Frontier Capital Management Company, LLC (“Frontier”) manages small, smid and mid cap growth and small and smid cap value equity portfolios for primarily institutional investors. Our investment process is focused on our internally generated research. Through in-depth fundamental analysis, we identify companies that we believe have the potential to deliver above average returns for our clients’ portfolios. We typically seek companies that are leaders in their industry, may offer significant upside to consensus earnings per share estimates over the next several years and operate business models that should generate and sustain an attractive return on capital for their shareholders.
Frontier’s financial analysis includes assessing material environmental, social and governance factors (“ESG Factors”) that could impact a company’s business prospects and therefore valuation and share price. The Responsible Investment Policy (“RI Policy”) describes how Frontier incorporates ESG considerations into its fundamental research with the goal of improving investment performance for our clients. While we deem ESG considerations important, they are not the sole factors for investment decisions. Rather, investment teams assess a variety of economic and financial indicators, which may include material ESG considerations, to make investment decisions that achieve our clients’ objectives.
Frontier is a signatory to the United Nations Principles for Responsible Investment (“UN PRI”). As a signatory, Frontier recognizes that applying UN PRI principles to its investment philosophy may better align its clients with the broader objectives of society as articulated by the United Nations sustainable development goals.
ESG Integration: Frontier Capital Appreciation, Frontier Mid Cap Growth, Frontier Small Cap Growth and Frontier Small and Smid Cap Value Strategies
Investment Process
ESG Factors arise from current and future operating practices as well as from external circumstances. Examples of ESG Factors that may be considered include 1) corporate governance factors such as disclosure quality, regulatory compliance, executive compensation, and business ethics, 2) social factors such as human rights, the health and well-being of customers and employees, employee working conditions, community impact and 3) environmental factors such as climate change and the use and sustainability of natural resources. When applied to a particular company, specific ESG Factors and their relative importance may vary significantly depending on the industry, sector, markets, location and revenue sources. Utilizing their industry and sector expertise, Frontier’s Research Analysts exercise their discretion to evaluate the impact on earnings power and valuation that ESG Factors may have on individual stocks. When deemed to be material, ESG Factors are reflected in the Research Analyst’s investment recommendation.
Portfolio Monitoring
While Research Analysts are the primary investment professionals considering ESG Factors as they apply to particular companies, Frontier’s Portfolio Managers also evaluate the importance of ESG Factors and the potential impact on investment performance when managing client portfolios. Frontier investment professionals typically communicate regularly regarding existing and potential holdings, which may include a discussion of how ESG Factors affect a company’s business and future prospects when those issues are deemed to be relevant to the investment thesis. In addition, Portfolio Managers and Research Analysts meet on a quarterly basis to formally discuss how ESG Factors impact a selection of stocks that are currently held in client portfolios. Those selected for review have generally received either relatively low ESG ratings or ESG controversy scores (i.e., high levels of perceived controversy) from a third-party research firm. These meetings may or may not result in changes to an investment thesis with respect to an individual stock or changes to investment decisions in client portfolios.
Engagement
On occasion, an ESG Factor identified during financial analysis leads to the engagement of company management. Our engagement is consistent with our usual practice of seeking direct communication with the management teams of the stocks in our portfolios or stocks we are considering for investment. Direct discussions with management may provide insights into strategy, operations and competitive positioning, as well as ESG topics to the extent believed to be material to Frontier’s investment thesis. Corporate governance factors, for example, can be an indicator of the effectiveness of company management. The incorporation of sound business practices, including those defined as ESG Factors, often lead to improved long-term fundamentals and valuation.
Proxy Voting
In accordance with Frontier’s Proxy Voting Statement and Guidelines, Frontier, with the exception of Frontier Focus Strategy, has largely adopted the policy guidelines of its proxy agent and generally votes in accordance with the recommendations of the proxy vendor. There is one notable exception, however: where instructed by a client to vote proxies in accordance with the client’s socially responsible principles.
ESG Integration: Frontier Focus Strategy
Frontier’s integration of ESG Factors extends further with respect to the management of the Frontier Focus strategy. The Frontier Focus strategy pursues long-term capital appreciation by employing a Growth at a Reasonable Price approach to identify 40 or fewer U.S. small- and mid-capitalization equity companies that we believe offer attractive financial return potential. Our fundamental analysis includes a qualitative evaluation of ESG Factors and their potential impact on a company’s future financial performance and valuation as part of the investment decision-making process for all holdings in the Frontier Focus strategy.
