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A Behavioural Insights Analysis of the Effects of Environmental, Social, and Governance Factor (ESG) Disclosure and Advertising by Investment Funds on Retail Investors

Executive Summary

Incorporating environmental, social, governance (ESG) factors into investment decision-making has become a key issue for capital markets and investor protection. This is marked by a number of factors including growth in assets under management of ESG investment funds, demands for ESG information when making investment decisions, and pressing sustainability objectives in the global economy. Notably, there has been rapid growth, followed by continued net inflows into ESG investment funds in Canada in the past few years.[1] However, these inflows bring challenges that may undermine investor protection and confidence in capital markets, such as greenwashing. Thus, it is imperative for regulators to examine the retail investor experience with respect to investing in ESG investment funds in order to further the mandate of investor protection.

Based on our review, we have noted that it is challenging for retail investors to evaluate the ESG component of investment funds for several reasons including:

  • Lack of standardized definitions of ESG factors
  • Lack of standardized methodologies to measure ESG factors
  • Lack of a definition of sustainability
  • Differences in ratings and rankings variables, and their understandability
  • Different values, beliefs, and motivations within retail investing
  • Behavioural challenges when investing

Disclosure related issues and the key concern of “greenwashing” have led securities regulators and international organizations to address these ongoing challenges. The International Sustainability Standards Board (ISSB) publication in June 2023 of their first two sustainability disclosure standards (S1 & S2) is an important milestone for the development of a global framework for sustainability disclosure. However, IFRS S1 and S2 will not enter into effect in Canada until given effect, with or without modifications, by the Canadian Sustainability Board, and then action is taken by the Canadian Securities Administrators (CSA) to establish disclosure rules in Canada.

In this report, we examine greenwashing in investment funds, which occurs when a fund’s disclosure or marketing intentionally or inadvertently misleads investors about the ESG-related aspects of the fund.[2] We also explore the retail investor experience in relation to ESG investment funds by examining their motivations and behaviours.

ESG Foundations

ESG refers to a collection of non-financial factors used to assess an organization or investment's practices and performance on various sustainability and ethical issues. Investors can consider ESG factors when investing, which can include identification of material risks, growth opportunities, and other normative goals. Despite no globally agreed upon taxonomy, ESG can be understood as:

  • Environmental: Issues relating to the quality and functioning of the natural environment and natural systems. This includes, but are not limited to, climate change, biodiversity, air and water pollution and natural resource management.
  • Social: Issues relating to the rights, well-being and interests of people and communities. This includes, but are not limited to, reconciliation with Indigenous Peoples, diversity and inclusion, data privacy and security, labour practices, supply chain management and human rights.
  • Governance: Issues relating to the governance of underlying companies and other investee entities. This includes, but are not limited to, board structure and independence, business ethics, executive compensation, and shareholder rights.

When retail investors make decisions to invest in ESG products, their selection of a fund may be influenced by the presence of ESG ratings or an ESG-related name. There are several organizations that provide quantitative measures to review ESG performance of companies. However, there is no standardized measurement of ESG factors. The volume of different types of ratings and rankings, their level of transparency, understandability, governance, and inconsistent terminology, have created challenges for stakeholders to navigate the ESG space.

ESG ratings and the data produced by ratings agencies can be one of several sources of information used by fund managers to develop ESG investment funds. The ratings generally use an approach that assesses the sustainability-related financial risks and opportunities to the company rather than measuring a company’s impact on the environment and/or society. These concepts are known as enterprise value vs impact value. These different frameworks may be misunderstood by retail investors and other users of ESG data and ESG ratings. For example, retail investors may review the ESG ratings for the company and assume an ESG rating is based on the company’s low carbon footprint (impact-value) when, in actuality, the rating reflects the company’s low risk exposure to climate change events (enterprise-value).

ESG products are built using financial, enterprise-value, and impact-value reporting, ESG ratings, and proprietary research. A spectrum of approaches is possible—from enterprise-value focused to impact-value focused—with many variances in between. There are five approaches commonly used to build ESG products: ESG integration, exclusionary screening, inclusionary screening, impact, and active (see Table i for descriptions of these approaches).

Table i: Spectrum of ESG investment themes

Objective

Integration ThemesDescription

Enterprise- value focused

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Table Arrow

Impact-value focused

ESG IntegrationIncorporates ESG data, alongside traditional financial analysis, into the securities election process.
Exclusionary Screening

Exclusionary screens can often be categorized as either values-based or norms-based.

