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For use by professional clients and/or equivalent investor types in your jurisdiction (not to be used with or passed on to retail clients).
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Insights

Our approach to system-level stewardship

Kirk Moore
Kirk Moore
Global Head of Research
Claudia Wearmouth
Claudia Wearmouth
Global Head, Responsible Investment

As a research-intense active manager, we engage with companies to deepen our understanding of their current business performance and future fundamental growth drivers, including material sustainability and governance issues.

Through sharing our views as an informed investor, we seek to encourage companies to undertake robust management of these issues, with the ultimate objective of underpinning long-term resilient investment returns.

But companies do not operate in isolation from the environment they operate in. Social and environmental drivers – people and planet – are shaped by forces often beyond a company’s direct control, including regulation, geopolitics and technology. The performance of our portfolios is also dependent on the macroeconomic environment in which we invest, which will be fundamentally impacted by sustainability challenges such as climate change.

Understanding this interconnectedness is core to our research philosophy and approach, and also influences how we see the role of stewardship.

Planet: The source of natural resources and recipient of industrial impacts, requiring responsible stewardship and sustainable management.

People: Society’s stakeholders who both consume goods/services and earn income through employment, forming the foundation of economic activity.

Capital markets: The dynamic systems where capital flows connect investors, companies, and opportunities, reflecting both risks and potential.

Regulators: Authorities who shape market behaviour and corporate accountability through policy frameworks that balance societal, environmental, and economic interests.

Corporations: Organisations that fulfil societal needs while managing environmental impacts, creating value through the responsible use of resources.

Columbia Threadneedle: A strategic partner at the intersection of these elements, helping clients navigate the complex relationships between people, planet, markets and corporate performance.

What is system-level stewardship?

Stewardship at a system level means looking beyond one-on-one dialogue with issuers, and incorporating engagement with wider stakeholders including policymakers, regulators, standard-setters and industry networks. It recognises that company performance is shaped not only by their own actions, but by the context they operate within.

Whilst public policy engagement has long been part of responsible investment approaches, the focus on understanding and engaging on system-level risk has intensified over the recent past, driven by the accelerating pace of global environmental and geopolitical change, and by increasing awareness of the limits of company-level engagement1.

Why conduct system-level stewardship?

We see system-level stewardship as something which is not a separate activity but which is embedded in our investment process, and that supports our delivery of investment and client goals.

We identify three distinct areas of system-level dialogue that provide value, as set out below.

Enhancing our research and stewardship

  • Long-term company performance is shaped by factors beyond their immediate control, such as the policy environment
  • Engaging policymakers and other stakeholders helps us understand the risk and opportunity landscape, supporting our investment analysis
  • We may feed back views on effective policy design, based on insights from company engagement and analysis

Building strong market standards

  • Strong market standards, such as listing rules and corporate governance codes, are critical in creating stable conditions for investment
  • We can play a constructive role in shaping standards by sharing our perspective as an active long-term investor

Supporting sustainable products and asset classes

  • Credible best-practice standards and regulations support the integrity of sustainability products and asset classes
  • As an investor with a deep history in this area, we can offer our knowhow in creating and evolving these standards
  • For labelled bonds we also engage directly with sovereign and corporate issuers, to set out our expectations

Enhancing our research and stewardship

Speaking with policymakers and regulators helps to deepen our understanding of the policy landscape, and to assess the quality of companies’ strategic response to material sustainability business drivers.

Our dialogue with multiple companies across a sector also means that we build a picture of common obstacles to achieving sustainability goals, which may include the policy landscape. As investors, we can then feed back our views on effective policy design to decision-makers in governments or regulatory bodies, which can help create a more supportive policy environment for companies to operate in, supporting stable long-term performance. 

Below gives an example, where our engagement with European banks led us to speak with policymakers on physical risk management.

Case study: Engagement with UK mortgage lenders leads us to engage with policymakers on the future of flood protection

Context

  • Engagement with European banks and building societies revealed well-developed energy transition policies, but less robust physical risk management
  • This represents potentially mispriced risk and future credit loss exposure

Action

  • Engaged one-on-one with Defra policymakers on the future of UK floods policy and the pooled insurance scheme, Flood Re

  • Joined a Climate Financial Risk Forum meeting bringing together investors, insurers, banks and policymakers on floods policy

  • Shared our view that long-term flood risk may be underestimated by UK financial institutions

Outcomes

  • We continue to seek opportunities to engage UK policymakers and regulators, focusing on proposed new Flood Performance Certificates, which we believe could improve understanding of true levels of risk

Building strong market standards

As investors, we rely on regulators to set basic minimum standards in areas like corporate governance and disclosure. These standards are critical in order to create orderly markets, where investors can trust the information they are given.

