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UK Stewardship Code

This report details our policies and procedures in relation to stewardship; while it is principally focused on the stewardship of UK companies, we apply similar standards to overseas holdings, complying with local requirements, where appropriate.

Statement of compliance

This report details our policies and procedures in relation to stewardship; while it is principally focused on the stewardship of UK companies, we apply similar standards to overseas holdings, complying with local requirements, where appropriate.


Institutional investors should publicly disclose their policy on how they will discharge their stewardship responsibilities.

At Pictet Asset Management we are long-term investors and as such seek to protect the rights and the shareholder value of our clients through the diligent application of our investment process and stewardship activities.

Investment managers are responsible for the implementation of our stewardship responsibilities. Typically the investment manager with the largest holding of a stock will determine voting for or against resolutions. However they must consult with any other investment teams that may also hold those stocks to elicit agreement on the voting policy. This is overseen by the Chief Investment Officer for equities and the Compliance and Legal departments. 

Ultimate responsibility rests with the Executive Board to ensure that robust procedures are in place to execute our stewardship responsibilities.  

When investing in companies on behalf of our clients, we apply the core tenets of good company ownership within our fundamental research-driven investment process. Our goal is to ensure that investee companies are well-run, with a strong culture of corporate governance – including Environmental, Social and Governance (ESG) considerations – and credible reporting standards. To achieve this, through our research and meetings with company management we focus our attention on: 

  • The strength of a company and likely future performance
  • A company’s fair valuation based on its fundamentals
  • A company’s capital structure and any potential changes to this
  • ESG ratings from Sustainalytics and ISS(1)
  • Threats and risks the company may face and the regulatory environment it operates in
  • The clarity and robustness of the company’s corporate strategy and future developments
  • The functioning and calibre of the company’s management team and its ability to implement strategy through effective leadership

These core tenets can only be applied if there is regular on-going interaction with a either a company’s management or its agents; we conduct over 4,000 meetings with company management annually. Interaction with companies takes the form of: one to one discussions; shareholder meetings; investor road-shows and/or conference calls. The objective is both to assess an organisation before investment and to monitor that the corporate strategy is being implemented in line with our expectations and the company is on track with its goals and objectives. Regular ongoing assessment of a company’s performance forms the backbone of our investment thesis for a stock. 

Pictet Asset Management is not an activist investor. However we do consider it our responsibility to engage with and challenge companies’ management to ensure that: strategy is effectively implemented; results are in line with expectations; and shareholder value is delivered to our clients. We also attend and/or vote at AGMs on behalf of our clients. You can view our voting policy here.

(1) Sustainalytics is an award-winning global responsible investment research firm specialized in environmental, social and governance (ESG) research and analysis. The firm offers global perspectives and solutions that are underpinned by local expertise, serving both values-based and mainstream investors that integrate ESG information and assessments into their investment decisions. 

Institutional Shareholder Services Inc. (ISS) is the world’s leading provider of corporate governance and responsible investment (RI) solutions for asset owners, asset managers, hedge funds, and asset service providers. ISS’ solutions include: objective governance research and recommendations; RI data, analytics, and research; end-to-end proxy voting and distribution solutions; turnkey securities class-action claims management; and reliable global governance data and modeling tools.


Institutional investors should have a robust policy on managing conflicts of interest in relation to stewardship which should be publicly disclosed.  

Pictet Asset Management is an independent asset manager and consequently is free of many of the conflicts of interest that are faced by larger or more dependent financial institutions.

Pictet Asset Management recognises that conflicts of interest may arise within the context of the exercising of our stewardship responsibilities, particularly when voting on behalf of our clients’ shares. 

For example, we may have concerns about a company whose pension scheme or senior management are clients of Pictet Asset Management or a Pictet group entity. We have, therefore, implemented robust policies and control processes for the identification, management, and monitoring of potential conflicts of interest, including those arising from engagement or voting issues.

We employ a firm-wide conflicts of interest policy. All of our staff are required to undertake regular training to ensure they are aware of their obligations and adhere to this policy. Our policy can be viewed here

Any conflict of interest arising in the performance of our fiduciary responsibilities – and in particular in relation to the Stewardship Code – will in all instances be referred to both the CIO Equities and Pictet Asset Management’s Head of Compliance to ensure that we always act in the best interests of our clients. If deemed significant issues may be raised to the Executive Board.