Excludes, from the investment universe, companies, sectors, or countries involved in activities that do not align with the moral values of investors or with global standards.

Inclusionary Screening

Tilts portfolio toward one of following:

  • Best in class: companies outperforming peers in ESG measures.
  • ESG momentum: companies improving ESG measures more quickly than peers.
  • Thematic investing: companies solving specific ESG challenges (climate change, gender diversity, etc.). Tends not to leverage ESG ratings.[3]
ImpactTargets a measurable positive social and/or environmental impact. Investments are generally project specific and tend not to leverage ESG ratings.
Active (i.e., corporate engagement and stakeholder action)Entails engaging with companies and voting company shares on a variety of ESG issues to initiate changes in behaviour or in company policies and practices.

Source: CFA, PRI, State Street

Marketing of ESG Investment Funds

Fund managers use several vehicles to market products and provide information to retail investors. Typically, the following four channels are used:

  1. Push marketing (direct-to-consumer advertising) and press releases
  2. Product names and product labels
  3. Websites and retail outreach channels: fund manager and product branding/websites
  4. Fund documentation: prospectus, Fund Facts, fund factsheets, annual reports

Within these marketing vehicles, greenwashing is of serious concern. Greenwashing—defined by the CSA—occurs when a fund’s disclosure or marketing intentionally or inadvertently misleads investors about the ESG-related aspects of the fund.[4] The CSA Staff Notice 81-334 provided guidance to investment funds and their investment fund managers to “enhance the ESG-related aspects of the funds’ regulatory disclosure documents and ensure that the sales communications of such funds are not untrue or misleading and are consistent with the funds’ regulatory offering document.” The notice also states that “the name and investment objectives of a fund should accurately reflect the extent to which the fund is focused on ESG, where applicable, including the particular aspect(s) of ESG that the fund is focused on.”[5] In June 2024, new provisions were added to Canada’s Competition Act that explicitly target greenwashing, which require businesses to have testing or substantiation to support certain environmental claims.[6]

The inherent complexity of ESG information makes it challenging to test and validate claims made by fund managers. Thus, regardless of whether intentional or unintentional, ESG marketing claims have the risk of misleading retail investors.

ESG Investment Funds and Retail Investors

Our examination of the retail investor experience finds that retail investors' beliefs and attitudes towards ESG significantly influence their investment decisions when deciding to invest in funds. Depending on their beliefs and attitudes, retail investors may fall anywhere along the continuum between being financially-driven and values-driven. Financially-driven investors focus on reducing risks and increasing returns, while values-driven investors aim to create ESG-focused changes. Consequently, values-driven investors may accept lower returns and higher fees for investment funds with higher ESG ratings.

When deciding to invest in ESG investment funds, investors may examine product names, ESG ratings, and marketing materials. Product names can significantly influence decisions, as many retail investors may not look too far beyond them. Retail investors in ESG investment funds may have biases and use heuristics (i.e., mental shortcuts), leading them to rely on ESG ratings. Values-driven investors, in particular, may make investing decisions based on positive emotions rather than rational metrics.

A consideration of the mental shortcuts that people take such as biases and heuristics when designing policy or educational interventions can improve ESG investing decisions. Retail investors should strive to understand their own motivations, recognize the volume and quality of information, and be cautious of marketing tactics. Financial advisors play a crucial role in guiding retail investors through ESG investing by leveraging their financial literacy and product knowledge, though they may face similar challenges with complex ESG information. Supporting and strengthening advisors' proficiency in ESG knowledge is recommended to better support investors and navigate the ESG landscape effectively.[7]

The Experiment

The literature review on ESG retail investing was complemented by an experiment to examine retail investors’ attitudes, values, and intentions towards ESG investment funds. The purpose of this rigorous experiment is to support OSC in facilitating data-driven, evidence-based regulation. We used an experimental method known as a discrete choice experiment (DCE)—a scientifically robust technique that is used to understand individual preferences by presenting them with sets of hypothetical choices.

