On June 23, 2020, the Department of Labor issued a rule proposal aimed at formalizing and updating DOL’s interpretation of ERISA fiduciaries’ obligations regarding ESG integration. The PRI (to which Dalton is a signatory) argues that the proposal fails to distinguish between ESG integration and economically targeted investing, also known as “impact investing.” The PRI believes the lack of clarity on this point could cause the US to lag other leading markets around the world, which have made the consideration of ESG factors a requirement for investment fiduciaries. Dalton believes that fully integrating ESG analysis into its process is part and parcel of its fiduciary duty of prudent risk management and believes that investing in companies with stronger ESG practices likely will have an impact on long-term company and stock performance. Dalton has submitted letters to the DOL, providing its views on the proposal and asking the period for comment from interested parties to be extended from 30 days to 90 days, to allow for a more thorough discussion of this important issue.
Dalton’s sustainable investment policy is here.
Please click here to view Dalton’s letters to the DOL.