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Review of KiwiSaver default provider arrangements: quick submissions

We received 231 submissions through our online portal. 198 can be viewed below. A further 33 submitters did not want their submissions published. Redactions have been made in accordance with the Official Information Act 1982, and the Privacy Act 1993.

Adam Crisp

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

Balanced - mixed portfolio 50% growth and 50% conservative. This will ensure people feel comfortable with it as a default option, without the issues of over investment in conservative funds.

Which fees option do you prefer and why?

Zero-fees for under 18s or people with low KiwiSaver balances (eg under $5,000 or $10,000), because the hardship for young people is great enough (housing crisis, climate crisis, social isolation) without adding fees on top also.

Should default funds be used to promote responsible investment? If yes, how should this be done?

Yes. Given that If NZ wants to maintain its clean green image, and avoid increasing the already occurring climate crisis, then we must divest from all oil, coal, gas extraction or energy use related investments. Criterion 4 is to support development of New Zealand’s capital markets that contribute to New Zealanders’ wellbeing. To continue investing such a large proportion of NZ's investments in greenhouse gas producing energy sources is in direct conflict with contributing to New Zealanders’ current and future wellbeing. The increasing financial instability of energy based investments that are based on oil, coal and gas and the risk of stranded assets is too great. Also having our kiwisaver fund supporting these climate-destabilising energy sources sends the wrong message internationally as to NZ's position on social and environmental issues, especially to our Pacific neighbours. Therefore, a certification scheme, indicating whether they are portfolios that all direct energy users are oil, coal and gas free or not is needed, and a default exclusion position is needed i.e. by default all funds are carbon, coal and gas energy source free, and only if someone actively Under this criteria, for instance, Fonterra would currently be excluded from default investment as they have coal-fired power plants for drying milk into powder.

How disruptive would it be for a person if their default provider changed?

It depends how it is managed. If it is an automated process with a notification letter that a person has a time period to notify that they stay with the provider if they wish to then disruption is minimal.

Any other feedback?

Investing is funds that support New Zealanders' current and future wellbeing, by being environmentally responsible, is essential to NZ's local and international reputation as well as to New Zealanders' wellbeing.

Ali Northern

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

I think default funds shouldn't be invested in the fossil fuel industry.

Which fees option do you prefer and why?

I support the adoption of Option 1 and think that the fossil fuel industry should be excluded from default fund portfolios, as investments in the fossil fuel industry pose a material, sociopolitical, repetitional, and financial risk to shareholders.

Should default funds be used to promote responsible investment? If yes, how should this be done?

Yes, by ensuring that default funds are only invested in climate-conscious, ethically acceptable businesses.

How disruptive would it be for a person if their default provider changed?

Not at all.

Any other feedback?

Alison Robins

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

Change the default Kiwisaver settings to a robust 'responsible investment' criteria, which uses sector exclusion policies in particular the exclusion of the fossil fuel, tobacco and alcohol industries (Option 1).

Which fees option do you prefer and why?

Should default funds be used to promote responsible investment? If yes, how should this be done?

Adopt a certification regime for all Kiwisaver providers so investment funds are transparent and accountable.

How disruptive would it be for a person if their default provider changed?

Any other feedback?

Alistair

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

Should have responsible investment option, and via hot links provide access to information in controversial companies and their links to the principal investment house. Controversial organizations for me include fossil fuel and mining companies with activities in notorious human rights hot spots like West Papua, Tibet, Xinxiang /Uighur land in China and Africa (Chad phosohate). Also our dairy corporations purchasing milk from non-compliant water users or importers of PKE from unsustainable, labour-abusing palm plantations. Or major timber companies importing Kwila or other rainforest timber or retailers importing and distribution dodgy products. Check with TRANSOARENCY INTERNATIONAL (NZ branch( for Best Practice ethical investment principles and detailed guidelines

Which fees option do you prefer and why?

After 6 years in Kiwisaver I have found my small investment, deliberately in cash, is not only charging excessive fees that negate the low interest, but that it allows no option for responsible investment & transparency. Therefore I intend to soon withdraw.

