1. Select region

3. Select role

Institutional Intermediary

This website is not suitable for retail investors. If you are a retail investor, please contact your financial advisor.


Change country


You are about to enter a website for professional/institutional investors and the information contained herein is not suitable for retail investors. Private/retail investors should not proceed any further.

By clicking “Accept” you expressly acknowledge and confirm that you are accessing this site for the purposes of acquiring information as a professional/institutional investor and accept the Terms of Use.


    Your access to and use of the web sites (“Services”) of Wellington Management are conditioned on your acceptance of and compliance with these Terms of Use (“Terms”). By accessing or using the Services, you agree to be bound by these Terms. If you are accepting these Terms and using the Services on behalf of a company, organization, government, or other legal entity, you represent and warrant that you are authorized to do so. You may use the Services only in compliance with these Terms and all applicable local, state, national, and international laws, rules, and regulations.

    All materials on this web site are owned or licensed by Wellington Management and/or its third-party providers and are protected by US and international intellectual property laws.  Unless otherwise indicated, all service marks, trademarks, and logos appearing on this web site are the exclusive property of Wellington Management. The information, materials, and other content of this web site may not be copied, displayed, distributed, downloaded, licensed, modified, published, reposted, reproduced, reused, sold, transmitted, used to create a derivative work, or otherwise used for public or commercial purposes without the express written consent of Wellington Management.

    Products and services
    The information, materials, products, and services on this web site are current at the time of writing and are subject to change. Not all products and services are available in all geographic areas. Your eligibility for particular products or services is subject to determination by and the approval of Wellington Management. No solicitation is made by Wellington Management to any person to use any information, materials, products, or services in any jurisdiction where the provision of such information, materials, products, and services is prohibited by law.

    The information on this web site or in any communication containing a link to this web site is not intended to constitute investment advice or an offer to sell, or the solicitation of an offer to purchase shares or other securities.

    Investment products and services are available through Wellington Management. Investment products and services are not FDIC-insured, are not deposits or obligations of, or guaranteed by, any bank, and involve investment risks, including the possible loss of the principal amount invested. Investors should always obtain and read an up-to-date investment services description or prospectus before deciding whether to appoint an investment manager or invest in a fund.

    International use
    Wellington Management makes no warranties that materials on this web site are appropriate for use in countries other than the US. Because the web site may be accessed internationally, you agree to comply with all local laws, rules, and regulations including, without limitation, all laws, rules and regulations in effect in the country in which you reside and the country from which you access the web site. The information on this web site is not intended for distribution to, or use by, any person or entity in any jurisdiction or country where such distribution or use would be contrary to law or regulation, or which would subject Wellington Management or its affiliates to any registration requirement within such jurisdiction or country.

    No warranty
    Wellington Management does not warrant the accuracy, adequacy, completeness, or timeliness of the information, materials, products, and services on this web site or the error-free use of this web site. All information, materials, products, and services are “as is” and “as available.” No warranty of any kind, express or implied, including but not limited to the warranties of non-infringement of third-party rights, title, merchantability, fitness for a particular purpose, and freedom from computer virus is given in conjunction with the information, materials, products, and services. Any views expressed herein are those of the author(s), are based on available information, and are subject to change without notice. Individual portfolio management teams may hold different views and may make different investment decisions for different clients. Wellington Management does not warrant that the web site will meet your needs. You agree to assume the entire risk as to your use of the web site.

    Limitation of liability
    In no event shall Wellington Management be liable for any damages, losses, or liabilities including without limitation, direct or indirect, special incidental, consequential damages, losses, or liabilities, in connection with your use of this web site or your reliance on or use or inability to use the information, materials, products, and services on this web site, or in connection with any failure of performance, error, omission, interruption, defect, delay in operation or transmission, computer virus, or line or system failure, even if Wellington Management is advised of the possibility of such damages, losses, or expenses.


    As a condition of your use of the Services, you agree to indemnify and hold Wellington Management, its affiliates, and its and their respective partners, directors, employees, and agents harmless from and against any and all claims, losses, liability, costs, and expenses (including but not limited to attorneys’ fees) arising from your use of the web site or from your violation of these Terms.

    Your use of the hyperlinks on this web site to other Internet web sites is at your own risk. Wellington Management is not responsible for the content or accuracy of third-party web sites hyperlinked from this web site, nor does it guarantee the products or services offered on third-party web sites. You should review the privacy statements of a web site before you provide any personal or confidential information.

