The New York State Common Retirement Fund has ratcheted up pressure on companies in its listed equity portfolio to disclose their political spending in what it calls a “priority issue,” up there with climate, DEI and capital management.

“It is about governance,” says Liz Gordon, executive director of corporate governance at the $267.8 billion pension fund, speaking on the anniversary of last year’s siege on US Capitol Hill which prompted unprecedented scrutiny of corporate America’s response to the turmoil.

“As shareholders, this is our money and we are concerned if it is being spent in a way that is consistent with companies stated priorities and if there is a thoughtful process in place.”

Gordon argues it is in companies’ interest to participate in the political process and their right to do so, but transparency and governance around the process is also essential.

“We just want to make sure they are doing it in line with long-term shareholder value. The risk is real, no matter who you are giving to. It is about governance and the potential for misalignment.”

She dates NYS Common’s engagement on the issue from 2010 when corporate funding began to play an outsized role in campaign financing following a Supreme Court decision in Citizens United v FEC which removed any limits that corporations, or other groups, could spend on political elections. Since then, the pension fund has worked closely with the Centre for Political Accountability a non-profit organisation created in 2003 to bring transparency and accountability to corporate political spending.

Using its index on corporate disclosure, the pension fund targets the lowest scoring companies posing the greatest risk because of the absence of disclosure and oversight. The fund has filed 169 shareholder proposals since 2010 and successfully persuaded 49 companies to adopt and improve their disclosure.

Progress

Gordon is convinced things are starting to change – although laggards remain, she notes that companies are responding. Like clothing maker Hanesbrands, one of the companies targeted in the fund’s  latest batch of shareholder proposals, and where executives have already voiced their commitment to upping governance and disclosure around political spending, contributions to trade associations and other so-called dark money.

Moreover, she believes the debate has moved on as companies increasingly question if political contributions make sense for their corporations.

“Is this something they need to be doing? This is something companies increasingly need to explore themselves,” she says.

Although conversations depend on the culture of the company and its evolution, there is also clear best practice to follow and most are doing a good job around disclosure in “cordial and productive” conversations.

Still, she concludes efforts are confined to the fund’s public equity exposure. As an LP in private equity funds, it is much more difficult to engage directly with companies leaving NYS Common dependent on effective and robust engagement with its managers on the issue.

“They know what we prioritise and what we care about,” she concludes.

Many other asset allocators are also looking at political spending as a risk. Over the last three years, nine of the world’s largest asset allocators voted in favour of corporate resolutions for increased transparency and accountability on political spending, including APG, BCI, CalPERS, CalSTRS, CPPIB, NYC Retirement System, NBIM, OTTP and PGGM.

Scott Kalb, director of the Responsible Asset Allocator Initiative (RAAI) at think tank New America, says political spending is a risk that asset owners need to take seriously. He said screening out political risk required better asset owner education and investors using their proxy voting power to improve corporate disclosure on political spending.

“Asset owners should adopt policies on political spending as part of an ESG framework and put their asset managers on watch to the risk, notifying them that they won’t tolerate investment in companies spreading disinformation or engaged in violent activity.”

Moreover, he said these groups threaten the very system on which institutional investors rely like the rule of law.

“If you are a good steward of capital, investing in companies that have poor transparency regarding political funding contravenes good governance.”

 

 

 

 

 

 

 

In our latest episode of Double Take, we explore the sustainability of sustainable technology. Is the full life cycle of green tech truly sustainable when you consider all the mining, waste, and carbon emissions?

China has been the chief engine of emerging-market growth for the last two decades, and the pace of growth has stepped up under the leadership of President Xi Jinping in recent years. The speed of change has been so dramatic under the current government’s policies that investors are well justified in asking whether China has entered a new socioeconomic paradigm, or whether the current brand of socialism with Chinese characteristics is simply just a continuation of plain ‘old-fashioned’ socialism.