Should default funds be used to promote responsible investment? If yes, how should this be done?

Yes. Precisely as concisely stated by the 350.org submission, which I have just read.

How disruptive would it be for a person if their default provider changed?

Any other feedback?

It is good to see MBIE is catching up with the positive lead of many contemporary corporate CEOs, business leaders and ethical financial journalist to assume moral leadership and deploy decisive organisational capacity to shift the norms from an uninhibited frontier ethic of unlimited and often manifestly unethical exoansion, to a framework of peace, justice and sustainability. There should be explicit SDG investment options with reasons why they are recommended for responsible citizens.

Structure the investment platforms to allow, no, to *encourage* us all to act as citizens and not merely as consumers. The capital sector is in the spotlight in these rapidly changing times. Even the spokespersons for the US Round Table of CEOs are calling for accountability to society at large as well as shareholders (abc.net.au/rn/saturdayextra). "Lets do this" should not mean let's say and not do.

Anake Goodall

Organisation

Seed The Change | He Kākano Hāpai

In what capacity are you making this submission?

Consumer group or advocate

What is your feedback on the investment mandate options for default funds?

We fully support the submission of 350.org Aotearoa.

Specifically:

Change the default KiwiSaver settings to a robust ‘responsible investment’ criteria, which uses sector exclusion policies, in particular, the exclusion of the fossil fuel industry (Option 1).
Adopt a certification regime for all KiwiSaver providers, so investment funds are transparent and accountable so they cannot greenwash their way around responsible investments.

Which fees option do you prefer and why?

Should default funds be used to promote responsible investment? If yes, how should this be done?

Yes. Leaving people to opt out.

How disruptive would it be for a person if their default provider changed?

No biggie.

Any other feedback?

Now is the hour to be bold.

Andrew Haddleton

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

Stop investing in fossil fuels, arms, pharma, industrial dairy.

Invest in companies that will supply long-term products like renewable energy, natural medicinal treatments, specialist food growers.

Which fees option do you prefer and why?

The government sets the fee for default providers. This will keep an even platform, plus KiwiSaver providers, usually banks, make huge profits anyway.

Should default funds be used to promote responsible investment? If yes, how should this be done?

Stop investing in fossil fuels, arms, pharma, industrial dairy.

Invest in companies that will supply long-term products like renewable energy, natural medicinal treatments, specialist food growers.

How disruptive would it be for a person if their default provider changed?

I don't know. I imagine it's a simple transfer to a new provider.

Any other feedback?

Andrew Murphy

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

We sould only support funds that support the environment

Which fees option do you prefer and why?

Free

Should default funds be used to promote responsible investment? If yes, how should this be done?

Yes and electric cars

How disruptive would it be for a person if their default provider changed?

Any other feedback?

Andy Kenworthy

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

Which fees option do you prefer and why?

Should default funds be used to promote responsible investment? If yes, how should this be done?

Yes:

Adopt a certification regime for all KiwiSaver providers, so investment funds are transparent and accountable so they cannot greenwash their way around responsible investments.

How disruptive would it be for a person if their default provider changed?

Any other feedback?

Anna Berthelsen

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

I urge the government to change the default KiwiSaver settings and implement a robust criteria for ‘responsible investment’, which utilises negative-screening through sector exclusion policies, in particular, the exclusion of the fossil fuel industry.

Which fees option do you prefer and why?

Should default funds be used to promote responsible investment? If yes, how should this be done?

Material risk: The fossil fuel industry has over five times the amount of coal, oil, and gas than is safe to burn in order to curb temperature rise to 1.5C warming pre-industrial levels. Given the direct link between the fossil fuel industry’s business model and the impacts of climate change, investments in this industry pose a material risk for shareholders.

Financial risk: Failure to account for falling power prices, the rapid growth of renewable energy, flat or falling energy demand, and new emissions-control policies can result in coal, oil, and gas projects becoming stranded assets. Various fossil fuel products have entered structural decline, which by definition is a long-term shift that transcends cyclical ups and downs. Therefore, it is irresponsible for default KiwiSaver products, which in nature are long-term investments to invest in a high-risk industry, like the fossil fuel industry.

