMI has suspended activities to review and ensure the initiative remains fit for purpose https://www.netzeroassetmanagers.org/update-from-the-net-zero-asset-managers-initiative/
8 Smurfit Kappa, now Smurfit WestRock, has made good progress on this topic since we first began engaging it in 2023
9 WHEB redirected its focus and exited the position in J.B. Hunt in early 2024.
10 Full details of our public policy engagement are included in our Stewardship Report on p. 72 https://www.foresight.group/media/ebxhgp1v/20240730-wheb-asset-management-2023-stewardship-report.pdf
11 https://www.foresight.group/media/htglji4t/20241030-wheb-stewardship-white-paper.pdf
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.
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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.
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