It is worth noting that China has pursued regulatory action at various times over the last 20 years against industries deemed as becoming too comfortable or affluent at the expense of the wider population. This policy assault, termed ‘common prosperity’, has most recently focused on telecommunications operators and banks, and is now turning its sights on the perceived excesses of the real-estate sector.

In many cases, the targeted industries have subsequently underperformed the wider Chinese market as they undergo enforced changes or restructuring, but recent history shows us that new industries have arisen to ultimately exceed them in capitalisation, and to drive the market higher.

Two faces of Chinese governance

We regard this reality as the ‘yin and the yang’ of the Chinese system of governance: moderate pruning of certain sectors that have grown too big or unwieldy allows for society and ultimately new investment opportunities to flourish. Western investors might be confused or even sceptical about the future prospects of China’s capital markets, but there is a wide perception that the constant cycle of renewal is what has allowed Chinese society to endure over many centuries, and we do not expect to see this dynamic change any time soon.

Under Xi, economic and social reforms, and a more widespread ‘opening up’ of the country which had characterised his most recent predecessors, have stalled somewhat. Some observers believe that problems emanating from parts of the heavily indebted real-estate sector, which have become a concern for many in China, have led to Xi stoking up nationalist sensibilities among the population to deflect any perceived criticism. Nevertheless, while the leader talks about Taiwan as a sovereign part of China and warns the US not to get involved, he has also won popular support at home by cracking down on corruption within the ruling party and beyond, and in the strides his administration is making to tackle air pollution in China’s cities.

Technology concerns

For multinationals still keen to engage with China, the technology sector is the area that throws up most concern. Both China and the US have begun a ‘decoupling’ process in which the US is trying to bring manufacturing capabilities back onshore, while maintaining its global leadership in technological intellectual property. China, which has become a leader in 5G technology, for example, is attempting to catch up with the US as a global technology leader and has aligned much of its high-level technology with both its internal and external geopolitical ambitions. The bilateral tensions between the US and China, not least in artificial intelligence, automation and semiconductors, have created an uncertain environment for companies looking to invest in China, especially for those in government procurement and high-level technology. Developed-world companies are also becoming more aware of Chinese companies – particularly those in the private sector – improving their competitiveness to go more global more quickly.

We are continuing to keep a close eye on the regulatory flurry of activity around China’s ‘common prosperity’ policy, to see how it manifests itself over time. Despite the continuing geopolitical tensions, many overseas investors continue to expand their investments within the country, as it is clear that, with its powerful economy and ever-expanding middle class, China will continue to be one of the strongest engines of global growth over the next decade. However, at the portfolio investment level, we believe it is crucial for investors to listen very carefully to the words of the Chinese leadership to discover which sectors will be favoured and which will be reined in over the coming months and years. By doing so, they can attempt to invest selectively with the flow, rather than against it.