Reputational risk: The socio-political landscape is rapidly changing as the majority of New Zealanders report being concerned about climate change. There is increased scrutiny on government, investment fund providers, among other institutions to be accountable for their relationship to the fossil fuel industry and the emissions their finance is enabling. Notable social indicators signal the public’s disapproval of the fossil fuel industry that include the divestment movement, which globally has shifted over USD$11 trillion worth of investment portfolios away from the fossil fuel industry, the large mobilisations of students and supporters for School Strike for Climate, and the government’s signal policy to ban new offshore oil and gas permits.

Responsible investment with mandatory exclusion of the fossil fuel industry and a stable economy do not necessarily fall into conflict. Given the rate of climate breakdown and negative feedback loops in the Earth’s cooling systems, the government cannot afford to make compromises for the current economic model. The economy must be shifted and transformed to account for a fast and just transition away from fossil fuels. I urge the government to require mandatory exclusion of the fossil fuel industry in default Kiwisaver providers in order to signal this necessary shift.

I believe the duty to invest responsibly should fall on fund providers rather than Kiwisaver members. Given those fund providers have the economic literacy, access to information, and ultimately the decision-making over investments, there should be stricter policies in place to ensure fund providers are transparent and accountable to the public. For example, Partners for Carbon Accounting Financials have developed a model for the finance sector to accurately report on carbon emissions. This sort of reporting is effective because it holds the finance sector to account for its role in enabling fossil fuel projects to go ahead. I believe a reporting model like this would increase transparency and accountability.

How disruptive would it be for a person if their default provider changed?

Any other feedback?

Ultimately I am calling for two main things.

Adopt a certification regime for all KiwiSaver providers, so investment funds are transparent and accountable so they cannot greenwash their way around responsible investments.

Anna Percy

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

I do not have a view either way

Which fees option do you prefer and why?

I do not have any expertise on fees, though i personally support the limiting of fees on low balances even if this means higher fees on my (higher) balance.

I repeat the point made below that responsible investment should not impact noticeably on fees.

Should default funds be used to promote responsible investment? If yes, how should this be done?

I strongly support the option to prohibit default providers from investing in particular sectors. This must include robust criteria to exclude investment in the fossil fuel industry.

I have personally changed my Kiwisaver to an ethical option, but recognise that most New Zealanders have not done so, indeed many are still with their default provider. I believe the default option should be for New Zealanders to invest in things that are good for the future of New Zealand. This cannot include investment in the fossil fuels industry.

I also believe that over the long term that Kiwisaver funds will be invested, fossil fuel investments can only perform very poorly indeed.

I submit that responsible investment should be the default, without limiting individuals' scope to make their own active investment choices.

I do not accept that this will necessarily lead to higher fees. I can see how collecting this information has a cost, which any competent fund manager will be incurring already. I fail to see how disclosing this information can lead to a cost significant enough to have an impact on fees.

How disruptive would it be for a person if their default provider changed?

Hardly disruptive at all

Any other feedback?

Anna Williams

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

I endorse the prohibition of default providers from investing in particular sectors or industries or require them to meet certain certification standards. We must change the default settings to a robust 'responsible investment' criteria. This is critical in the current environment (and is only going to become more-so) - the fossil fuel industry MUST be excluded from these investment criteria. It would be morally indefensible for this not to happen.

Which fees option do you prefer and why?

I don't have a preference regarding which fee option. However, when shopping around for a different provider (once I realised what the default provider I had been with was investing my savings in - see below), I was struck by the difference in fees charged by different providers.

Should default funds be used to promote responsible investment? If yes, how should this be done?

Absolutely yes.

By changing the default settings to a robust 'responsible investment' criteria, which uses sector exclusion policies, in particular, the exclusion of the fossil fuel industry (i.e., the first option given for responsible investment in the consumer summary document).

Secondly, by adopting a certification regime for all Kiwisaver providers, so investment funds are transparent and accountable and so that the providers cannot 'greenwash' their way around responsible investments.