    Web site security and restrictions on use
    As a condition to your use of Services, you agree that you will not, and you will not take any action intended to:  (i) access data that is not intended for you; (ii) invade the privacy of, obtain the identity of, or obtain any personal information about any other user of this web site; (iii) probe, scan, or test the vulnerability of this web site or Wellington Management’s network or breach security or authentication measures without proper authorization; (iv) attempt to interfere with service to any user, host, or network or otherwise attempt to disrupt our business; or (v) send unsolicited mail, including promotions and/or advertising of products and services. Unauthorized use of the web site or Services, including but not limited to unauthorized entry into Wellington Management’s systems, misuse of passwords, or misuse of any information posted to a web site, is strictly prohibited. Portions of the web site are designated for password access only as indicated by a lock icon. In these instances, if you do not have an authorized password, no access is permitted.

    Confidentiality and password security
    Certain parts of this web site may be protected by passwords or require a login. You are responsible for maintaining the confidentiality of any user names, passwords, security questions, and answers. All information available through the privileged area of the site is confidential and proprietary to us. This includes all investment information and results, offering materials, financial statements, and other information provided through this part of the site.

    You will use your best efforts to keep all this information strictly confidential. You will not disclose any of this information to any person or use it for any purpose other than those strictly permitted by us, in writing.

    If any provision of these Terms is deemed unlawful, void, or for any reason unenforceable, then that provision will be reformed only to the extent necessary to make it enforceable, and it will be deemed severable from these Terms and will not affect the validity and enforceability of the remaining provisions.

    Applicable law
    These Terms and any action related thereto are governed by Massachusetts law and applicable US federal law. Any dispute relating to the above shall be resolved solely in the state or federal courts located in Massachusetts.

    Privacy statement
    Wellington Management respects the privacy of its clients and the confidentiality of information pertaining to its clients.

    Information we collect
    We may collect non-public personal information about you on RFPs, questionnaires, and other forms we receive from you, as well as from personal contacts such as correspondence, e-mail, telephone calls, or meetings. We may also receive information about you from third parties, such as your accountants, lawyers, financial consultants, and/or other service providers.

    It also is possible to receive information from web browsers and apps regarding certain of your online activities using cookies, or other common tracking technologies.  Some web browsers and other applications may provide a Do Not Track (DNT) preference setting.  When a user turns on a tracking preference, the browser or application may send a message to web sites requesting that they do or do not track the user. At this time, we take no actions in response to any DNT settings or messages.

    Information sharing
    Wellington Management seeks to provide seamless service to all clients. To facilitate that process, information regarding client accounts is shared broadly between affiliates within the Wellington Management group of companies. For example, an affiliate may share information with other affiliates in order to facilitate portfolio management or provide client liaison services to a particular client. Client information may be used by Wellington Management in order to identify potential client needs for additional investment management services.

    Wellington Management generally does not share non-public client information with unaffiliated third parties, except as necessary to perform the investment management services it has been hired to provide. For example, Wellington Management may share non-public client information with brokers and custodian banks in order to buy and sell securities and record those purchases and sales accurately. As a general rule, Wellington Management does not engage in joint marketing arrangements with unaffiliated third parties that involve the sharing of non-public information regarding Wellington Management’s clients. Wellington Management does not provide client information to unaffiliated third parties for their own marketing purposes.

    Wellington Management does not disclose your information except as required or permitted by law. In the event that Wellington Management is involved in a merger, acquisition, reorganization or sale of assets, or bankruptcy, your information may be transferred or sold as part of that transaction.

    Security policies
    We use technical, administrative, and procedural measures in an attempt to safeguard your personal and other information from unauthorized access or use. No such measure is ever 100% effective though, so we do not guarantee that your personal and other information will be secure from theft, loss, or unauthorized access or use, and we make no representation as to the reasonableness, efficacy, or appropriateness of the measures we use to safeguard such information. Users are responsible for maintaining the secrecy of their own passwords. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us by contacting your relationship team member.

    Transfer of data to other countries
    Any information you provide to Wellington Management through use of the Site may be stored and processed, transferred between, and accessed from the US and other countries which may not guarantee the same level of protection of personal information as the one in which you reside. However, Wellington Management will handle your personal information in accordance with this Privacy Statement regardless of where your personal information is stored/accessed.

