The Investment Management Consultants Association (IMCA) code of professional responsibility has helped TCorp with the development of its investment stewardship policy.

The $70 billion central financing agency for the New South Wales Treasury had to recently debate where it stood on values-based investing, with the IMCA code providing one framework from which to think about the issue, TCorp senior manager, investment management Kylie Willment told delegates at IMCA’s annual conference in Sydney on Monday.

“Where we’ve landed on that is that we don’t believe that it is our job as a government investment management organisation to be making value-based decisions within our investment portfolios. We think the government is best placed to make that decision, and they should be instructing TCorp where those exclusions are likely to apply,” Willment said.

IMCA released an updated code, effective from May 1, 2016, to which all its members are required to adhere. This is particularly pertinent to Willment as she is also the deputy chair of the IMCA board.

The code includes principles such as acting in the best interest of clients and maintaining a high level of ethical conduct.

“There is a preamble that talks to a number of professional values that underpin the code. The first one of those is integrity,” Willment said, adding that this was a strong personal and professional value for herself.

The value of integrity, coupled with acting in the best interest of clients, means that Willment and TCorp felt they did not have the right to exclude investments on a values basis, as they were merely custodians of money from the NSW public sectors.

Willment qualified that while TCorp would not be making value-based investments, it “absolutely had to consider” anything that would likely have a material impact on the risk return profile of clients’ investment portfolios or products.

“To the extent that things, such as climate change, pose a material financial risk to the portfolio, we will take whatever action required to make sure we’re considering those risks and that portfolios have a resilience,” she said.


IMCA code of professional responsibility

IMCA members are required to follow this code:

  1. Act in the best interest of the client.
  2. Disclose services to be offered and provided, related charges, and compensation.
  3. Disclose the existence of actual, potential, and/or perceived conflicts of interest and relevant financial relationships, direct and/or indirect. Take appropriate action to resolve or manage any such conflicts.
  4. Provide clients information needed to make informed decisions.
  5. Respond to client inquiries and instructions appropriately, promptly, completely, and truthfully.
  6. Maintain confidentiality of client information, however acquired, consistent with legal and regulatory requirements and firm policies.
  7. Provide competent service by truthful representation of competency, maintenance and/or development of professional capabilities, and, when appropriate, the recommendation of other professionals.
  8. Comply with legal and regulatory requirements related to one’s practice of his or her profession.
  9. Maintain a high level of ethical conduct.

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