How disruptive would it be for a person if their default provider changed?

It wouldn't be disruptive at all. Speaking for myself - I didn't even think about who my default provider was for years, and then when I did think that I ought to check, I was horrified to find that I had unwittingly been contributing to the climate crisis by the funds that my default provider was investing my money into. It took a lot of research and time for me to find a Kiwisaver provider that would invest my savings into socially, morally, ethically and environmentally responsibly funds.

Any other feedback?

When I was working out which provider to change to, I was fed a 'greenwashed' line regarding indirect investment by a number of those I approached, about the funds that they invested in. Had I not been such a 'critical consumer' of information, I would have brought into the line. However, I didn't, and instead persisted until I found a provider that was straight-up and did not invest indirectly in those industries that I object to. My point is that many people do not have the time or distrust/recognition of 'spin' that I have, and so would have taken the 'greenwashed' line at face value.

Anonymous submitter 1

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

Which fees option do you prefer and why?

Should default funds be used to promote responsible investment? If yes, how should this be done?

I would like to see the default KiwiSaver fund be an ethical fund. That is to say, excluding investment in products such as weapons and tobacco that do harm and especially excluding investment in the fossil fuel industry.

How disruptive would it be for a person if their default provider changed?

Surely not more disruptive than run away climate change

Any other feedback?

Anonymous submitter 2

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

I think it should be an easy option for everyone to choose to not invest in the fossil fuel industry. It should be clear and simple to have default funds that do not invest in fossil fuels. It is unethical and currently, it is difficult for people to make this choice. It's the right thing to do.

Which fees option do you prefer and why?

Lower fares than fossil fuel funds

Should default funds be used to promote responsible investment? If yes, how should this be done?

350 Aotearoa also urge the government to adopt a wider certification regime, beyond default providers, to reinstate trust in KiwiSaver members and ensure transparency and accountability of fund providers in adhering to responsible investments.

We believe the duty to invest responsibly should fall on fund providers rather than Kiwisaver members. Given those fund providers have the economic literacy, access to information, and ultimately the decision-making over investments, there should be stricter policies in place to ensure fund providers are transparent and accountable to the public. For example, Partners for Carbon Accounting Financials have developed a model for the finance sector to accurately report on carbon emissions. This sort of reporting is effective because it holds the finance sector to account for its role in enabling fossil fuel projects to go ahead. I believe a reporting model like this would increase transparency and accountability.

How disruptive would it be for a person if their default provider changed?

not al all. Many people wouln't even notice and many people would actually earn more from their investments.

Any other feedback?

It's the right thing to do. Let's all work together to move New Zealand beyond fossil fuels

Anonymous submitter 3

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

Change the default KiwiSaver settings to a robust ‘responsible investment’ criteria, which uses sector exclusion policies, in particular, mandatory exclusion of the fossil fuel industry

Which fees option do you prefer and why?

Option 1

Should default funds be used to promote responsible investment? If yes, how should this be done?

Adopt a certification regime for all KiwiSaver providers, so investment funds are transparent and accountable so they cannot greenwash their way around responsible investments.

How disruptive would it be for a person if their default provider changed?

If for good reason, (with a capital G), then the longterm benefit would far outweigh the short term inconvenience. This simply needs to be well communicated.

Any other feedback?

It should be a given that our Kiwisavers can be trusted, that our money is being used ethically and where possible for positive and good investments.

Anonymous submitter 4

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

Life Stages seems much the best option for default providers, with information provided that it may not be the best option if you plan to use it for first home purchase withdrawal option.

Which fees option do you prefer and why?

Government to set fees. All other options open to be exploited by providers by setting higher fees so consumers gain no advantage.

Should default funds be used to promote responsible investment? If yes, how should this be done?

Definitely. All default funds should have transparent responsible investment criteria, using sector exclusions. Excluding the fossil fuel industry should be mandatory. Other sectors such as weapons and tobacco could also be excluded by some funds. Non-default funds should have to declare their areas of investment so people can make a broader ethical choice if they wish.

