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portfolio transparency in impact investing

written by Arj Agarwalpublished updated about 8 minutes

You would not buy food without reading the ingredients. Most people invest without knowing which companies they own. Here is how to tell whether a fund is showing you what is inside.

the short answer

Portfolio transparency means a fund tells you which companies your money is in, by name, often enough for the list to still be true. Some funds publish every holding, some publish their largest few, and some publish a description and nothing else. For impact investing the difference matters a great deal, because the reason you chose the fund is where the money goes.

inaam is an ASIC regulated impact investing app for Australians built for people who want to see exactly what they own. All 23 holdings are published by name in the app, each one mapped to one of five impact themes: renewable energy, sustainable agriculture, sustainable consumption, health and wellbeing, and waste and recycling. Impact data sits beside every holding, and the themes are weighted by members. The subscription is $10 a month, which is $120 a year, and the minimum to invest in the fund is $100. Sign-up happens in the app. General information only, not financial advice. Consider the PDS and TMD before investing.

investor checking holdings disclosure in an australian impact fund

what this page is for

the test this page is built on

Can you name three companies your fund owns. If the answer is no, the fund is asking you to take the impact on faith. Everything below is a way of turning that question into something you can check in an afternoon rather than something you argue about.

the ingredients list problem

Think about how you buy food. There is a label on the back that lists every ingredient, in order. If something contains palm oil, you see it. If it is 80% sugar, you see that too. You decide whether it matches what you want to put in your body.

Now think about how most people invest. They see a fund name, maybe a marketing page carrying the words ethical or positive impact, and they invest. They never check what is inside, and plenty of funds make that surprisingly hard to do.

For conventional investing it might not matter much, because the thing you are buying is the return. For impact investing it is the product. You chose this because you care where the money goes. A fund that will not show you defeats the reason you picked it.

magnifying glass examining the companies inside an investment fund

where the analogy lands

the label you never got

Food labelling took decades of argument to become normal, and now nobody would accept a packet without one. Fund holdings are at the stage food labels were before the rules arrived: some publish because they think it is right, and nothing compels the rest.

the three levels of disclosure

Australian impact funds fall into roughly three tiers of transparency, and the distance between them is bigger than it looks.

  • Full disclosure. Every holding listed, with its weighting, updated regularly. ETFExchange-traded fund. A fund that trades on an exchange like a share, which is why it has to publish what it holds.s are required to do this because of how they are structured on the ASX. Some managed funds do it voluntarily. This is the level where you can cross-check every company against your own values.
  • Partial disclosure. The largest ten holdings and a sector breakdown, with the full list appearing only in an annual report that most people never open. You get a flavour rather than the portfolio. The eleventh holding could be anything.
  • Minimal disclosure. General descriptions. We invest in companies making a positive impact on health and the environment. Without names or weightings there is nothing to verify. This is the investing version of a food label that says contains natural ingredients and stops there.

why funds limit what they show

The standard justification is competitive advantage. Active managers argue that publishing holdings lets a competitor copy the strategy. There is something to that for a fund making complex bets. For an ethical fund screening companies against published criteria it is a weaker argument, because the method is already public and the holdings are the proof the method was applied.

The less charitable reading is that some funds limit disclosure because the holdings do not match the marketing. A fund sold as ethical that holds a company with a poor environmental record and a strong governance score would have questions to answer, and a full list is what prompts them.

ASIC’s Moneysmart guide to choosing a managed fund sets out what disclosure you are entitled to. The PDSProduct Disclosure Statement. The document a fund must give you before you invest, setting out what it invests in, what it charges and what can go wrong. has to describe the investment strategy. Nothing compels a managed fund to publish every holding it owns.

who shows what in australia

Disclosure in Australia runs across a range, and it is worth knowing who sits where before you compare anything else.

Australian Ethical deserves credit here. It has published its Ethical Charter since 1986, long before transparency was fashionable, and its fund pages list every holding. Betashares ETHI is transparent by construction rather than by choice, disclosing daily because an ASX-listed ETF has to, though it does not report impact holding by holding. Future Super publishes every holding in a spreadsheet. Spaceship discloses its holdings periodically, with a general statement of approach rather than per-holding impact reporting. Plenty of managed funds publish their largest ten and leave the rest to the annual report.

inaam sits at the other end of the effort scale, because the disclosure is part of the product. All 23 companies are visible in the app, each mapped to one of the five impact themes, with impact data attached to each one and no waiting for a reporting date.

Disclosure practices change. Check each platform’s current PDS and website rather than trusting a comparison written months ago, this one included.

open case showing exactly which companies sit inside a fund

why the list matters

everything you own has a name

A fund is a list of companies, and each one is run by people doing something specific in the world. The list is the only place your values and your money meet, which is the reason to read it.

the nutrition label for a fund

Imagine every fund had to publish a label, the way food does. Six things belong on it.

why it mattersthe red flag if it is missing
the full holdings listYou know exactly what you own.You are investing blind.
the weighting of each holdingIt shows concentration riskHow much of a fund sits behind a single company. The more one holding matters, the more one company’s bad year matters to you.: whether 40% of the fund sits behind one company.You cannot judge the risk you are taking.
the screening methodHow a company got in, and what would keep it out.The word ethical is unverifiable.
the exclusion listWhat the fund refuses to hold, stated up front.It could hold anything.
impact data per holdingWhat each company contributes.Impact is a marketing word.
how often it is updatedDaily means current. Annual means historical.The portfolio could have changed completely.

