Section 172 statement

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The below statement relates to Insight Investment Management Ltd (IIML), Insight Investment Funds Management Ltd, Insight Investment Management (Global) Ltd and Insight Investment Services Ltd:

Under section 414 of the UK 2006 Companies Act (the “Act”), the Company is required to include a section 172 statement, describing how it has dealt with the matters set out in section 172 of the Act during the period in question. In addressing these matters, we would like to expand on the following: 

Business relationship with suppliers, customers and others

Insight considers our clients to be one of the most important stakeholders of our business model. In an environment where the needs of clients are rapidly evolving, Insight considers client engagement as a key element of promoting the success of the Company. Insight aims to achieve a deep understanding of clients’ needs. 

From the Greenwich Associates UK Investment Consultant Research study (the “Study”), Insight was voted the 2019 Greenwich Associates Quality Leader for ‘Overall U.K. Institutional investment Management Service Quality’ having achieved a high score based on positive citations from a significant number of institutional clients. A large part of Insight’s success stems from effective engagement with clients, an approach that is heavily endorsed by the Board.

Similarly, consultants are seen as a key source of success for the business. They typically act as advisors to pension schemes, insurance companies, wealth platforms and other types of financial institutions.  Insight’s consultant engagement continues to be very high, as evidenced by the 2019 Greenwich Consultant Survey. In the 2019 study, UK consultants surveyed ranked Insight first for Overall LDI Quality for the ninth consecutive year and first for Overall Fixed Income Quality for the sixth year running. 

Insight continues to engage with clients, either directly or via our network of consultants, in a deep and meaningful way using strategies and processes developed over several years to help find solutions that are of material value to our clients. 


Insight’s Payment Practices policy stipulates that the Company should aim to pay suppliers for their goods and services within 30 business days from the date of receipt of their invoices. The Company is satisfied that the bulk of invoices meet this target as reflected within Insight’s publicly available payment practice reports.

Insight recognises that key stakeholders can have a material impact on the long-term success of the business and so incorporates the interests of these stakeholders when making strategic long-term decisions. The Company believes that having due regard to the interests of its stakeholders is a dynamic and ongoing process which requires thoughtful monitoring and assessment.  

Employees (IIML only)

Another critical stakeholder is, of course, Insight’s staff base. New members of staff receive induction training and the opportunity to meet the CEO and the Head of Human Resources. This typically takes place a few weeks after joining Insight which gives new joiners the opportunity to review how Insight does things and make suggestions of how things could be improved, which is then taken on board by HR representatives. 

Insight is a strong believer in developing its staff. This is visible through the training programs available which are designed to encourage staff and manager development. 

Insight also operates a structured graduate scheme. For the period in question, the graduate scheme that was in progress included investment, business management and technology - key areas of the business. The graduate intakes will be rotating between different areas of the business for six months at a time between November 2019 and September 2020. 

Insight completed a staff survey during the period; the results showed a range of 80-89% of colleagues having confidence in the leadership of Insight, believing that Insight sets high standards of performance and that colleagues enjoyed working at Insight and would recommend Insight as a place to work with there being confidence in the long-term growth prospects of our business.

Insight recognises that diversity of thought, talent and experience is critical to the continued success of our business, industry and society. We understand that diversity is multi-dimensional, from national origin and disability, to gender and social background; it needs to be tackled all the way from school age all the way up to Board level; and we still have much to do in many areas if we want to make a difference at the industry level. Throughout the year, there have been multiple initiatives to push for greater diversity addressing education for culture, development, selection and leadership.

Impact on the community and environment

Insight’s Parent Company, BNY Mellon earned a position on the Climate Change ‘A List’ by CPD for the seventh year in a row in recognition of its efforts to cutting emissions, mitigating climate risks and developing the low carbon economy, all of which Insight are adopting.

Insight is committed to contributing to a sustainable world where people succeed and economies thrive. We do this by providing quality services to clients, supporting stability in a constantly changing world, and using our resources to deliver positive impact for stakeholders, communities and society. Some of our recent initiatives include moving to environmentally friendly printing, carbon neutral flights, reducing plastics in our offices and charity engagement.

During the period, Insight continued to review the various ESG working groups in addition to the formalisation of the CSR committee to ascertain how best the Company can play a meaningful role in these issues.

The Board are focusing on finding solutions to make key CSR/ESG activities embedded into the operations of the Company and for them to form part of the Company’s culture. 

High standards of business conduct

The directors recognise that as part of the objective to promote the success of the business, maintaining a high standard of business conduct when dealing with stakeholders such as regulatory bodies and vendors is vital.  Insight’s interactions with these stakeholders throughout the period are set out below.

Regulatory/Trade bodies

Due to the breadth of the business as well as Insight’s position in the market in which it operates, the Company recognises the importance of keeping up to date with industry regulations and best practices. To this end, the Company maintains regular interaction with key regulatory bodies such as the FCA and the CBI in Ireland.  Insight strives to maintain a flexible and open relationship with these and other regulatory bodies that have an interest in the Company’s operations.   

During the period, Insight has met with the FCA to discuss issues such as the cessation of LIBOR, Operational Resilience, levels of liquidity as well as Brexit.  Each meeting with regulatory bodies provides the Company with an opportunity to express how it is tackling various issues and gain some insight into the expectations from these bodies. 

In addition to this, as a way to represent its clients’ interests, Insight also has meaningful engagement with other key organisations such as the Bank of England, the Investment Association, ISDA Working Group and Pensions Europe. The Company has been active in forums held by key organisations to help tackle issues such as LIBOR replacement and clearing exemption for pension funds. 

Acting fairly between members of the company in a shareholder relationship

Insight’s Board of Directors includes representatives from its corporate shareholder BNY Mellon. It maintains an open relationship with BNY Mellon where ideas and strategic objectives are exchanged and shared. The Insight board is fully committed to ensuring that due regard is given to the interests of BNY Mellon as well as other stakeholders as described above.