We can feed in our views on what type of standards support us as long-term active investors, particularly where regulators are considering changes and are keen to seek investor input through consultation processes.

Below gives an example of how we fed into work to enhance corporate governance standards in Hong Kong.

Case study: Supporting reforms to Hong Kong’s Corporate Governance Standards

Context

  • Hong Kong listed companies have historically faced structural governance weaknesses, including entrenched directors, overboarding, and weaker independence standards compared with neighbouring markets

  • Hong Kong’s regulator proposed enhancements to the Listing Rules and Corporate Governance Code to address these issues

Action

  • Responded to the consultation, providing investor perspectives based on our engagement and voting experience

  • Our submission broadly supported HKEX’s proposals to tighten independence expectations, cap INED tenure at nine years and limit overboarding to six listed-company directorships

Outcomes

  • HKEX adopted the key governance reforms we supported, including caps on INED overboarding and tenure, stronger board evaluation and skills-matrix disclosures, enhanced diversity, risk-control and dividend-policy reporting, and mandatory director training

  • The main rules, which will impact the entire market, took effect from July 2025

Supporting sustainable products and asset classes

With several decades of experience in running sustainability strategies, we now have over $50bn2 in assets under management with specific ESG and sustainability objectives, designed to meet clients’ goals.

We are an active in supporting the kind of robust market standards for these type of products and asset classes which are essential to their credibility. Key areas for us here include standards on transition finance, as well as on labelled bonds such as green and transition bonds, where we may engage directly with sovereign issuers to set out our expectations.

Below gives an example of engagement with the UK and Japanese governments on labelled bond issuance, and how that relates to wider dialogue on each country’s climate strategy.

Case study: Engagement with the UK and Japan to encourage labelled bond best practice and discuss climate policy

Context

  • We engage with sovereign issuers to discuss our views on best practice in labelled bond issuance
  • Best practice includes linking use of proceeds to key sustainability topics facing the country
  • In this way, engagement on green or transition bonds opens the door to a discussion about broader climate policies

Action

  • In 2025 and 2026 we engaged with the Japanese and UK governments

  • We discussed how Japan views its transition bonds as signalling support for new technologies

  • In the UK, we compared green gilts’ use of proceeds to areas identified by the Climate Change Committee as needing progress

  • In both cases, we also discussed what we would find useful in impact reporting

Outcomes

  • In a subsequent meeting with Japan, we were pleased to see improvements in impact reporting, and shared further ideas
  • We will continue to monitor how these governments and others tie labelled bonds to their climate policies, and the quality and usefulness of impact reporting

In summary

System-level stewardship is part of how we seek to understand the wider factors that can affect companies, markets and investments, and to develop and build markets. By engaging across different parts of the system, we can deepen our understanding of systemic risks and, where possible, contribute to how these are managed.

Read the full viewpoint

Discover how system-level stewardship helps investors address systemic risks through engagement with policymakers, regulators and market standards.

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1 See, for instance, “Systemic Risks: A framework for portfolio resilience” (UKSIF, May 2025) and “Realigning Stewardship: Delivering sustainable value through stewardship” (Investment Association, February 2026)
2 As at 30 June 2026

Important information

For use by professional clients and/or equivalent investor types in your jurisdiction (not to be used with or passed on to retail clients). For marketing purposes.