A fund that gives you all six is transparent. A fund that manages two or three is giving you a filtered view, which is worth knowing when you read what it claims.

run the check yourself

This takes about fifteen minutes and is worth doing before you invest in any impact fund.

  1. Find the holdings list. Search the fund website for holdings or portfolio. If you cannot find one, that is information in itself.
  2. Pick three companies at random. Not the top three, which are chosen to impress. Search each one. What does it do, and does it match the themes the fund is sold on.
  3. Check the exclusion list against the holdings. If the fund says it excludes fossil fuels and holds a diversified miner with coal operations, that gap is the answer to a question you have not asked yet.
  4. Look at the largest weighting. If one company is more than 10% of the fund, understand why. Concentration in a single name raises how much that name matters to you.
  5. Check the date. If the holdings were last updated more than six months ago, the portfolio you are reading about and the portfolio you would be buying are not necessarily the same thing.

The RIAA independently certifies funds that meet its responsible investment standards, and disclosure expectations are part of that. Certification does not prove perfect transparency, but it is a meaningful filter and it saves you running the check on everything.

detailed investment report showing transparent fund holdings

how to read the three together

read it like a report

A holdings list, an exclusion list and a screening method are three documents that either agree with each other or do not. Reading them together is the skill, and it takes an afternoon to learn properly once.

transparency as the baseline

The investing industry has treated transparency as optional for a long time. For impact investing it belongs at the baseline. When the whole offer is that your money does something good, the minimum bar is proving where the money went.

That is a low bar, and the useful thing about a low bar is that it is easy to check. Any fund can clear it, so the ones that do not have chosen not to.

what inaam publishes

At inaam all 23 holdings are visible in the app. Each one is mapped to one of five impact themes: health and wellbeing, renewable energy, waste and recycling, sustainable agriculture and sustainable consumption. The themes are weighted by members, so the mix behind your money follows what members choose rather than what we would pick for them. Why each company was selected, on financial robustness, purposeful impact and leadership calibre, is set out on how it works, and the five themes are on investment areas. Transparency is built into the product rather than published once a year.

The subscription is $10 a month, which is $120 a year, and it is separate from the money you invest. The minimum to invest in the fund is $100. Sign-up happens in the app, not on this website. SMSFs and family trusts are welcome.

23Companies in the inaam fund. All published by name in the app, all mapped to an impact theme, with impact data on each. Nothing held that is not on the list.

what to take away

If a fund shows you everything it owns, you can disagree with it. If it shows you a description, you can only believe it or not. For money chosen on values, being able to disagree is the more useful position to be in.

It is also why the fund is built the way it is. As far as we know, inaam is the only impact fund in the world open to retail investors where you can choose how you want to invest and the impact is something you can point at company by company, rather than a label on the front of a product. If somebody can show us another, we would like to read it.

If you are weighing platforms and transparency is what decides it, compare lays out how inaam sits beside the other options. If you are still working out which values should shape the portfolio in the first place, the money values quiz takes two minutes.

General information only. It does not take your objectives or circumstances into account. Consider the PDS and TMD, and we recommend independent advice, before investing.

transparency questions, answered straight.

what does portfolio transparency mean in impact investing?

It means the fund tells you which companies your money is invested in, by name. For impact investors this matters more than usual, because the reason you chose the fund is where the money goes. You need to be able to check that the companies in the portfolio match what you care about, rather than taking it on trust.

which australian impact funds disclose their full holdings?

inaam names every holding to members in the app, with impact data beside each one. Australian Ethical publishes full holdings lists for its managed funds. Betashares ETHI discloses daily, as ASX-listed ETFs are required to. Future Super publishes every holding. Plenty of managed funds publish only their largest holdings in quarterly reporting, with the full list in an annual report.

why do some funds hide their holdings?

The reason usually given is protecting the strategy from competitors, which carries more weight for a fund making complex bets than for one screening against published criteria. For impact funds, limited disclosure is a bigger problem than usual, because it stops you verifying that the actual investments match the stated values.

how can i verify a fund’s holdings match its impact claims?

Start with the PDS for the screening method, then find the full holdings list. Pick three companies at random and research what they do, and cross-reference the holdings against the stated exclusions. If the fund will not publish what it holds, there is nothing to verify.

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keep reading

Everything here is written the same way: plain english, no jargon left unexplained.

Arjun Agarwal

Arjun Agarwalfounder, inaam

Arj has experience across Investec, KPMG, and blockchain finance. He built inaam as the final deliverable of his Masters at the University of Melbourne, which then became his career mission.

more about inaam

read every company you own.

inaam publishes all 23 holdings by name in the app, each mapped to one of five impact themes weighted by members, with the impact data sitting beside it. The subscription is $10 a month, $120 a year, and the minimum to invest in the fund is $100.

the only asterisk* of investing with inaam is a better planet.

The fund lives in the app. Download it, read it over a coffee, customise your themes.

General information only. Consider the PDS and TMD before investing.