In our experiment, we asked participants to choose between two investment funds—with each choice having a total of 8 attributes displayed within a key fact sheet (See Table ii for description of attributes). Both choices include the same attributes, however, their levels (i.e., versions of the attributes) may differ, as they are randomly selected from a predetermined list. For example, while both choices will have a fund name, the names may differ, such as ESG Equity Fund or Sustainable Equity Fund. By examining participants’ choices, we can determine which attributes within an ESG investment fund drive the selection of ESG investment funds.

Table ii: The attributes included in our key fact sheet.

Attribute

Description

Fund NamesDraw attention to and/or build associations about the purported activities, strategies, or impacts of the fund.
Investment StrategiesArticulate to participants how the fund will be invested to meet its stated objectives.
ESG RatingsReflect assessments of a fund's exposure to ESG-related risk vis-a-vis the portfolio's holdings. Ratings were either represented visually (out of 5 stars), or with letters grades. We also presented some funds with no ratings as a comparison.
Rating ExplanationsInclude information about the meaning of the ESG rating.
Investment ObjectivesClarify the goals of the fund.
Risk ProfilesIndicate the volatility of the fund and is based on how much the fund’s returns have changed from year to year considering its holdings.
Past PerformanceProvide historical data on fund returns.
Management Expense Ratios (MERs)The total of the fund’s management fee (which includes any trailing commission) and its operating expenses.

 

A total of 961 retail investors participated in the experiment. Each participant was given a series of 12 choices between two key fact sheets with randomly selected levels of attributes and was asked to select which of the two funds they preferred. Following the experiment, participants completed a questionnaire on their attitudes towards investing and financial product ownership, and a demographic questionnaire.

Key Findings

  • The ESG rating stood out as one of the most important attributes influencing consumer choice—second only to a fund’s past performance.
  • The strength and format of the rating (letter grade and number of stars) were both impactful attributes.
    • Higher ESG ratings had more positive influence on fund selection than lower ESG ratings.
    • Star-rated funds had more positive influence on fund selection than letter-rated funds.
    • The absence of an ESG rating was preferred to some of the lower ESG ratings, suggesting that there is a threshold at which ESG ratings transition from a motivating factor to a deterrent.
  • Clustering—a data analysis method that organizes data into groups based on similarities—revealed two distinct segments of Canadian retail investors:
    • Both segments were similar in their demographics and in their assessment of fund name, past performance, fund objective, and risk profile. They differed in their valuations of fund investment strategies, ESG ratings, rating explanations, and MER.

Values-Driven Investors

Financially-Driven Investors

  • These investors are characterized by a stated willingness to trade returns for sustainable outcomes.

  • Values-driven investors were less responsive to ESG integration strategies than their financially-driven counterparts.

  • Values-driven investors were more responsive to an ESG rating of 4 stars than their enterprise-minded peers, while also being less likely to select a fund that lacks an ESG rating altogether.

  • Values-driven investors were generally less responsive to MER, being more likely to purchase funds with high MERs and less likely to prioritize funds with low MERs.

  • These investors are characterized by a focus on more traditional outcomes such as return-on-investment (ROI).

  • Financially-driven investors, in practice, displayed indistinguishable responses to all three of the strategies outlined as part of our DCE, while values-driven investors tended to discount ESG integration strategies.

  • The inclusion of a rating explanation was an influential attribute for financially-driven investors while being virtually irrelevant to the decision-making of values-driven investors. Financially-driven investors may have found the ESG ratings to be more valuable after understanding what the ratings represented.

 

  • Participants were not sensitive to mismatches between a fund’s more salient attributes (e.g., fund name) and its actual investment strategy. For example, participants were not sensitive to a misalignment in attributes such as fund name, “ESG Fund”, with the investment strategy “no ESG strategy”. This result suggests that Canadian retail investors may face risk from greenwashing of products available in the market.

The lack of standardization in ESG definitions and ratings is a critical issue that can lead to inadvertent and deliberate greenwashing. Even without deliberate greenwashing, ESG ratings can mislead retail investors, who believe they are investing in impactful companies aligned with their ESG values, when in fact they are often investing in ESG risks. It is unlikely that retail investors fully understand ESG ratings, yet these ratings are a particularly important factor when selecting ESG investment funds. The different types of ratings and lack of clarity around ratings allow manufacturers of these funds to potentially exploit investors’ tendency to rely on ESG ratings. Values-driven investors are particularly affected, as they are more willing to sacrifice returns, including higher MERs and potentially lower performance, to support funds they believe are making a positive impact. Based on these findings the OSC’s Research and Behavioural Insights Team recommends that stakeholders including authorities should incorporate the following to combat these challenges:

  1. Strive towards Clarity in ESG Definitions and Ratings
    • Clarity around or potential standardization of ESG ratings to eliminate confusion and prevent greenwashing. This will support ESG ratings that are consistent and comparable across different funds and products.
  2. Educate Investors
    • Improve retail investors’ understanding of ESG investing through education and outreach, including the differences between ESG risks and impacts, as well as being able to identify signs of greenwashing. This will empower investors to make decisions that truly align with their values.
  3. Strengthen Advisor Proficiency
    • Promote financial advisors training on ESG investing to better support their clients.

These findings are crucial as they help the OSC and stakeholders understand the influence of ESG factors on retail investment decision-making and behaviour, including susceptibility to greenwashing. Recognizing the diversity in retail investors’ preferences and behaviours is a key element in supporting informed decision-making.

 


[1] Morningstar (2024). Canadian Investors Stuck with ESG in 2023.

[2] Canadian Securities Administrators. (2022; revised 2024). CSA Staff Notice - 81-334 - ESG-Related Investment Fund Disclosure.

[3] This can often be treated as a separate strategy.

[4] Canadian Securities Administrators (2022; revised 2024). CSA Staff Notice - 81-334 - ESG-Related Investment Fund Disclosure.

[5] Canadian Securities Administrators (2022; revised 2024). CSA Staff Notice - 81-334 - ESG-Related Investment Fund Disclosure.

[6] Competition Bureau Canada (2024). Public consultation on Competition Act’s new greenwashing provisions.

[7] The Client Focused Reforms changes to Know-Your-Product (KYP) requirements require registered firms to assess and individuals to understand the relevant aspects of the securities that they are considering making available to clients. Firms are expected to have the appropriate skills and experience to perform the necessary assessment of all securities to be made available to clients. Additional training and/or proficiency requirements are necessary for their registered individuals to understand ESG securities and make appropriate suitability determinations. Please refer to National Instrument 31-103 and Companion Policy 31-103CP for additional details.

National Instrument 31-103 Registration Requirements, Exemptions and Ongoing Registrant Obligations and Companion Policy to NI 31-103 CP Registration Requirements, Exemptions and Ongoing Registrant Obligations

Overview

Environmental, social, governance (ESG) factors have become increasingly prominent within retail investing. There has been rapid growth, followed by continued net inflows into ESG investment funds in Canada in the past few years.[8] Consequently, it is imperative for regulators to examine the retail investor experience with respect to investing in ESG investment funds to further the mandate of investor protection.

In this research report, the Ontario Securities Commission seeks to better understand ESG factors within retail investing and their influence on retail investing behaviours. The goal of the research report is to provide a review of:[9]

  1. The definitions, measurements, and disclosures of ESG
  2. How fund companies integrate ESG into their products and marketing
  3. How retail investors approach the multi-dimensional nature of ESG investment funds when making investing decisions including assessing a product’s sustainability and performance
  4. The influence of ESG factors on retail investment decision making and behaviour

Report Structure

Prepared by the OSC, this report provides a high-level summary of key information contained within two reports resulting from our collaboration with PricewaterhouseCoopers (PwC) and The Decision Lab (TDL), respectively. This report contains a literature review and environmental scan on ESG and retail investing that was prepared by PwC in collaboration with OSC, and a behavioural science experiment also on ESG and retail investing that was prepared by TDL in collaboration with OSC.

 


[8] Morningstar (2024). Canadian Investors Stuck with ESG in 2023.

[9] Note that this is not a comprehensive review of ESG factors nor a compliance review of disclosures.

ESG Foundations

ESG Marketing

ESG and Retail Investors

Experiment

Conclusion

In this report, we examined how retail investors navigate the complicated and confusing ESG landscape. We discussed the key groups and their relationships within ESG retail investing, which include regulators, institutions, intermediaries, and retail investors. We noted that ESG information is not standardized, and that there are gaps in data, and information production methodologies are inconsistent and often opaque.