This document is intended for informational purposes only and should not be considered representative of any particular investment. This should not be considered an offer or solicitation to buy or sell any securities or other financial instruments, or to provide investment advice or services. Investing involves risk including the risk of loss of principal. Your capital is at risk. Market risk may affect a single issuer, sector of the economy, industry or the market as a whole. The value of investments is not guaranteed, and therefore an investor may not get back the amount invested. International investing involves certain risks and volatility due to potential political, economic or currency fluctuations and different financial and accounting standards. The securities included herein are for illustrative purposes only, subject to change and should not be construed as a recommendation to buy or sell. Securities discussed may or may not prove profitable. The views expressed are as of the date given, may change as market or other conditions change and may differ from views expressed by other Columbia Threadneedle Investments (Columbia Threadneedle) associates or affiliates. Actual investments or investment decisions made by Columbia Threadneedle and its affiliates, whether for its own account or on behalf of clients, may not necessarily reflect the views expressed. This information is not intended to provide investment advice and does not take into consideration individual investor circumstances. Investment decisions should always be made based on an investor’s specific financial needs, objectives, goals, time horizon and risk tolerance. Asset classes described may not be suitable for all investors. Past performance does not guarantee future results, and no forecast should be considered a guarantee either. Information and opinions provided by third parties have been obtained from sources believed to be reliable, but accuracy and completeness cannot be guaranteed. This document and its contents have not been reviewed by any regulatory authority.

In Australia: Issued by Threadneedle Investments Singapore (Pte.) Limited [“TIS”], ARBN 600 027 414. TIS is exempt from the requirement to hold an Australian financial services licence under the Corporations Act 2001 (Cth) and relies on Class Order 03/1102 in respect of the financial services it provides to wholesale clients in Australia. This document should only be distributed in Australia to “wholesale clients” as defined in Section 761G of the Corporations Act. TIS is regulated in Singapore (Registration number: 201101559W) by the Monetary Authority of Singapore under the Securities and Futures Act (Chapter 289), which differ from Australian laws.

In Singapore: Issued by Threadneedle Investments Singapore (Pte.) Limited, 3 Killiney Road, #07-07, Winsland House 1, Singapore 239519, which is regulated in Singapore by the Monetary Authority of Singapore under the Securities and Futures Act (Chapter 289). Registration number: 201101559W. This advertisement has not been reviewed by the Monetary Authority of Singapore.

In Hong Kong: Issued by Threadneedle Portfolio Services Hong Kong Limited 天利投資管理香港有限公司. Unit 3004, Two Exchange Square, 8 Connaught Place, Hong Kong, which is licensed by the Securities and Futures Commission (“SFC”) to conduct Type 1 regulated activities (CE:AQA779). Registered in Hong Kong under the Companies Ordinance (Chapter 622), No. 1173058.

In Japan: Issued by Columbia Threadneedle Investments Japan Co., Ltd. Financial Instruments Business Operator, The Director-General of Kanto Local Finance Bureau (FIBO) No.3281, and a member of Investment Management Association of Japan and Type II Financial Instruments Firms Association.

In the UK: Issued by Threadneedle Asset Management Limited, No. 573204 and/or Columbia Threadneedle Management Limited, No. 517895, both registered in England and Wales and authorised and regulated in the UK by the Financial Conduct Authority.

In the EEA: Issued by Threadneedle Management Luxembourg S.A., registered with the Registre de Commerce et des Sociétés (Luxembourg), No. B 110242 and/or Columbia Threadneedle Netherlands B.V., regulated by the Dutch Authority for the Financial Markets (AFM), registered No. 08068841.

In Switzerland: Issued by Threadneedle Portfolio Services AG, Registered address: Claridenstrasse 41, 8002 Zurich, Switzerland.

In the Middle East: This document is distributed by Columbia Threadneedle Investments (ME) Limited, which is regulated by the Dubai Financial Services Authority (DFSA). For Distributors: This document is intended to provide distributors with information about Group products and services and is not for further distribution. For Institutional Clients: The information in this document is not intended as financial advice and is only intended for persons with appropriate investment knowledge and who meet the regulatory criteria to be classified as a Professional Client or Market Counterparties and no other Person should act upon it.

This document may be made available to you by an affiliated company which is part of the Columbia Threadneedle Investments group of companies: Columbia Threadneedle Management Limited in the UK; Columbia Threadneedle Netherlands B.V., regulated by the Dutch Authority for the Financial Markets (AFM), registered No. 08068841.

Columbia Threadneedle Investments is the global brand name of the Columbia and Threadneedle group of companies. © 2026 Columbia Threadneedle. All rights reserved.

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Important information

For use by professional clients and/or equivalent investor types in your jurisdiction (not to be used with or passed on to retail clients). For marketing purposes.