Investment Process
Frontier’s ESG analysis for Frontier Focus reflects our qualitative assessments of companies and their implementation or anticipated adoption of what Frontier’s Research Analysts deem in their discretion to be appropriate ESG risk mitigation practices. For Frontier Focus, ESG risk mitigation practices are generally characterized by thoughtful financial risk management in light of the potential impact of ESG factors on the enterprise. Organizations that meet these standards typically exhibit good corporate governance and have superior leadership and executives who are properly incentivized, reduce the risk of harm to customers and workers and recognize the value of sustainable practices, each in the context of the particular industry or sector in which they operate. Companies with weak corporate governance, disclosure and regulatory practices, regardless of sector or industry, are disfavored.
While the Frontier Focus strategy does not use exclusionary screens based on industry or product in determining which stocks are eligible for potential investment, Frontier has historically avoided companies that employ what are deemed to be predatory lending or pricing practices, such as financial firms that charge usurious rates. Other examples of firms that generally do not meet Frontier’s ESG standards are those employing child or indentured labor and pharmaceuticals that produce or distribute, as a significant portion of their operations, the type of opioid medications that have been frequently associated with dependence or abuse.
The Focus investment team meets at least once a month or more frequently if needed to discuss the strategy’s investment performance, risk profile and ESG considerations, and makes investment decisions consistent with the strategy’s objective of achieving long-term capital appreciation.
Engagement
For the Frontier Focus strategy, engagement with company management on ESG issues occurs at least annually and more often when necessary. Where appropriate, Frontier seeks to discuss management’s approach to ESG issues and convey what we deem to be priorities and best practices. We do not disqualify a company from investment consideration based on specific targets or quantitative goals but we do expect management to have credible plans, which are appropriate for their industry or sector, to reduce their potential financial risks arising from ESG Factors. We also expect to see management make progress in implementing those plans. Notes on those engagement efforts are stored in Frontier’s proprietary research database.
Proxy Voting
Our ESG engagement efforts are supported by proxy voting. The Frontier Focus strategy investment team has developed and implemented a set of policy recommendations for voting on ESG-related issues, which is used as a guide for proxy votes cast on ballots for stocks held in the Frontier Focus strategy. Frontier’s ESG proxy voting recommendations are consistent with investors seeking enhanced investment return with a focus on disclosing and mitigating financial risk regarding ESG issues.
Governance
Frontier’s Management Committee approved the RI Policy, defined its scope and applicability and established an ESG Committee to oversee and be responsible for implementing the RI Policy. The ESG Committee is accountable for integrating ESG best practices into Frontier’s investment analysis. Investment professionals are responsible for applying the RI Policy to the extent that it is relevant to companies in their coverage and has the potential for material financial impact. The RI Policy is reviewed annually by the ESG Committee or more frequently, if appropriate.
ESG Training, Standards and Sources
Frontier’s investment analysis of ESG Factors relies on multiple standards and sources, including the SASB industry-specific standards, to evaluate financial material sustainability metrics for companies in a particular industry. Recognizing the ongoing evolution in the field of ESG investing and changes to standards and sources, Frontier’s investment team participates in periodic ESG education training on industry best practices within U.S. small and mid-cap equity investing.
Frontier’s analysis is supplemented by the work of two ESG ratings firms, MSCI and Sustainalytics. Research Analysts regularly review MSCI controversy scores and Sustainalytics ESG scores to identify ESG Factors and associated risks for companies that are held or are under investment consideration. ESG data from these two firms is included in our proprietary research database and updated daily, which can alert investment professionals to new ESG controversies and allow them to monitor stock trends in ESG ratings.
Definitions
The RI Policy supplements and should be read in conjunction with the Investment Management Agreement (including any investment guidelines therein) between Frontier and the client, as well as in conjunction with the applicable Prospectus, Confidential Private Offering Memorandum, Partnership Agreement, or other applicable governing disclosure document or agreement of the relevant Frontier Account (each, a “Governing Document”). In the event of a conflict between this RI Policy and the applicable Governing Document, the provisions of the applicable Governing Document shall control.
Updated July 2024