715,000 people have been put in default funds. 72% of New Zealanders expect that their investments are being made responsibly. The government has a responsibility to ensure that this is correct. These funds are supposed to help people save for a more secure future. It is unacceptable that they should be used in ways which contribute to the climate change crisis.

This is a two-fold opportunity for the government to show that it does take climate change very seriously. It can make sure these funds do not help support the fossil fuel industry, and it can use them instead to develop the country's resilience. (I do not have the necessary expertise to suggest how this is best done)

How disruptive would it be for a person if their default provider changed?

Not at all. They probably would not even notice. We are talking about changing their default provider not a provider that they have taken the time to consider and chosen.

Any other feedback?

Some may say that it should be a personal choice about how our savings are used, and not to be decided by the government. Some may value higher returns above ethical investment. But this is about only the default schemes, so personal choice is not restricted.

Anonymous submitter 5

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

I urge the government to require mandatory exclusion of the fossil fuel industry in default Kiwisaver providers in order to signal this necessary shift.

Which fees option do you prefer and why?

Change the default KiwiSaver settings to a robust ‘responsible investment’ criteria, which uses sector exclusion policies, in particular, mandatory exclusion of the fossil fuel industry (Option 1).
Adopt a certification regime for all KiwiSaver providers, so investment funds are transparent and accountable so they cannot greenwash their way around responsible investments.

Should default funds be used to promote responsible investment? If yes, how should this be done?

How disruptive would it be for a person if their default provider changed?

I do not believe this need be disruptive at all. Most people just care that there funds are secure and invested justly

Any other feedback?

Anonymous submitter 6

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

Would you please change the KiwiSaver setting changes to 'responsible investment'. I would like to exclude the fossil fuel industry, implicit in the climate crisis, as a potential investment.

Which fees option do you prefer and why?

Please adopt a certification criteria that is both transparent and accountable. I want to prevent KiwiSaver from investing in fossil fuels.

Should default funds be used to promote responsible investment? If yes, how should this be done?

See above. It's important that KiwiSavers can see clearly where their savings are invested.

How disruptive would it be for a person if their default provider changed?

I don't know.

Any other feedback?

Thank you for taking the time to read my submission.

Anonymous submitter 7

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

Option one.

Which fees option do you prefer and why?

Government sets the fee for default providers OR better still government becomes the 'provider' - making ethical decisions for its citizens and any fees return to government for the common good.

Should default funds be used to promote responsible investment? If yes, how should this be done?

YES, definitely! All investments should be ethical - armaments, tobacco, slavery etc ... and of course, including investment in the fossil fuel industry because of the direct links between fossil fuels and climate change and the limited time available to keep global warming at or below 1.5 degrees. The duty to invest responsibly should not lie with the fund providers. Government, being the initiator of the scheme should decide how this is done. eg: Partners for Carbon Accounting Financials have a model for the finance sector to accurately report on carbon emissions and this is effective, as it holds the finance sector to account for its role in climate change. Aotearoa should have a transparent, and accountable reporting model such as this.

How disruptive would it be for a person if their default provider changed?

The responsibility of ethical investment should not be left to Kiwisaver members. Government supported scheme, so Government must oversee the responsible investment of their funds. Most citizens do not have the knowledge to deal with the research etc that is involved in checking out their providers investments. It is the duty of government and providers to attend to this. Social-geo-political aspects also have to be considered - all funds must be ethical and avoid the climate crime elements. See above: Partners for Carbon Accounting Financials have a model etc. It is not fair to expect members to engage in financial decisions at this level. Even basic Financial literacy is shown to be wonting in Aotearoa.

Any other feedback?