In relation to our stewardship activities, a key consideration is ensuring that Pictet Asset Management does not during its course of engagement with company management become an unintentional insider rendering us unable to trade on behalf of clients. In certain circumstances for specific limited periods of time Pictet Asset Management is willing to become an insider. However, to ensure that our ability to deal in stocks is not restricted, we request that companies and their advisers do not make us insiders without our prior agreement. Investment managers will at this point determine whether or not to accept the inside information, taking into account the interests of all clients as a whole.

In accordance with EU Market Abuse Regulations, which came into force in July 2016 we have implemented Gatekeeper procedures to manage and control the wall crossing process in relation to market soundings in respect to potential primary and secondary transactions across equity and fixed income.


Institutional investors should monitor their investee companies.

As active investors, we continually monitor investee companies to ensure the original investment thesis remains intact and to identify any changes that might trigger a decision to no longer invest in the stock or take other action. We use ISS and Sustainalytics to score a company’s ESG rating. It is the responsibility of an investment manager to justify any holding which scores poorly against these analytics. A regular (at least twice a year) independent formal portfolio review is conducted with the Investment Manager, CIO and Managing Partner during which the portfolio’s ESG score is compared to that of the benchmark. Furthermore the five holdings with the worst ESG rating are challenged and must be justified by the Investment Manager. One such example could be recent change of company management, which has yet to be reflected in ESG ratings.

In addition to conducting ongoing analysis of a company’s fundamentals and the relevant risk metrics, we hold a continued dialogue with management to ensure the company strategy remains on target.

For large holdings we typically meet management in person twice a year, while for smaller holding this may be less frequent. We may also attend management briefings, road-shows and AGMs and/or hold conference calls with senior management (smaller holdings).

During a company meeting we use our company analysis template to shape the discussion, capturing all the key information in a uniform manner. We then feed any new information into the research databases used by our active equity investment teams.

Pictet Asset Management generally does not seek to become insiders as this significantly restricts our ability to deal in the securities of the company concerned. However, where the receipt of inside information may lead to positive outcomes to our customers, and does not unduly restrict our ability to trade then on occasions we may choose to receive inside information.

All potential inside information should be sent to the Compliance department who will act as gatekeeper and determine whether the information should be accepted or not by Pictet Asset Management.


Institutional investors should establish clear guidelines on when and how they will escalate their stewardship activities.

As mentioned earlier, we are not an activist manager. We do not buy companies in order to change them. However, we take seriously our stewardship responsibilities and we always act in the best interest of our clients to ensure they receive shareholder value; having invested in a company we would take action, where appropriate, to protect or enhance the value of our clients’ investments.

Where we consider that a company is underperforming, governance or management structures are failing to meet the standards expected, or we have other concerns on matters such as strategy or remuneration, we would pursue a number of courses of action.

We typically begin with discussions with management if we have concerns about a company in which we are invested. If we are not satisfied with the outcome we may write to the full board expressing our concerns. We may also vote against management at company meetings. If we are still not satisfied that the management team have no clear explanation, then we must consider whether it is in the best interest of our clients that we remain invested in the stock. PAM is not an interventionist investor and we do not set about changing companies or management. If we have doubts about an organisation we will simply sell the holding. However if we believe an investment is in the best interest of the client, but we have concerns then we may submit a resolution at a shareholder meeting, although this is rare as typically we will have sold such a position. 


Institutional investors should be willing to act collectively with other investors where appropriate.

Pictet Asset Management recognises that there are occasions when it is better to act collectively rather than individually, particularly if our investment is relatively small given the size (capitalisation) of the company.

Collaborative engagement is reviewed on a case-by-case basis to ensure the objectives are aligned with our own policy and that of our clients. Collective engagements must be approved by Pictet Asset Management’s Executive Board and Compliance department. We monitor such engagements to ensure companies’ subsequent actions are in-line with the engagement objective.