    Changes to Terms of use

    We may revise these Terms from time to time; the most current version will always be at http://www.wellington.com/terms-use. By continuing to access or use the Services after those revisions become effective, you agree to be bound by the revised Terms.

    Effective as of  17 January 2014

This web site uses cookies; by continuing to browse you consent to our cookies usage.
See our policy for more details.

April 2018 | Multiple authors

Global ESG Research Update — Shining a light on the “S” of ESG

Our ESG Research Team explains how they engage with companies on issues like the opioid crisis, firearms, and workplace harassment, and why broader stakeholder views and actions on such externalities matter. They also provide an update on ESG engagement activity in the first quarter.

DISCOURSE ON OPIOIDS, FIREARMS, AND SEXUAL HARASSMENT HAS PUT THE “S” IN ENVIRONMENTAL, SOCIAL, AND CORPORATE GOVERNANCE (ESG) INTO SHARP FOCUS. Our investors have long considered social externalities — the negative effects that companies can have on society through their products, cultures, or policies — in our fundamental research and engagement. These nuanced, often misunderstood issues can affect the value of corporate securities. Today, these are no longer just shareholder concerns; companies need to consider the opinions and actions of broader stakeholder constituencies, including employees, customers, and the public.

Seeking greater transparency

Members of our ESG Research Team encourage companies to disclose risk-management strategies that acknowledge their societal impacts. When a company faces litigation or negative press, we inquire about lessons learned and request evidence of substantive changes that aim to prevent recurrence and mitigate downside risk.

We are engaging with drug manufacturers and distributors on their role in the opioid crisis. Most have been open and responsive to enhancing their risk-management processes, as they have become aware of the potential negative impacts on their brand and bottom line. Engagement with weapons-related companies, on the other hand, has been mixed, with some dismissing the public backlash as a passing political issue, and others facing political pressure if they sever ties with the National Rifle Association. Our team will continue to engage on this issue.

Given the flurry of workplace misconduct accusations, we recently collaborated with our Human Resources and Legal Teams to develop questions for assessing the potential financial impact of these incidents as they occur. We believe certain sectors and corporate cultures are more susceptible to such behavior, and company-specific factors, including key-employee risk, can exacerbate the consequences. We increasingly look to open-source and public platforms for information about companies’ tolerance for misconduct. A pattern may indicate a structural problem, posing greater risk to shareholders.

We seek to gauge a company’s attitude and approach on social issues. Is management dismissive and defensive, or receptive to feedback and open to change? We want to see evidence of the latter, which may indicate solid overall risk management and sensitivity to the concerns of shareholders and stakeholders.

1Q2018 Firmwide proxy-voting results

Proxy voting can be a powerful tool that we leverage when engaging with company management teams. Our team examines each proxy proposal and votes against issues that we believe would have a negative effect on shareholder rights or on the current or future market value of the company’s securities. Figure 1 shows the breakdown of the past quarter’s global proxy voting.

Figure 1

Wellington Management’s 1Q2018 proxy-voting results

1Q2018 ESG engagement activity

In the first quarter of 2018, our team engaged with 96 portfolio companies in 18 countries (Figure 2) on ESG topics ranging from climate risk disclosure to diversity and corporate culture to board composition. See the list of our engagement discussions for the quarter below.

