Ethical Investment Representations Review Subcommittee

The Ethical Investment Representations Review Subcommittee (EIRRS) is a subcommittee of Investment Committee. It was established with effect from 26 April 2021 when responsibility for monitoring socially responsible policies and practices was transferred from the former Socially Responsible Investment Review Committee (SRIRC) to the Investment Committee (see Gazette notice on 10 December 2020). The Subcommittee considers representations concerning ethical or socially responsible investment relating to the University's Investment Policy Statement and will make recommendations to the Investment Committee.

Membership as at TT 2022 will be as follows

Position Name Conditions of appointment Until
[1] Mr Huw van Steenis a Chair who shall be the member of Investment Committee with expertise in socially responsible investment appointed under Council Regulations 15 of 2002 Section 23.1(9), or another Chair with appropriate expertise appointed by Council; ex officio
[2] Pro-Vice-Chancellor (Research) the Pro-Vice-Chancellor (Research) or another Pro-Vice-Chancellor as shall be determined by Council from time to time; ex officio
[3] Professor Tom Douglas, Philosophy a member of the Committee for Review of Donations and Research Funding, appointed by Council; MT 2023
[4]

Professor H Bhaskaran, Department of Materials

a member of Congregation elected by Congregation from members of the faculties in the Divisions of Mathematical, Physical and Life Sciences and of Medical Sciences; MT 2023
[5] Dr Isabel Ruiz, Blavatnik School of Government a member of Congregation elected by Congregation from members of the faculties in the Divisions of Humanities and of Social Sciences; and MT 2023
[6] Oxford SU VP (Charities and Community)

one sabbatical trustee of Oxford University Student Union.

ex officio
Secretary: Head of Legal and Compliance, Oxford University Endowment Management Limited (Alex Wilson)

 

A representation may be made to the EIRRS by:

a. Council, the Investment Committee or any other committee reporting directly to Council;

b. 10 or more members of Congregation;

c. a majority resolution of the Council of the Oxford University Student Union.

Should you wish to discuss the mechanisms for making such a representation, please contact the EIRRS Secretary.

The University has chosen at various instances to place restrictions on sectors in which it will not hold investments on ethical grounds, nor invest in funds which invest primarily in the below listed categories of company:

Direct investment in companies which manufacture arms that are illegal under the Munitions (Prohibitions) Act 2010 or the Landmines Act 1998.

 

This issue of investments in arms manufacturing companies was originally raised by students and, at the request of Council, was considered at the inaugural meeting of the Socially Responsible Investment Review Committee (SRIRC) on 26 May 2009. This committee continued its deliberations at its meetings in Michaelmas Term 2009 and Hilary Term 2010. These deliberations resulted in a Report to Council dated February 2010 which can be viewed at C1032 (PDF, 54kb) (the Report).

At its meeting on 15 March 2010, Council considered the SRIRC Report. Council thanked the SRIRC for the careful thought it had applied and the effort it had put in. However, Council deferred a decision on the recommendation of the Report, agreeing that before it could take a decision on the recommendation of the SRIRC, it should be apprised fully of the implications of accepting the recommendation. Council therefore referred the report to the Investment Committee for comment, liaising with Oxford University Endowment Management Ltd (OUEM) as appropriate, focusing particularly on the financial ramifications and the practicalities of implementing the recommendation. In addition, agreeing that it would be desirable to have a consistency of approach as between its investment decisions, receipt of research funding and receipt of donations, Council also referred the report to the Research Committee for its views on the potential implications for the receipt of research funding, should the report's recommendation be accepted.

Council considered the matter further at its meeting on 21 June 2010. During this discussion it was emphasised that investment in such companies was actually very difficult to achieve as such a tiny minority of companies manufactured such weapons or munitions, and most were state-owned. Furthermore, it was very difficult to establish with certainty that an investment in such a company had been made because of the paucity of reliable information in this field. Noting the extent to which, as the charity trustees of the University for the purpose of charity law, Council could take policy decisions that might have a detrimental effect on the investment return of the charity, and coupling this with the robust advice of the Investment Committee that, for pooled vehicles, the implementation of such a policy would have considerable financial ramifications, Council was clear that in applying the policy, it would have to distinguish between direct investments and investments in pooled vehicles. It therefore agreed that it should pursue the implementation of the recommendation with respect to direct investments, subject to providing the necessary notification to external investors. Where there were pooled investment vehicles, it was agreed that it should implement a policy of monitoring investment in such companies by those vehicles. The difficulties of obtaining reliable information were acknowledged and OUEM was asked to use its best endeavours to obtain such information.

A related issue arose in discussions at later Council meetings. At its meeting on 14 November 2011, the question was asked whether the University’s existing policy prevented investment in companies whose activities in this respect were lawful according to the place of manufacture but would be illegal if manufacture took place in the UK. At the subsequent Council meeting on 5 December 2011, it was confirmed that, if the activity was illegal under the Cluster Munitions (Prohibitions) Act 2010 and the Landmines Act 1998, then the University’s policy would ban investment in that company, irrespective of where the company was based, or where the manufacture was taking place. So a company in the US that was manufacturing cluster bombs, for example, would be on the prohibited list, notwithstanding that the company, or its manufacturing facilities, were not based in the UK.

Direct investments in tobacco companies (as defined by UK Cancer Research[1]).

Investment Committee (IC) recommended that a restriction was formalised on direct holdings in tobacco companies[1], in line with the practices of the Committee to Review Donations and Research Services that the University should not accept funds from such companies. Council received this recommendation, together with a response submitted by the SRIRC endorsing the recommendation, at its meeting on 20 June 2016

Council approved the IC’s recommendation.


[1] As defined by Cancer Research UK. Tobacco companies are defined as a company, entity or organisation (or groups or combinations of the same) whose business other than for an insignificant part (i.e. less than 10% of its revenue), is the development, promotion, marketing or sale of tobacco in any country in the world, or is a subsidiary or a holding company of the same.  E-cigarette companies, fully or partially owned by the tobacco industry, are also considered tobacco companies under this definition.

Regulations


For the regulations of the Ethical Investment Representations Review Subcommittee, please click here:

Regulations

Contact us


Sarah Cowburn

Assistant Registrar (Governance)

Planning and Council Secretariat

sarah.cowburn@admin.ox.ac.uk