Important information

This is a financial promotion. This article is for institutional investors only. Material in this article is for general information only. The opinions expressed in this article are those of Newton and should not be construed as investment advice or recommendations
for any purchase or sale of any specific security or commodity. Any reference to a specific country or sector should not be construed as a recommendation to buy or sell this country or sector. Please note that strategy holdings and positioning are subject to change without notice. Newton manages a variety of investment strategies. Whether and how ESG considerations are assessed or integrated into Newton’s strategies depends on the asset classes and/or the particular strategy involved, as well as the research and investment approach of each Newton firm. ESG may not be considered for each individual investment and, where ESG is considered, other attributes of an investment may outweigh ESG considerations when making investment decisions.
Issued by Newton Investment Management Limited, The Bank of New York Mellon Centre, 160 Queen Victoria Street, London, EC4V 4LA. Registered in England No. 01371973. Newton Investment Management Limited is authorized and regulated by the Financial Conduct Authority, 12 Endeavour Square, London, E20 1JN. ‘Newton Investment Management Group’ is used to collectively describe a group of affiliated companies that provide investment advisory services under the brand name ‘Newton’ or ‘Newton Investment Management’. Investment advisory services are provided in the United Kingdom by Newton Investment Management Ltd (NIM) and in the United States by Newton Investment Management North America LLC (NIMNA). Both firms are indirect subsidiaries of The Bank of New York Mellon Corporation (‘BNY Mellon’). Newton Investment Management Limited is registered with the SEC as an investment adviser under the Investment Advisers Act of 1940. Newton Investment Management Limited’s investment business is described in Form ADV, Part 1 and 2, which can be obtained from the SEC.gov website or obtained upon request.
Personnel of certain of our BNY Mellon affiliates may act as: (i) registered representatives of BNY Mellon Securities Corporation (in its capacity as a registered broker-dealer) to offer securities, (ii) officers of the Bank of New York Mellon (a New York chartered bank) to offer bank-maintained collective investment funds, and (iii) Associated Persons of BNY Mellon Securities Corporation (in its capacity as a registered investment adviser) to offer separately managed accounts managed by BNY Mellon Investment Management firms, including Newton.
Certain information contained herein is based on outside sources believed to be reliable, but their accuracy is not guaranteed. Unless you are notified to the contrary, the products and services mentioned are not insured by the FDIC (or by any governmental entity) and are not guaranteed by or obligations of The Bank of New York or any of its affiliates. The Bank of New York assumes no responsibility for the accuracy or completeness of the above data and disclaims all expressed or implied warranties in connection therewith. © 2021 The Bank of New York Company, Inc. All rights reserved.
In Canada, Newton Investment Management Limited is availing itself of the International Adviser Exemption (IAE) in the following Provinces: Alberta, British Columbia, Ontario and Quebec and the foreign commodity trading advisor exemption in Ontario. The IAE is in compliance with National Instrument 31-103, Registration Requirements, Exemptions and Ongoing Registrant Obligations.

Reshaping how we live

Digital transformation is reshaping all aspects of our lives, including the way we work, consume, and entertain ourselves. There have also been major shifts in the way companies operate, and every sector has had to adapt. In the retail industry, businesses must now consider not only the physical shelf, but also the digital shelf, as the shopping experience continues to digitise. In addition, there have been major changes in terms of how consumer brands market to their audience – they can no longer rely solely on television advertisements and billboards, but must now consider how they target customers through their mobile phones and social media.

As the digital transformation continues to permeate every aspect of our lives, there are technological developments that our investigative research team view as particularly interesting – including light detection and ranging (Lidar) and radio detection and ranging (Radar). To put it simply, this is the use of lasers and radio waves to detect other objects. Lidar and Radar are frequently used in cars and autonomous vehicles, and are now becoming increasingly smaller and more effective, meaning that numerous sensors can be used.

Has the tech ship sailed?

In recent years we have seen technology sector stocks that are dialled into the technology innovation theme perform very well, which raises the question: have investors missed the boat? The short answer, we believe, is no; we still see opportunities in the technology area. We are still relatively early in the digital transformation movement; in fact, many industries, such as education, energy, transportation and health care, are still in the earliest phases of deploying technology.

If we focus in on the UK market, although technology stocks account for only around 2% of the benchmark (FTSE All Share index) by value, the impact that digital transformation has on every sector means that investors do not have to miss out on the theme in this specific market. Despite not necessarily being household names, there are a number of small and mid-cap stocks that are leaders in their niche and have a significant runway for growth.

Risky business?

Although the digital transformation has the potential to significantly affect and improve our lives, we must acknowledge its potential drawbacks. As adoption of technology grows, we become increasingly connected to each other and to our surroundings. Our digital footprints will become much larger than they are today, which unfortunately presents increased scope for cyber attacks. Nevertheless, this also creates investment opportunities, for instance in the form of cyber-security vendors, which are able to protect users.

As technological innovation has progressed, so too have data privacy rules that seek to regulate who controls our data, such as the General Data Protection Regulation (GDPR) in Europe. These rules have changed the way that data is controlled: anyone who takes our data is now a custodian of it. This presents a number of risks to firms given the extent of the regulation, and there can be serious consequences if firms misuse this information. On the other hand, this has given rise to new companies that help businesses to ensure they are using data appropriately.