Figure 2

Company engagements by Wellington Management’s ESG Team in 1Q2018

1Q2018 ESG engagement activity by company

  Company E S G
  Consumer discretionary
  Advance Auto Parts  
  Cheesecake Factory  
  Ford Motor Co
  Honda Motor Co Ltd
  J Alexander’s Hldgs    
  Lowe’s Companies  
  Maisons du Monde SA  
  Neinor Homes SA  
  Newell Brands Inc  
  Norwegian Cruise Lin
  Persimmon PLC  
  Rakuten Inc    
  Wolverine World Wide    
  Company E S G
  Cimarex Energy Co
  Concho Resources Inc    
  Diamondback Energy  
  EnCana Corp    
  Energy Transfer Prtn  
  Extraction Oil & Gas
  Exxon Mobil Corp    
  Marathon Petroleum
  Oasis Petroleum Inc    
  Royal Dutch Shell  
  Company E S G
  American Express Co    
  Assicurazioni Gen  
  Banco Santander SA
  Bank of America Corp  
  BlackRock Inc    
  Brighthouse Financial    
  Comerica Inc    
  Dai-ichi Life Hldgs
  Enstar Group Ltd    
  FCB Financial Hldgs  
  Fidelity Southern    
  Hannon Armstrong    
  MGIC Investment Corp
  Prudential Financial    
  Travelers Cos Inc    
  Wells Fargo & Co  
  Company E S G
  Health care
  Anthem Inc  
  athenahealth Inc  
  Baxter International  
  Envision Healthcare    
  Genmab A/S    
  Company E S G
  ABB Ltd  
  ACS Actividades Cons    
  Advanced Drainage Sy  
  AerCap Holdings NV  
  Airbus SE  
  Cie de Saint-Gobain
  Continental Building  
  CSX Corp  
  Equifax Inc  
  General Electric Co  
  Illinois Tool Works  
  Insteel Inds Inc    
  JetBlue Airways Corp  
  Johnson Controls Int    
  Knight-Swift Transpo    
  Mitsubishi Corp
  Navigant Consulting    
  Nippon Yusen KK    
  Pentair PLC  
  Prosegur Cia de Segu    
  Rexnord Corp  
  Schneider Electric    
  Terex Corp  
  United Parcel Servic  
  Company E S G
  Information technology
  Acxiom Corp    
  Akamai Technologies    
  Belden Inc    
  Broadcom Ltd    
  CommScope Holding Co    
  HP Inc  
  Nintendo Corp  
  PayPal Holdings Inc  
  Samsung Electronics  
  Sopra Steria Group    
  Company E S G
  BHP Billiton Ltd
  Minerals Tech Inc    
  Nampak Ltd    
  Northern Dynasty Min
  Olin Corp    
  Company E S G
  Real estate
  Easterly Govt Pptys    
  Equinix Inc  
  Unibail-Rodamco Se    
  Company E S G
  E.ON SE    
  Entergy Corp  
  FirstEnergy Corp  
  Iberdrola SA
  PG&E Corp  
  Pinnacle West Cap    

E = environmental, S = social, and G = corporate governance discussions. The companies shown comprise a complete list of all engagement meetings in which Wellington Management’s ESG Team participated in 1Q2018. The companies shown are not representative of all of the securities purchased, sold, or recommended for clients. It should not be assumed that an investment in the companies listed has or will be profitable. Actual holdings will vary for each client and there is no guarantee that a particular client’s account will hold any or all of the companies shown. This material is not intended to constitute investment advice or an offer to sell, or the solicitation of an offer to purchase shares or other securities.

1Q2018 ESG engagement examples



We met with the chair and CEO, the CFO, and the incoming lead independent director to discuss board updates, the company’s climate report, and cybersecurity.

Key discussion topics
Climate change

We supported a 2017 shareholder proposal for increased climate risk disclosure, which received notable shareholder support but did not pass. Despite initial resistance to the proposal, the company proactively published a report aligned with the recommendations of the Task Force for Climate-related Financial Disclosures (TCFD). The management team believes the company would fare well, even in a 2-degree scenario, due to the cost advantage of US refining versus global peers and the bullish outlook on natural gas as it relates to the midstream business. The team therefore emphasized continued investment in the company’s export capability and midstream infrastructure. The company has been investing significantly in the resilience of its physical assets, particularly electrical infrastructure and building construction.

The company’s energy intensity may increase temporarily as it makes certain investments to meet the International Maritime Organization (IMO) targets for sulfur reduction in fuel oil by 2020. However, the company believes this temporary trade-off should be a meaningful net positive given the toxic emission improvements that will result. Refiners who can meet the expected increased demand for cleaner, compliant fuel may be poised to gain a competitive advantage as the shipping industry looks to adhere to the new rules.


The new lead independent director raised cybersecurity as one of the board’s top priorities, on par with climate risk. The CFO described their approach, as cybersecurity personnel report to him, and he noted that resource allocation to cybersecurity efforts will continue in the future.

At gas stations, personal fraud is the biggest risk. This company will be fully EMV-chip compatible by the end of 2018 across all locations, well ahead of the liability shift for US credit card payments that is expected in 2020. This data security improvement is seen as an opportunity to build customer trust and perhaps push cyberattacks to less proactive competitors. Because terrorist threats pose potential risks to refining operations, the company works with the FBI and Department of Homeland Security. The CFO emphasized the hiring of a cyber expert with a military background as key to these efforts.

