Dear recipient,
thank you for giving the possibility to comment on these principles. I’m currently working as an Advisor in KPMG, in Responsible Investment, Climate and Sustainability Business in Helsinki. In addition, I’m conducting post-doc research in University of Helsinki, Faculty of Agriculture and Forestry, Department on Economics and Management. My area of specialisation is drivers of responsible investment by institutional investors.
My comments for the Zero Draft are the following:
1. Are all relevant issues and areas related to fostering responsible agricultural investments adequately addressed in the Zero Draft? If not, what should be changed?
It appears to me that the principles are thoroughly prepared. However, I would like to pay your attention to two other sets of principles for responsible agricultural investment that already are in use: comparing the principles you are preparing to the existing ones would ensure that they do not become overlapping. The links are here:
http://unctad.org/en/Pages/DIAE/G-20/PRAI.aspx
2. Are the roles and responsibilities of relevant stakeholders clearly defined in order to facilitate implementation of the principles? If not, what should be changed?
I think the roles and responsibilities are clearly defined. However, I think that the principles do not account for the way investors (that are in a central role to get more investments to agriculture) have to make their investments. Taking this into account would be a major contribution. This would mean that the principles would be modified to be implementable from the asset class point of view. In other words, how to invest in agriculture in the asset classes of equities, bonds, commodities, farmland? If this is not explained, the majority of investors will not have the resources to find this out. I think that you would have a great opportunity here to make agriculture accessible for mainstream institutional investors.
3. Does the Zero Draft achieve the desired outcome to promote investments in agriculture that contributes to food security and supports the progressive realization of the right to adequate food in the context of national food security? If not, what should be changed?
Yes, if the principles explained how investors can invest in agriculture (via the different asset classes). One of the central findings of my PhD is that responsible investment is difficult to define and implement, i.e. institutional investors need support with it.
4. The principles are intended to provide practical guidance to stakeholders; therefore:
Are the current structure and language used clear and accessible for all relevant stakeholders to apply?
I recommend that you would include clear guidance for institutional investors that make the decisions for their investments. To reach this, you are of course welcome to contact me. In my current work, we make responsible investment accessible for institutional investors. Another idea could be to include a finance professional to the team that is preparing the principles.
What steps need to be taken for the CFS-RAI principles to be used and implemented by different stakeholders after endorsement by CFS?
I think it is important to promote the principles for the different parties that are involved in investment decisions and in creating the “environment” for it, i.e. institutional investors, asset managers, service providers, authorities at national and international levels.
Kind regards,
Riikka Sievänen
tel. +358 400 653 640; +358 40 679 2632
博士 Riikka Sievänen