Technology and sustainability go hand in hand

Finally, we must recognise the implications that digitalisation has on sustainability. The consideration of environmental, social and governance (ESG) factors can be a useful tool to achieve a more holistic picture of companies. There are various ESG issues that are prevalent in the technology sector, in particular around social media, cyber security, and (as mentioned) data privacy. In addition, many of the large technology companies have voting structures that can be detrimental to shareholders. All of these risks must be monitored.

We look for businesses that will survive and thrive for not just the next few years, but for the next few decades, and the focus on sustainability has led to new business opportunities. A good example of this is a global leader in industrial software. The company essentially creates a digital representation of a physical asset for industrial businesses. This virtual model is able to study the asset and suggest potential improvements, thereby improving the efficiency of industrial processes. Not only does this have financial advantages, but also significant environmental benefits, including reduced waste and lower carbon emissions.

Important information

This is a financial promotion. This article is for institutional investors only. Material in this article is for general information only. The opinions expressed in this article are those of Newton and should not be construed as investment advice or recommendations for any purchase or sale of any specific security or commodity. Any reference to a specific country or sector should not be construed as a recommendation to buy or sell this country or sector. Please note that strategy holdings and positioning are subject to change without notice. Newton manages a variety of investment strategies. Whether and how ESG considerations are assessed or integrated into Newton’s strategies depends on the asset classes and/or the particular strategy involved, as well as the research and investment approach of each Newton firm. ESG may not be considered for each individual investment and, where ESG is considered, other attributes of an investment may outweigh ESG considerations when making investment decisions.
Issued by Newton Investment Management Limited, The Bank of New York Mellon Centre, 160 Queen Victoria Street, London, EC4V 4LA. Registered in England No. 01371973. Newton Investment Management Limited is authorized and regulated by the Financial Conduct Authority, 12 Endeavour Square, London, E20 1JN. ‘Newton Investment Management Group’ is used to collectively describe a group of affiliated companies that provide investment advisory services under the brand name ‘Newton’ or ‘Newton Investment Management’. Investment advisory services are provided in the United Kingdom by Newton Investment Management Ltd (NIM) and in the United States by Newton Investment Management North America LLC (NIMNA). Both firms are indirect subsidiaries of The Bank of New York Mellon Corporation (‘BNY Mellon’). Newton Investment Management Limited is registered with the SEC as an investment adviser under the Investment Advisers Act of 1940. Newton Investment Management Limited’s investment business is described in Form ADV, Part 1 and 2, which can be obtained from the SEC.gov website or obtained upon request.
Personnel of certain of our BNY Mellon affiliates may act as: (i) registered representatives of BNY Mellon Securities Corporation (in its capacity as a registered broker-dealer) to offer securities, (ii) officers of the Bank of New York Mellon (a New York chartered bank) to offer bank-maintained collective investment funds, and (iii) Associated Persons of BNY Mellon Securities Corporation (in its capacity as a registered investment adviser) to offer separately managed accounts managed by BNY Mellon Investment Management firms, including Newton.
Certain information contained herein is based on outside sources believed to be reliable, but their accuracy is not guaranteed. Unless you are notified to the contrary, the products and services mentioned are not insured by the FDIC (or by any governmental entity) and are not guaranteed by or obligations of The Bank of New York or any of its affiliates. The Bank of New York assumes no responsibility for the accuracy or completeness of the above data and disclaims all expressed or implied warranties in connection therewith. © 2021 The Bank of New York Company, Inc. All rights reserved.
In Canada, Newton Investment Management Limited is availing itself of the International Adviser Exemption (IAE) in the following Provinces: Alberta, British Columbia, Ontario and Quebec and the foreign commodity trading advisor exemption in Ontario. The IAE is in compliance with National Instrument 31-103, Registration Requirements, Exemptions and Ongoing Registrant Obligations.

