Environmental, Social and Governance (ESG) and sustainable investing may limit the type and number of investment opportunities, and, as a result may affect performance relative to other approaches that do not impose similar sustainability criteria. Sustainable investment products are subject to availability. Certain sustainable investment opportunities may not be available in all regions or not available at all. No guarantee is provided regarding the financial or sustainability performance of such products and the products may not meet their investment or sustainability objectives. 

Investment strategies, portfolios and products offered via the Citi Global Wealth Investments’ (CGWI) sustainable investing platform, Investing with Purpose (IwP), meet CGWI’s defined criteria for a sustainable investment. Every sustainable investment on the IwP platform incorporates one or more approaches: Socially Responsible Investing (SRI), Environmental, Social and Governance (ESG) Integration, Thematic, and Impact. 

At CGWI, we define the four approaches to sustainable investing as follows. Socially Responsible Investing (SRI) involves the exclusion of sectors or companies that may not to be aligned with sustainability values or objectives. The investment mandate must explicitly state the intention to exclude certain exposures to such sectors, industries and products based on values-related criteria. 

ESG Integration uses ESG data and metrics to identify investments with potentially attractive risk and return characteristics. Investment mandates will incorporate ESG risks and opportunities that are considered material and integral drivers of investment decisions into their investment process. Managers of ESG integration strategies may directly engage with portfolio companies and / or use their proxy votes to help drive positive ESG outcomes.

Thematic investments access exposure to investments aligned to sustainable themes such as climate change or access to healthcare. Investments seek alignment to sustainable themes through their business lines as demonstrated by their current and future revenue exposures. 

Impact investments demonstrate measurable impact in a particular environmental or social area. Investment mandates not only state intent, but also manage to a desired sustainable outcome by providing measurable environmental and/or social metrics alongside a potential financial return. To be considered ‘impact’, the outcome must be incremental, meaning it would not have occurred had the investor’s capital not been allocated to the investment. 

A single investment product can combine multiple approaches. These approaches may limit the type and number of investment opportunities, and, as a result may affect performance relative to other approaches that do not impose similar sustainability criteria. Sustainable investment products are subject to availability. Certain sustainable investment opportunities may not be available in all regions or not available at all. No guarantee is provided regarding the financial or sustainability performance of such products and the products may not meet their investment or sustainability objectives. Strategies and products must meet certain criteria for sustainable investing to be marketed as such on CGWI’s IwP platform. Investments outside the IwP platform may still consider sustainability criteria in the investment process, such as potential impact of climate risk on investment value.

There is currently no globally accepted framework or definition (legal, regulatory or otherwise) nor market consensus as to what constitutes, an “ESG”, “sustainable”, “impact” or an equivalently labelled product, or regarding what precise attributes are required for a particular investment, product or asset to be defined as such. Different persons may arrive at varied conclusions when evaluating the sustainability attributes of a product or any of its underlying investments. Certain jurisdictional laws and regulations require classifications of investment products against their own sustainability definitions and as such there is likely to be a degree of divergence as to the meaning of such terms. For example, the term “sustainable investing” where used in this disclosure is by reference to CGWI’s internal framework rather than any defined meaning under jurisdictional laws and regulations. There is no guarantee that investing in these products will have a sustainability impact.

There are numerous ESG data providers that evaluate companies on their ESG performance and provide reports, ratings, and benchmarks. Report, rating and benchmark methodology, scope, and coverage, vary greatly among providers. ESG data may not be available for all companies, securities, or geographies and as such, may not necessarily be reliable or complete. Such data will also be subject to various limitations, including (inter alia): i) limitations in the third-party data provider’s methodologies; ii) data lags, data coverage gaps or other issues impacting the quality of the data; iii) the fact that there are divergent views, approaches, methodologies and disclosure standards in the market, including among data providers, with respect to the identification, assessment, disclosure or determination of “ESG” factors or indicators and which precise attributes are required for a particular investment, product or asset to be defined as such; iv) the fact that ESG information, including where obtained from third-party data providers, may be based on qualitative or subjective assessment, and any one data source may not in itself represent a complete ‘picture’ for the ESG metric that it represents; v) the fact that such data may be subject to change without any notice of this to CGWI by the third-party data provider or other source. Furthermore, some of the data CGWI obtain from third-party providers is not obtained directly from investee companies, but rather represents estimated / proxy data that the third-party data provider has prepared using its own proprietary methodologies (e.g. because there is no actual investee company data). Such proprietary methodologies are also subject to various limitations of their own, acknowledging that estimates / proxies are in and of themselves an inexact science. CGWI does not make any representation or warranty as to the completeness or accuracy of any such third-party data (whether actual or estimated), or of data that is generated using this third-party data. CGWI shall have no liability for any errors or omissions in the information where such information has been obtained from third parties or not.