Environmental, social and governance (ESG) factors have “taken a back seat” at German occupational pension funds amid the prevailing low-interest-rate environment, the country’s industry association has said.

Responding to a European Commission consultation on long-term and sustainable investment, aba said “the security of the investment that achieves the necessary return is more important for investors than ESG factors” and that some investors did not therefore include ESG factors in their investment decisions.

“Their primary responsibility of strategic investment decisions is to maximise the returns to fulfil the pension commitments for the members,” added the association, which represents German occupational pension funds.

“Other priorities are a reasonable mix and diversifications of the assets, while maintaining an adequate level of liquidity. Investors often fear the higher costs of ESG research.”

The role ESG factors play in investment decisions will also depend on the asset class, said aba.

A recurring point in its submission was the implications for investment along ESG lines of the structure of workplace pensions in Germany.

This is one where the IORPs (institutions for occupational retirement provision) “are always linked to a sponsoring employer and sometimes in addition to social partners of a special industry”.

The aba said: “The sponsoring employer might already have an ESG strategy in place that will then have an impact on the investment strategy of the IORP.

“In addition, the field in which the sponsoring undertaking operates will influence ESG decisions – for example, the IORP of a company running a nuclear plant will not put nuclear energy on a negative list.”

According to the aba, the main reasons why institutional investors and asset managers take ESG factors into account in their investment decisions are risk management, alignment of investment policies with the beneficiaries’ long-term interests, pressure from the investors’ clients and reputation.

The latter two could lead to greenwashing, said the association.

The answers were chosen from a multiple-choice list, although ‘reputation’ was a free input from aba.

Reliability, usefulness, availability and cost of information/data is an issue when it comes to ESG matters, according to the association.

“Different actors analyse the issues and publish the information in different ways, making it difficult to compare,” said aba. “In addition, most research is equities focused.”

The association also raised the risk of “greenwashing” by companies in this context, noting that it might occur “in areas where it is difficult to measure improvement”.

ShareAction, a London-based responsible investment charity, yesterday published a survey indicating that lack of data was preventing institutional investors from incorporating the UN’s Sustainable Development Goals (SDGs) into their investment process.

German investors were among the respondents.

The UN-backed Principles on Responsible Investment (PRI) are “a good starting point” for many investors looking at long-term risk assessment, said aba.

However, the most important directive for occupational pension funds, according to the association, is the IORP Directive, and it “should be kept in mind”.

Fiduciaries ‘busy people’

A revised IORP Directive is in the process of being negotiated by the European Council, the EC and the European Parliament (EP), with the EP’s proposed version mandating the integration of ESG factors in fiduciary duty.

The aba is against this and reiterated its position in this latest consultation response.

“To avoid uncertainty for IORPs and sponsoring employers and to allow them to address the challenges they currently face,” it said, “the review of the IORP Directive should not lead to additional regulatory changes in this field.”

In Germany, overall interest from beneficiaries in ESG matters “is perceived to be relatively low”, said aba.

Still, external events such as the UN climate change conference in Paris and scandals, such as about investing in cluster bombs, can trigger individuals to contact their pension scheme, noted the association.

Asked about barriers to more integration of medium to long-term risk indicators, including ESG matters, into investment decisions, aba identified five factors that affect investor behaviour in this area.

These included “fear of a lower return, reduced investment universe, higher costs, the fact many ESG factors are not specific and a lack of human resources”.

“In addition,” it says, “day-to-day investment decisions are often outsourced to external asset managers, with the investors not providing additional indicators relating to ESG factors.”

Investment consultants, said aba, “almost never, unless it is already included in the concept”, consider an asset manager’s approach to ESG issues and active asset ownership when advising institutional investors about selection of managers.

Elsewhere, it said “fiduciaries are busy people, and ESG is not a priority”, citing a 2006 and 2015 updated report from Freshfields on the matter.

Sustainable and long-term economic growth is a pre-occupation for many European policymakers, who are trying to recruit the financial sector, in particular institutional investors, to play a greater role in unlocking the investment needed to achieve this aim.

The EC’s consultation, for example, builds on the ‘Communication on Long-Term Financing of the European Economy’ and the Commisson’s Capital Markets Union action plan. 

In the UK, meanwhile, a fresh initiative came from the Investment Association, which yesterday launched an action plan aiming to solve the country’s “productivity puzzle” and fostering long-term investment thinking.

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