As investors, we have the ability and the responsibility to speak to the boards and management of the companies that we invest in, to raise concerns, offer feedback, and also share best practice. This dialogue enables us to get a sense of how key risks, such as the energy transition, are being managed, and helps us gauge how companies are positioned to pursue opportunities. We also gain useful insights into corporate culture. Our experience to date suggests that how a company engages with its investors and how receptive it is to feedback can be indicative of how open it is to change and, as a result, how wholeheartedly it is embracing the energy transition.

Stewardship feeds the research process

Our engagement uncovers data that cannot be gleaned from an annual report or a presentation alone. This data feeds into the mosaic of information we use in our investment research process and helps us be better informed investors and therefore better allocators of capital.

Companies must demonstrate a genuine commitment to the energy transition

Currently, it is rare to see a company report which does not contain the phrase ‘net zero’, and ‘greenwashing’ is a concern. When we analyse companies, and assess their strategies, there are a number of specific things that we look for. We want to see a roadmap, with interim targets up to 2025, 2030 and 2040. We want to see a discussion of scenario analysis, specifically showing that companies have considered how they could adapt to a range of different eventualities and externalities. We want to see evidence that the oft-stated commitment to the energy transition is genuine. Crucially, through our persistent engagement, we want to see how well the tone from the top is supported by action at the operational level.

One thing we find really useful in helping us understand a company’s approach is disclosure in line with the TCFD (Task Force on Climate-related Financial Disclosures) recommendations. This reporting framework provides a good structure for this level of detail. It should be emphasised that this assessment is undertaken in partnership with our investment analysts. These considerations are part of the fundamentals – capital expenditure is costs, for example, and changing product lines are changing revenue streams. Our collective viewpoints contribute to a better determination of the credibility of a company’s strategy.

The social implications of the energy transition

We see the social and environmental implications of the energy transition as intrinsically linked to the sustainability of companies’ business models. Human-capital management has been an important topic for Newton* for some time. Over the years, we have engaged with companies across the energy and utilities sectors in particular, in order to research how they are managing the transition for their employees. We ask companies to explain what they think the future model of work will be and how they are reskilling, or upskilling, their employees for the future they anticipate. Arguably, this area has been overlooked by many investors for a long time, with the result that there is a dearth of useful information and data investors can use to assess how companies are managing this risk, so peer-group analysis is challenging.

We look for companies to provide detailed disclosures and improved KPIs (key performance indicators), including what kind of reskilling and training is available to employees and what take-up rates have been across the business. We also look for longer-term planning measures which demonstrate considerations from an employee perspective, such as a thoughtful approach to a shift in geographic location based on future product offerings.

