ESG Policy

Policy as at:


The Board recognises that environmental, social and governance (ESG) matters are an essential part of the investment strategy and stock selection process of Mid Wynd International Investment Trust plc (the Company, or Mid Wynd). We expect our Manager, Artemis Fund Managers Limited (Artemis), to invest in companies which provide long term value for our shareholders, without damaging either society or the environment. The Company’s ESG values are aligned with those of the Manager. The assessment of ESG factors is incorporated throughout Artemis’s investment process – from thematic analysis to stock selection and portfolio construction, as well as on-going engagement and voting.

Investment process

As the Manager of shareholders’ capital, Artemis acts in shareholders’ interests to invest in companies which can create, preserve and enhance value. This involves the assessment of a broad range of factors which have, or could have, an impact on value, including those related to ESG drivers.

The portfolio has a number of key themes. These currently include automation, the transition to a low carbon world and online services. At a thematic level, the consideration of ESG factors can highlight long-term risks and opportunities, for example the labour implications of increasing automation, the legislative and environmental considerations related to the transition to a low carbon economy, and data privacy, corporate ethics and potential regulation for online service providers.

At a company level, Artemis has a set of ESG metrics which are assessed alongside traditional financial metrics to build a holistic view of the likely risks and opportunities for investment returns. These metrics often include carbon emissions, diversity, severe controversies, employee turnover, voting rights, and other governance issues.

The Manager attempts to establish the materiality of each of the underlying factors alongside its work on profitability.  Sometimes these factors raise quantifiable issues, such as environmental liability. Other aspects such as governance at a company or political level require judgement and affect sizing holdings rather than a decision whether to hold a stock.  This leads to certain sectors being excluded (using a 10% revenue threshold) where poor sustainability standards are endemic. As such, Mid Wynd aims to exclude from the portfolio the following: companies which receive more than 10% of their revenue from tobacco, gambling, weapons (including a total exclusion of companies involved in the production of cluster munitions, landmines, biological and chemical weapons) and fossil fuels (companies which derive more than 10% revenue from mining or sale of thermal coal; or extraction, production or refining of either oil or gas). These restrictions reinforce the Company's avoidance of companies that cause the most harm to the planet and society and there is a belief that this satisfies the principled needs of most investors. These exclusions are primarily focused on environmental and social factors, although soft exclusions around governance risks are also included. As a result, the Company has a low carbon risk, one which is significantly lower than its comparator index, the MSCI All Country World Index.

Issues around sustainability are constantly evolving and therefore require some level of judgment to be applied and informed predictions to be used to identify trends. Consequently, in addition to the 'hard exclusion' sectors noted above, the Company also has 'soft exclusions' where the Manager believes the risks are currently too great given the capital-protective approach to Company management. As an example, the Company has excluded Russian companies since the Manager was appointed in 2014 due to the level of governance standards. Overall, the Manager believes that it is sensible to have a forward-looking lens on sustainability issues when running a qualitative approach to stock selection that is built on fundamentals. For this reason, the sustainability approach is integrated as part of active, pragmatic fundamental equity analysis.

Artemis uses a number of research providers to guide its ESG risk and opportunity assessment, including the Sustainability Accounting Standards Board (SASB), MSCI ESG, Sustainalytics and company ESG reports. These sources of information provide valuable analysis and insight, but they are just one set of inputs into Artemis’s own investment evaluations. They supplement Artemis’s own research and engagement with companies.


The Board is mindful that it is overseeing the management of a substantial investment portfolio on behalf of investors. In many cases, the investment in the Company may represent a large proportion of an individual’s savings. Our approach to governing the Company is therefore underpinned by our determination to do the right thing for our shareholders.

Artemis undertakes extensive engagement with investee company managements on matters such as strategy, performance, risk, dividend policy, governance and remuneration. It also assesses matters relating to material environmental, human rights and social considerations that will ultimately affect the profitability of a company or its stock market rating.

The Mid Wynd Board has given discretion to Artemis to exercise the Company’s voting rights. Artemis endorses the UK Stewardship Code and has active engagement in industry bodies as well as with investee company boards. A copy of its Stewardship Report is available on the Artemis website.

With regard to the diligent performance of its stewardship obligations, Artemis actively participates in a range of industry wide initiatives and collaborations, with a view to driving positive change in the investment industry. It is a signatory to the Principles for Responsible Investment and the Climate Action 100+ initiative, a member of the Investor Forum, has a number of representatives on committees of the Investment Association and is a member of the Sustainable Accounting Standards Board.

Further information on how Mid Wynd discharges its responsibilities is given in the s172 Report within the Strategy and Business Review of the latest Annual Report and Accounts (link provided).

Full details on Stewardship, ESG and Engagement and Voting can be found on the Artemis website (link provided).

Charitable activities

The Manager has its own Charitable Foundation. Improving equality of opportunity is integrated into the activities of the Artemis Charitable Foundation.

Full details can be found within the Artemis Stewardship Report on the Artemis website.


The value of investments may fall as well as rise. Past performance is no guarantee of future returns. This document is issued for information purposes only and is not to be construed as an advertisement or a public offering of any investment. Nothing in this document constitutes investment, legal, tax or other advice. You must ensure you understand the risks associated with any investment you consider and read all relevant disclosure documentation.