Board composition

The CEO shared recent changes to the board, including the addition of two directors—one with global and downstream expertise applicable to the company’s goal of growing exports, and the other with midstream experience applicable to the core business. Two directors will be retiring. The board seeks to add commercial, financial, and technology skill sets with future director appointments. The CEO discussed their commitment to increase board diversity, as the board currently includes two people of color, one of whom is a woman.

The board remains classified after numerous years as an independent company. Although the board put declassification on the proxy ballot in 2013, it did not pass due to the company’s supermajority requirement.


The discussion highlighted passionate engagement by the board and senior management on major ESG issues, including climate change and cybersecurity. On climate change, we appreciate the company’s responsiveness to shareholders with improved transparency of climate risks. Its application of the TCFD framework is commendable, including the links from scenario analysis to strategic goals and the discussion of physical risks. We suggested enhancements to future disclosure, specifically to better articulate board oversight and identify efficiency targets to more accurately reflect refinery efforts. On cybersecurity, we are pleased that the CFO and the board are well-versed in cyber risks and that there is a direct escalation channel from information security to top management. We will continue to encourage management to declassify its board and improve board diversity, and we will monitor the company’s progress as the 2020 IMO deadline approaches.



We met with the global head of ESG to discuss ongoing efforts to improve the company’s customer relations, employee engagement, and public profile.

Key discussion topics
Corporate culture

Over the past five years, the company has learned that customer-centric growth is not at odds with business results. This mind-set shift was set in motion by the current CEO when he took over. For example, the company eliminated overdraft fees, which had been disproportionately affecting low-income families. This helped create a culture of growing responsibly, and generated significant savings by reducing the number of phone calls from frustrated customers, allowing the company to close call centers.

We asked about the company’s exposure to and management of potential misconduct allegations. The ESG head acknowledged that it’s impossible to stop every bad actor but emphasized the company’s zero-tolerance culture and described mechanisms for employees to report and escalate incidents as vital risk-management tools.

The company closely monitors its progress through employee and customer satisfaction scores, which have been improving. While some competitors have had to correct their employee incentive structures, this company determined it didn’t have to change sales practices or compensation. Nonetheless, the company recognizes the need to counter the strongly negative public opinion about large banks. The ESG head believes that the company’s public profile should improve over time as it should get credited for operating responsibly. As evidence that responsible investment is a priority, the ESG head reports to the vice chair, who reports to the CEO.


We appreciate that the head of ESG seems to be truly integrated with the company’s operations, rather than being siloed or overly focused on marketing, as is often the case in this type of role. We are constructive on the company’s progress to address the cultural issues that have historically plagued the industry. We encouraged improvement of disclosure on governance of cybersecurity in the annual ESG report, given the significance of technology to their business. Despite a positive trajectory, in our opinion, companies in this industry will always be magnets for occasional bad press; we will be discerning those headlines for signals of any potential deterioration of this progress.



We spoke with members of the investor relations team about recent developments at the board and management, as well as labor management.

Key discussion topics
Board composition

The board is adding three new directors in 2018. One is the company’s first non-Korean director. He is an American who brings technology, engineering, and operating expertise. Another is a highly qualified woman with legal expertise, and the third is a man who brings expertise in semiconductor technology and electrical engineering. The board also plans to replace two directors in 2019 and is seeking to attract another international director and another woman. Notably, the company also recently separated the roles of chair and CEO.

The company explained that part of the challenge in attracting foreign directors to the board is that the board meets over ten times per year and director compensation is lower than in other countries. In response, the new chair is considering changes to the format of board meetings, specifically holding fewer, more concentrated board meetings with additional time for discussion of strategy rather than simply administrative voting on various issues.

Business ethics

We asked about the employment status of a key executive who is in significant legal jeopardy as his bribery conviction remains under appeal. The company said that if he is convicted again, it will likely fill his role by promoting from within, and not replace him with another family member.

Labor relations

Unlike others in its country of operations, this company does not have unionized employees; rather, it uses its competitive compensation to ensure employees are content without needing union negotiations. The company does not believe that the negative press about bribery allegations has affected its ability to attract talent.


We are pleased that, after years of engagement, the company is making significant improvements to the composition of its board. Governance concerns remain regarding the company’s convoluted ownership structure and family control. The legal trouble of a top executive is less than ideal; we plan to monitor these developments closely and will engage again if the appeals process ultimately goes against him. Nevertheless, the notion that he would be replaced with existing talent — and not another family member — signals a marked shift in succession planning and a potential willingness to impart checks on family control.


Explore insights