* Newton Investment Management Ltd

Important information

This is a financial promotion. This article is for institutional investors only. Material in this article is for general information only. The opinions expressed in this article are those of Newton and should not be construed as investment advice or recommendations for any purchase or sale of any specific security or commodity. Any reference to a specific country or sector should not be construed as a recommendation to buy or sell this country or sector. Please note that strategy holdings and positioning are subject to change without notice. Newton manages a variety of investment strategies. Whether and how ESG considerations are assessed or integrated into Newton’s strategies depends on the asset classes and/or the particular strategy involved, as well as the research and investment approach of each Newton firm. ESG may not be considered for each individual investment and, where ESG is considered, other attributes of an investment may outweigh ESG considerations when making investment decisions.
Issued by Newton Investment Management Limited, The Bank of New York Mellon Centre, 160 Queen Victoria Street, London, EC4V 4LA. Registered in England No. 01371973. Newton Investment Management Limited is authorized and regulated by the Financial Conduct Authority, 12 Endeavour Square, London, E20 1JN. ‘Newton Investment Management Group’ is used to collectively describe a group of affiliated companies that provide investment advisory services under the brand name ‘Newton’ or ‘Newton Investment Management’. Investment advisory services are provided in the United Kingdom by Newton Investment Management Ltd (NIM) and in the United States by Newton Investment Management North America LLC (NIMNA). Both firms are indirect subsidiaries of The Bank of New York Mellon Corporation (‘BNY Mellon’). Newton Investment Management Limited is registered with the SEC as an investment adviser under the Investment Advisers Act of 1940. Newton Investment Management Limited’s investment business is described in Form ADV, Part 1 and 2, which can be obtained from the SEC.gov website or obtained upon request.
Personnel of certain of our BNY Mellon affiliates may act as: (i) registered representatives of BNY Mellon Securities Corporation (in its capacity as a registered broker-dealer) to offer securities, (ii) officers of the Bank of New York Mellon (a New York chartered bank) to offer bank-maintained collective investment funds, and (iii) Associated Persons of BNY Mellon Securities Corporation (in its capacity as a registered investment adviser) to offer separately managed accounts managed by BNY Mellon Investment Management firms, including Newton.
Certain information contained herein is based on outside sources believed to be reliable, but their accuracy is not guaranteed. Unless you are notified to the contrary, the products and services mentioned are not insured by the FDIC (or by any governmental entity) and are not guaranteed by or obligations of The Bank of New York or any of its affiliates. The Bank of New York assumes no responsibility for the accuracy or completeness of the above data and disclaims all expressed or implied warranties in connection therewith. © 2021 The Bank of New York Company, Inc. All rights reserved.
In Canada, Newton Investment Management Limited is availing itself of the International Adviser Exemption (IAE) in the following Provinces: Alberta, British Columbia, Ontario and Quebec and the foreign commodity trading advisor exemption in Ontario. The IAE is in compliance with National Instrument 31-103, Registration Requirements, Exemptions and Ongoing Registrant Obligations.

For a decade now, the behaviour of investors appears to have been predicated on the belief that a sustained acceleration in future inflation is unlikely. But if we are now entering an environment in which expectations of inflation begin to rise, the implications for investors are likely to be game-changing. A portfolio that is appropriate for an inflationary world is likely to be vastly different to one which has excelled in the last 40 years of disinflation.

Protecting a bond portfolio

Rising real yields and inflationary pressures are a key concern for bond investors, and conditions are likely to remain challenging for many developed-market government bonds in particular over the coming months. However, these assets may regain a role in portfolio construction as more elevated yield levels create attractive entry points.

There are a number of ways in which investors can seek to protect their bond portfolios in a more inflationary environment. Holding shorter-duration bonds helps to reduce the sensitivity of bond portfolios to rising yields. Other tools include inflation-linked bonds, such as US Treasury Inflation-Protected Securities (TIPS), and floating-rate notes where coupon payments rise with central-bank interest rates. Straightforward derivative strategies can help to protect against heightened rate volatility. Analysing the shape of any changes in the yield curve also provides opportunities to generate returns.

High-yield corporate bonds may also offer attractive characteristics. These bonds tend to be relatively short in duration and have a credit spread, providing a cushion against rising yields. Furthermore, while the economy is in a growth phase, companies are likely to be more profitable, meaning that they can better service their debt, resulting in lower default rates and potentially a tightening of credit spreads.

Finding equity opportunities

In equities, some of the more cyclical areas that have been out of favour in recent years may be set to outperform. Many ‘growth’ businesses, the relative winners of the low-growth, post financial-crisis world, have been trading at high valuation multiples, while those more cyclical areas of the market that traditionally benefit from higher inflation and higher interest rates now appear much cheaper relative to history.

Where can these stocks be found?

We see opportunities within parts of the financial sector; some of the large US banks, for example, have recently grown their dividend payments by 40%, as well as undertaking significant share buybacks. Together with the potential for multiple expansion, this has the potential to deliver a very attractive total return. Elsewhere, for many companies in the energy area, markets appear to be discounting a swift move to cleaner forms of power and the rollout of electric vehicles. Nevertheless, we believe there will be a need for transition fuels for some time, and see opportunities in certain businesses where we are observing a real shift in how management teams are allocating capital.