As a grandparent I am extremely disturbed by the predictions of runaway climate change and the social and emotional suffering this will cause in the future. It is therefore imperative that providers withdraw all Kiwisaver investments from fossil fuels. The fossil fuels industry must be excluded from default fund portfolios. Reasons:

Direct link between fossil fuel industry's business model and the impacts of climate change
The material risks for shareholders of a declining industry and subsequent stranded assets.
Long-term investments in the clean energy industry are more likely to produce good returns .
The majority of NZers report their concern about climate change therefore default providers should not use Kiwisaver to further global warming. Our reputation as NZ’ers as well as increased scrutiny on Government must be considered as well as the well-being of New Zealanders and that of the world. Ethical investment is a global concern.
Young people are mobilizing to demand change and there is increasing awareness among the general public of future environmental risks (and opportunities).
A good indicator for change is consumer preference for responsible investment.
Kiwisaver is a Government backed scheme, therefore Government has a role in see that providers are transparent and accountable regarding ethical investment aligned with and supported by NZ Government.
The well-being of all of Aotearoa -Tangata te Whenua and Tangata o Tiriti.

Anonymous submitter 8

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

I support a balanced investment option as default

Which fees option do you prefer and why?

I support zero-fees for under 18s or people with low KiwiSaver balances (eg under $5,000 or $10,000) because this will encourage people to begin saving early and build an initial level of capital rapidly

Should default funds be used to promote responsible investment? If yes, how should this be done?

Responsible investment with mandatory exclusion of the fossil fuel industry and a stable economy do not necessarily fall into conflict.

Given the rate of climate breakdown and negative feedback loops in the Earth’s cooling systems, the government cannot afford to make compromises for the current economic model. The economy must be shifted and transformed to account for a fast and just transition away from fossil fuels. 350 Aotearoa urge the government to require mandatory exclusion of the fossil fuel industry in default Kiwisaver providers in order to signal this necessary shift.

How disruptive would it be for a person if their default provider changed?

I think the benefits of having a better default provider outweigh any disruption due to a change in provider

Any other feedback?

We believe the duty to invest responsibly should fall on fund providers rather than Kiwisaver members. Given those fund providers have the economic literacy, access to information, and ultimately the decision-making over investments, there should be stricter policies in place to ensure fund providers are transparent and accountable to the public. For example, Partners for Carbon Accounting Financials have developed a model for the finance sector to accurately report on carbon emissions. This sort of reporting is effective because it holds the finance sector to account for its role in enabling fossil fuel projects to go ahead. 350 Aotearoa believe a reporting model like this would increase transparency and accountability.

Anonymous submitter 9

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

I prefer the life-stages option as providing the greatest return over time with automatic adjustments with age but with clear messages in simple plain English that if people plan to withdraw to use their funds early they should switch to conservative. Clear instructions should be given on how to do this and the process should be simple.

Which fees option do you prefer and why?

Fixed fees at the lower level. To contribute to affordability for low income people.

Should default funds be used to promote responsible investment? If yes, how should this be done?

Yes. By requiring that the investment is transparent and ethical, not just pretend ethical, and that the reasons behind the investment strategy are clear. I want fossil fuels to be excluded because we already have five times the amount of coal oil and gas than is safe to burn in order to curb temperatures to 1.5C warming pre- industrial levels, posing a material, but also a sociopolitical and financial risk to shareholders.

How disruptive would it be for a person if their default provider changed?

In my experience not disruptive. I have recently shifted my Kiwisaver funds on ethical grounds away from an ANZ fund to Simplicity. The process was simple and transparent.

Any other feedback?

No.

Anonymous submitter 10

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

Which fees option do you prefer and why?

Should default funds be used to promote responsible investment? If yes, how should this be done?

How disruptive would it be for a person if their default provider changed?

Any other feedback?

Ultimately I am calling for 2 main things:

Adopt a certification regime for all KiwiSaver providers, so investment funds are transparent and accountable so they cannot greenwash their way around responsible investments.

Anonymous submitter 11

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

Which fees option do you prefer and why?

Should default funds be used to promote responsible investment? If yes, how should this be done?

How disruptive would it be for a person if their default provider changed?

Any other feedback?

Ultimately I am calling for 2 main things:

Change the default KiwiSaver settings to a robust ‘responsible investment’ criteria, which uses sector exclusion policies, in particular, mandatory exclusion of the fossil fuel industry (Option 1).
Adopt a certification regime for all KiwiSaver providers, so investment funds are transparent and accountable so they cannot greenwash their way around responsible investments.

Anonymous submitter 12

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

Which fees option do you prefer and why?

