Write follow-up letters
Most campaigners find that a series of letters, rather than a one-off, is more successful in lobbying. However, not everyone has the time for a protracted correspondence, so don’t feel discouraged from taking part in the campaign if you can only write once. The work of individual campaigners is part of the national campaign and a number of individual letters will contribute to a cumulative effect.

DO...
• Keep copies of your letters and their responses
• Write follow up letters if you can
• Keep us informed of your correspondence and your progress

Countering some common responses

1. A letter correctly sent to the policy makers is answered by an administrator, with a dismissive statement clearly intended to discourage further correspondence.
Send a second letter to the original person, making it clear that as your letter refers to questions of investment policy it needs to be answered by him/her, and cannot be properly dealt with by someone whose job is to implement policy, not make it.

2. ”We have a Socially Responsible Investment policy and insist that our fund managers actively ‘engage’ on SRI matters with the management of the companies in which we have investments.”

BACKGROUND NOTE
This response is more likely to be coming from those who are responsible for a pension fund rather than a charitable fund and could be written by trustees or an administrator.

Since July 2000, all pension funds are required to publish a Statement of Investment Principles, which must indicate the extent (if at all) to which social, environmental or ethical considerations are taken into account when formulating their investment policy. An investment policy that incorporates these considerations is now often called a Socially Responsible Investment (SRI) policy.

This is a woolly term, however, and one which covers a number of different approaches, such as:
• Positive screening – where companies are selected because they fulfil certain criteria, often environmental, defined by the trustees
• Negative screening – where companies or sectors of the market are avoided because they are felt to be unacceptable in some way
• Engagement – ‘Positive engagement’ has been defined by the Ethical Investment Research Service as “a conscious process in which areas of improvement are identified for individual companies; the investor then seeks to persuade these companies to commit themselves to change and then monitors the implementation of any commitments made.”

‘Engagement’ has always been an integral part of any ethically managed fund, but fund managers are now promoting it as able to deliver improved financial returns as well as a socially responsible investment policy which avoids negative screening.

YOUR REPLY
In responding to this sort of letter, it is important to recognise that trustees will be reluctant to hear that their SRI policy is flawed. It may well take a considerable time for them to realise the shortcomings of a policy of ‘engagement’ that does not include the possibility of divesting from companies who fail to comply with agreed commitments.

When investing in target companies, they must not be allowed to ignore the social and environmental impact of what those companies do. Your aim would be to point out the shortcomings of their policy and hope that trustees will eventually realise the inappropriateness of including a company that contributes to human rights abuses in Sudan.

3. ”We do hold investments in target companies, but only a small proportion of their activity takes place in Sudan, so we do not feel that there is a significant ethical issue to be addressed.”

Point out that the target companies on the SDTF list are the ones who rate most poorly against the targeted divestment criteria. There are many more companies operating in Sudan who offer great benefit to the local population and/or who do not provide revenue directly to the Bashir government for the purposes of ethnic cleansing in Darfur. Example in here?

4. ”The oil/telecoms/x industry in Sudan is helping the country to grow economically and provides valuable revenue to allow that to happen” Point out that your concern lies with the fact that much of the revenue goes on military spending. It is not being invested in infrastructure, education, healthcare, or humanitarian purposes, nor does it contribute to the country’s economic growth and allow the people of Sudan to benefit from that growth. In contrast, it is being used to finance a campaign of ethnic cleansing in the Darfur region against those civilians that it should be helping.

5. ”Our investments are managed by the Charities Aid Foundation (CAF) in one of its common investment funds, so all investment decisions are theirs.”

BACKGROUND NOTE
CAF offers Charities a number of investment products, and of these the CAF Socially Responsible Fund specifically excludes investment in companies engaged in gambling, pornography, tobacco, alcohol, arms and nuclear power. However, it does not consider a companies indirect involvement in, for example, human rights issues.

YOUR REPLY
Point out that although they have handed over the management of their funds to CAF, they are still trustees and are in a position to specify how they want their fund invested. Ask whether they would consider switching to CAF’s Socially Responsible Fund, if they have not already done so.

6. ”We have a small percentage of our fund invested in an ethically managed portfolio.”

BACKGROUND NOTE
A number of local authority pension funds have placed a small percentage of their pension fund in a portfolio managed according to specified social, environmental or ethical criteria.

Councillors do want to be popular and win votes as long as they do not risk falling foul of the law (see next section). So to find that there is a prudent way of comparing the performance of their main pension fund with an ethically managed portfolio must be very reassuring.

Where the percentage invested in the ethical fund is small, about 1 or 2%, they presumably feel that the risk of jeopardising the overall financial return of the pension fund is minimal.

YOUR REPLY
Ask how long the ethical fund has been running and if it is not one we know about, ask what ethical criteria are applied and when they will be reviewing its performance. Will they consider extending the percentage of the main fund to be managed ethically?

If the correspondence continues you could go on to ask about excluding one company, such as x. If councillors are willing to invest 1 or 2% of their funds entirely ethically, they might be willing to consider excluding one company from their main portfolio.

8. ”There are so many different interest groups in the county, and a wide range of opinion as to what is, or is not, ethical, that we could not possibly take notice of them all. We aim to manage our fund in a way that benefits society as a whole.”

Say that you understand that obtaining the best financial return on their investments has to be their priority, but remind trustees that in a ‘tie break’ situation where there is a choice of two equally good investments, ethical considerations are preferable. They could also consider a policy of long-term sustainability.

Please also see the FAQs section from the Sudan Divestment Task Force at http://www.sudandivestment.org/divestment.asp