A different multi-asset toolkit

From a multi-asset perspective, a more inflationary environment over the medium term is likely to have profound implications in terms of how different asset classes behave and are correlated, and this will have repercussions for the way investment strategies are constructed. With bonds not offering the diversification that they have done in the past, it will be important to ensure that portfolios still have liquidity, tail-risk protection and alternative capital-preservation tools. Convex long option and volatility strategies, such as risk-premia strategies with an asymmetric return profile, could help and, if structured effectively, the cost of hedging may not be prohibitive.

Analysis of inflationary episodes and the performance of different asset classes over the last 50 years shows that bonds generated negative real returns during most inflationary episodes, and equities as an asset class also frequently underperformed. Gold performed strongly during the inflationary periods of the 1970s, but appears to have been much less related to inflation since then. On the other hand, commodities that constitute the raw materials of production processes have had a much more reliable relationship to inflation, with a strong positive correlation between broad commodity prices and inflation. Renewable-energy infrastructure assets, whose revenues are often linked to the rate of inflation, could also be well placed to outperform.

Ultimately, we believe an active and flexible approach will be critical in seeking to take advantage of a changing opportunity set, underpinned by a sound risk-management framework.

Important information

This is a financial promotion. This article is for institutional investors only. Material in this article is for general information only. The opinions expressed in this article are those of Newton and should not be construed as investment advice or recommendations for any purchase or sale of any specific security or commodity. Any reference to a specific country or sector should not be construed as a recommendation to buy or sell this country or sector. Please note that strategy holdings and positioning are subject to change without notice. Newton manages a variety of investment strategies. Whether and how ESG considerations are assessed or integrated into Newton’s strategies depends on the asset classes and/or the particular strategy involved, as well as the research and investment approach of each Newton firm. ESG may not be considered for each individual investment and, where ESG is considered, other attributes of an investment may outweigh ESG considerations when making investment decisions.
Issued by Newton Investment Management Limited, The Bank of New York Mellon Centre, 160 Queen Victoria Street, London, EC4V 4LA. Registered in England No. 01371973. Newton Investment Management Limited is authorized and regulated by the Financial Conduct Authority, 12 Endeavour Square, London, E20 1JN. ‘Newton Investment Management Group’ is used to collectively describe a group of affiliated companies that provide investment advisory services under the brand name ‘Newton’ or ‘Newton Investment Management’. Investment advisory services are provided in the United Kingdom by Newton Investment Management Ltd (NIM) and in the United States by Newton Investment Management North America LLC (NIMNA). Both firms are indirect subsidiaries of The Bank of New York Mellon Corporation (‘BNY Mellon’). Newton Investment Management Limited is registered with the SEC as an investment adviser under the Investment Advisers Act of 1940. Newton Investment Management Limited’s investment business is described in Form ADV, Part 1 and 2, which can be obtained from the SEC.gov website or obtained upon request.
Personnel of certain of our BNY Mellon affiliates may act as: (i) registered representatives of BNY Mellon Securities Corporation (in its capacity as a registered broker-dealer) to offer securities, (ii) officers of the Bank of New York Mellon (a New York chartered bank) to offer bank-maintained collective investment funds, and (iii) Associated Persons of BNY Mellon Securities Corporation (in its capacity as a registered investment adviser) to offer separately managed accounts managed by BNY Mellon Investment Management firms, including Newton.
Certain information contained herein is based on outside sources believed to be reliable, but their accuracy is not guaranteed. Unless you are notified to the contrary, the products and services mentioned are not insured by the FDIC (or by any governmental entity) and are not guaranteed by or obligations of The Bank of New York or any of its affiliates. The Bank of New York assumes no responsibility for the accuracy or completeness of the above data and disclaims all expressed or implied warranties in connection therewith. © 2021 The Bank of New York Company, Inc. All rights reserved.
In Canada, Newton Investment Management Limited is availing itself of the International Adviser Exemption (IAE) in the following Provinces: Alberta, British Columbia, Ontario and Quebec and the foreign commodity trading advisor exemption in Ontario. The IAE is in compliance with National Instrument 31-103, Registration Requirements, Exemptions and Ongoing Registrant Obligations.