More generally, to enable greater collaboration Pictet Asset Management is a participant or signatory to the following networks or organisations:

  • Since 2007 Pictet Asset Management has been a signatory of the UNPRI principles
  • In 2006 Pictet Asset Management joined the Eurosif organisation of institutional investors, investment managers and research institutes, whose mission is to address sustainability through financial markets. We also adhere to the voluntary transparency guidelines for SRI retail products issued by the same organisation. Further details about Eurosif can be found under www.eurosif.org
  • In 2006 Pictet Asset Management joined Eurosif’s local entities, the Forum Nachhaltige Geldanlagen (FNG), the UK Sustainable Investment & Finance (UKSIF) and the SpainSIF 
  • Since 2014 Pictet Asset Management has been a board member of Swiss Sustainable Finance organisation, which was created to promote sustainability in the Swiss financial market, and strengthen Switzerland's position as a leading worldwide centre for sustainable finance
  • Since 2013 Pictet Asset Management has been a member of the IIGCC (Institutional Investors Group on Climate Change), which provides investors with a collaborative platform to encourage public policies, investment practices and corporate behaviour that address long-term risks and opportunities associated with climate change
  • Since 2010 Pictet Asset Management has been a member of the working group on Responsible Investment of the European Fund and Asset Management Association (EFAMA), which is the representative association for the European investment management industry
  • Since 2007 Pictet Asset Management has been a signatory to the Carbon Disclosure Project, and we sponsored this initiative in Switzerland over three consecutive years (2007-2009). The Carbon Disclosure Project is an organisation which encourages companies to disclose their impact on the environment and natural resources
  • Since 2013 Pictet Asset Management has been a member of the Advisory Committee of the FTSE Environmental Markets Index Series. FTSE Group partnered with Impax Asset Management to create the FTSE Environmental Markets Index Series, which is broken down into two sub-series: the FTSE Environmental Technology Index Series and the FTSE Environmental Opportunities Index Series; both of which are based on the FTSE Environmental Markets Classification System (EMCS).
  • Since 2013 Pictet Asset Management has been a member of the Climate Bond Initiative’s Standards Board, which is an international, investor-focused not-for-profit organisation. It is the only organisation in the world focusing on mobilizing the $100 trillion bond market for climate change solutions
  • In 2008 Pictet Asset Management joined the Global Footprint Network, a non-governmental organisation that has pioneered a metric of sustainable development called Ecological Footprint, endorsed by government bodies and environmental organisations such as the WWF. We use their data to calculate sustainability scores for countries that fall within the investment universe of our SRI bond and balanced portfolios. It is a think tank that develops and promotes tools for advancing sustainability, including the Ecological Footprint and biocapacity
  • In 2008 Pictet Asset Management became one of the founding members of the Swiss Climate Foundation which helps to fund small and medium enterprises that are proactive in their approach to reducing CO2 emissions
  • Since 2009 Pictet Asset Management has been a signatory to the Forest Footprint Disclosure Project.


Institutional investors should have a clear policy on voting and disclosure of voting activity.

Voting rights are exercised systematically on all mutual funds managed by Pictet Asset Management entities. Our voting policy is based on generally accepted standards of best practice in corporate governance. Voting decisions do not always support the management of investee companies since the long-term interests of shareholders is the paramount objective.

For segregated accounts, mandates and third-party mutual funds managed by Pictet Asset Management, clients who want to exercise voting rights have the choice between Pictet Asset Management voting policy or their own voting policy.

To assist us in the exercising of proxy votes, Pictet Asset Management uses the services of third party specialists whose expertise and international experience allows us to vote at all relevant company meetings worldwide. Applicable voting guidelines can be found here:

International companies

US companies

Pictet Asset Management retains full discretion over all voting decisions and reserves the right to deviate from voting recommendations on a case-by-case basis in order to act in the best interest of its clients. Investment managers who choose to vote differently from the third-party recommendations must record their rationale. 

Pictet Asset management does not lend stock. However, the custodians of funds that we manage may lend stock on the provison that: 

a) we can recall stock at any time 

b) any stock lending should not impair or constrain the management strategy and investment managers can freely trade that stock when they wish to do so

Our voting records are published on our website and can be viewed here:

Voting summary 2020
Voting summary January 2021
Voting summary February 2021
Voting summary March 2021
Voting summary April 2021
Voting summary May 2021
Voting summary June 2021
Voting summary July 2021
Voting summary August 2021