This document is intended for informational purposes only and should not be considered representative of any particular investment. This should not be considered an offer or solicitation to buy or sell any securities or other financial instruments, or to provide investment advice or services. Investing involves risk including the risk of loss of principal. Your capital is at risk. Market risk may affect a single issuer, sector of the economy, industry or the market as a whole. The value of investments is not guaranteed, and therefore an investor may not get back the amount invested. International investing involves certain risks and volatility due to potential political, economic or currency fluctuations and different financial and accounting standards. The securities included herein are for illustrative purposes only, subject to change and should not be construed as a recommendation to buy or sell. Securities discussed may or may not prove profitable. The views expressed are as of the date given, may change as market or other conditions change and may differ from views expressed by other Columbia Threadneedle Investments (Columbia Threadneedle) associates or affiliates. Actual investments or investment decisions made by Columbia Threadneedle and its affiliates, whether for its own account or on behalf of clients, may not necessarily reflect the views expressed. This information is not intended to provide investment advice and does not take into consideration individual investor circumstances. Investment decisions should always be made based on an investor’s specific financial needs, objectives, goals, time horizon and risk tolerance. Asset classes described may not be suitable for all investors. Past performance does not guarantee future results, and no forecast should be considered a guarantee either. Information and opinions provided by third parties have been obtained from sources believed to be reliable, but accuracy and completeness cannot be guaranteed. This document and its contents have not been reviewed by any regulatory authority.

In Australia: Issued by Threadneedle Investments Singapore (Pte.) Limited [“TIS”], ARBN 600 027 414. TIS is exempt from the requirement to hold an Australian financial services licence under the Corporations Act 2001 (Cth) and relies on Class Order 03/1102 in respect of the financial services it provides to wholesale clients in Australia. This document should only be distributed in Australia to “wholesale clients” as defined in Section 761G of the Corporations Act. TIS is regulated in Singapore (Registration number: 201101559W) by the Monetary Authority of Singapore under the Securities and Futures Act (Chapter 289), which differ from Australian laws.

In Singapore: Issued by Threadneedle Investments Singapore (Pte.) Limited, 3 Killiney Road, #07-07, Winsland House 1, Singapore 239519, which is regulated in Singapore by the Monetary Authority of Singapore under the Securities and Futures Act (Chapter 289). Registration number: 201101559W. This advertisement has not been reviewed by the Monetary Authority of Singapore.

In Hong Kong: Issued by Threadneedle Portfolio Services Hong Kong Limited 天利投資管理香港有限公司. Unit 3004, Two Exchange Square, 8 Connaught Place, Hong Kong, which is licensed by the Securities and Futures Commission (“SFC”) to conduct Type 1 regulated activities (CE:AQA779). Registered in Hong Kong under the Companies Ordinance (Chapter 622), No. 1173058.

In Japan: Issued by Columbia Threadneedle Investments Japan Co., Ltd. Financial Instruments Business Operator, The Director-General of Kanto Local Finance Bureau (FIBO) No.3281, and a member of Investment Management Association of Japan and Type II Financial Instruments Firms Association.

In the UK: Issued by Threadneedle Asset Management Limited, No. 573204 and/or Columbia Threadneedle Management Limited, No. 517895, both registered in England and Wales and authorised and regulated in the UK by the Financial Conduct Authority.

In the EEA: Issued by Threadneedle Management Luxembourg S.A., registered with the Registre de Commerce et des Sociétés (Luxembourg), No. B 110242 and/or Columbia Threadneedle Netherlands B.V., regulated by the Dutch Authority for the Financial Markets (AFM), registered No. 08068841.

In Switzerland: Issued by Threadneedle Portfolio Services AG, Registered address: Claridenstrasse 41, 8002 Zurich, Switzerland.

In the Middle East: This document is distributed by Columbia Threadneedle Investments (ME) Limited, which is regulated by the Dubai Financial Services Authority (DFSA). For Distributors: This document is intended to provide distributors with information about Group products and services and is not for further distribution. For Institutional Clients: The information in this document is not intended as financial advice and is only intended for persons with appropriate investment knowledge and who meet the regulatory criteria to be classified as a Professional Client or Market Counterparties and no other Person should act upon it.

This document may be made available to you by an affiliated company which is part of the Columbia Threadneedle Investments group of companies: Columbia Threadneedle Management Limited in the UK; Columbia Threadneedle Netherlands B.V., regulated by the Dutch Authority for the Financial Markets (AFM), registered No. 08068841.

Columbia Threadneedle Investments is the global brand name of the Columbia and Threadneedle group of companies. © 2026 Columbia Threadneedle. All rights reserved.

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