We discussed the role of fund managers within ESG retail investing, and the common strategies fund managers use to manufacture and market ESG products. Given the complexity of the ESG information landscape, some retail investors—especially less sophisticated investors—may rely on fund manager marketing to fill information gaps. This dependency and information asymmetry can leave retail investors vulnerable to confusion and/or misleading information. In addition, retail investors’ confidence in ESG may be negatively impacted by “greenwashing”, which can include exaggerated claims of ESG performance by companies and fund managers or exaggerated claims about the ESG focus or strategies of a fund.

As retail investors seek to invest in ESG investment funds, they must navigate complex information, while accounting for their own beliefs, attitudes, and motivations. Retail investors investing in ESG are likely to encounter a number of behavioural barriers and biases. Retail investors and their advisors should be aware of heuristics and biases to make better informed decisions. We have discussed several strategies to overcome these heuristics and biases.

During the retail investors’ behavioural experience, they may choose to invest, and thus, we examined and identified the key influences on fund selection through a scientific experiment. Within our experiment, there were several key findings of note. With regards to the varying formats in which ESG ratings are presented to retail investors, our experiment showed that retail investors are more positively influenced by graphical representations of ESG ratings (in this case, stars) compared to letter-grade rating (in this case, A to F). This suggests that retail investor decision-making may not only be swayed by the quality of the funds that they consider, but by the arbitrary way that information is presented. Establishing clear standards for the construction and communication of ESG ratings may thus be a crucial step in protecting investors and ensuring a fair competitive landscape.

Our experiment’s results also showed that investors may be susceptible to greenwashing. Retail investors were not sensitive to mismatches in the attributes, such as a mismatch between a fund name (e.g., “ESG”) and its investment strategy (e.g., No ESG Strategy), as these mismatches did not influence their selection of the funds. This suggests that retail investors may face risk from greenwashing of the products available in the market.

We also were able to identify different types of ESG investors. Of note, values-driven investors tend to conflate ESG with positive impact more than financially-driven investors. Retail investors that are values-driven are more likely to be influenced by ESG ratings in comparison to investors who are more focused on returns. In particular, values-driven retail investors may be willing to make some financial sacrifice (in the form of MERs) in exchange for a more sustainable portfolio or hold an erroneous belief that ESG investment funds require higher MERs.

Implications

The lack of standardization in ESG definitions and ratings is a critical issue that can lead to inadvertent and deliberate greenwashing. Even without deliberate greenwashing, ESG ratings can mislead retail investors, who believe they are investing in impactful companies aligned with their ESG values, when in fact they are often investing in ESG risks. It is unlikely that retail investors fully understand ESG ratings, yet these ratings are a particularly important factor when selecting ESG investment funds. The different types of ratings and lack of clarity around ratings allow manufacturers of these funds to potentially exploit investors’ tendency to rely on ESG ratings. Values-driven investors are particularly affected, as they are more willing to sacrifice returns, including higher MERs and potentially lower performance, to support funds they believe are making a positive impact. Based on these findings the OSC’s Research and Behavioural Insights Team recommends that stakeholders including authorities should incorporate the following to combat these challenges:

  1. Strive towards Clarity in ESG Definitions and Ratings
    • Clarity around or potential standardization of ESG ratings to eliminate confusion and prevent greenwashing. This will support that ESG ratings that are consistent and comparable across different funds and products.
  2. Educate Investors
    • Improve retail investors’ understanding of ESG investing through education and outreach, including the differences between ESG risks and impacts, as well as being able to identify signs of greenwashing. This will empower investors to make decisions that truly align with their values.
  3. Strengthen Advisor Proficiency
    • Promote financial advisors training on ESG investing to better support their clients.

In sum, these findings are crucial as they help the OSC and stakeholders understand the influence of ESG factors on retail investment decision-making and behaviour, including susceptibility to greenwashing. Recognizing the diversity in retail investors’ preferences and behaviours is a key element in supporting informed decision-making. As an empirically driven regulator, we will continue to further our understanding of retail investor behaviour and decision-making with respect to ESG factors, and to share our findings.

Authors

Ontario Securities Commission:

Matthew Kan
Senior Advisor, Behavioural Insights 
[email protected]

Marian Passmore
Senior Legal Counsel, Investor Office
[email protected]

Meera Paleja 
Program Head, Research and Behavioural Insights
[email protected]

Kevin Fine
Senior Vice President, Thought Leadership
[email protected]

 

Acknowledgements to:

PricewaterhouseCoopers (PwC)

The Decision Lab