Should default funds be used to promote responsible investment? If yes, how should this be done?

How disruptive would it be for a person if their default provider changed?

Any other feedback?

Ultimately I am calling for 2 main things:

Adopt a certification regime for all KiwiSaver providers, so investment funds are transparent and accountable so they cannot greenwash their way around responsible investments.

Anonymous submitter 13

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

The 4 options are good idea, keeps it relatively simple but leaves people choice. There maybe should be an age or income guide to help people make choices, and maybe a rule whereby there is mandatory review of their option status every five years, by their provider. If they don't make an active choice then maybe they should go default into the risk band most suited to their age group.

Which fees option do you prefer and why?

I prefer option 3, get people into it early and make it easy. Its better for the richer people in the long run if they can help everyone get ahead.

If fees very a lot and unreasonably, maybe the govt should apply a fee range depending on the type of investment. Still gives room for provider choice

Should default funds be used to promote responsible investment? If yes, how should this be done?

Absolutely. The fossil fuel industry be excluded from default fund portfolios, as investments in the fossil fuel industry pose a material, sociopolitical, reputational, and financial risk to shareholders. They drive the ongoing crazy self harm situation that humanity is in.

Also transparency is key - if companies are involved in armaments and such like, this should also be visible to shareholder.

How disruptive would it be for a person if their default provider changed?

Not sure but probably most people wouldn't even notice and its for their benefit anyway - and presumably they will have been given opportunity to have a choice?

Any other feedback?

Anonymous submitter 14

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

Which fees option do you prefer and why?

Should default funds be used to promote responsible investment? If yes, how should this be done?

How disruptive would it be for a person if their default provider changed?

Any other feedback?

Ultimately I am calling for 2 main things:

Change the default KiwiSaver settings to a robust ‘responsible investment’ criteria, which uses sector exclusion policies, in particular, mandatory exclusion of the fossil fuel industry (Option 1).
Adopt a certification regime for all KiwiSaver providers, so investment funds are transparent and accountable so they cannot greenwash their way around responsible investments.

Anonymous submitter 15

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

Why, if we're trying to move to a cleaner future are we aiding the dirty fuel methods, and having the majority of Kiwisaver funds invested badly. I moved mine, years ago, to an ethical fund and am so pleased. IT's sad that this cannot be a standard.

Which fees option do you prefer and why?

An ethical and environmentally investment.

Should default funds be used to promote responsible investment? If yes, how should this be done?

Yes, why would we want the everyday person having their investment put towards arms, fossil fuels, pornography.

How disruptive would it be for a person if their default provider changed?

Not disruptive. Most don't even know who they're with.

Any other feedback?

Let's make a positive change. You have the power to move NZ in the right direction.

Anonymous submitter 16

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

Option 1 is the most logical, ethical and appropriate of these options.

Which fees option do you prefer and why?

Option 1, if Kiwi saver is about providing New Zealanders with adequate economic security and welfare, then considering how harmful activities by the fossil fuel industry interplay with financial investments is key. The need to secure a safe, equitable future is not compatible with a financial operation which supports the fossil fuel industry's ongoing corruption.

Should default funds be used to promote responsible investment? If yes, how should this be done?

Absolutely. Creating stricter criteria for who is allowed to be a recipient of default fund portfolios is critical, with the fossil fuel industry needing to be kept out of profiting on behalf of peddling the climate crisis. Partners for Carbon Accounting Financials offer an interesting means of how the finance sector can be audited and made known to kiwisaver members, in terms of their ethical credentials.

How disruptive would it be for a person if their default provider changed?

As long as the information was clearly laid out in terms of how these changes would impact on one's kiwi saver then I find that this would lead to minimum disruption. Preempting this disruption and offering ample information dissemination would also help with this.

Any other feedback?

Anonymous submitter 17

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

Which fees option do you prefer and why?

Should default funds be used to promote responsible investment? If yes, how should this be done?

I support the submission of 350 Aotearoa, namely the adoption of Option 1. The fossil fuel industry be excluded from default fund portfolios, as investments in the fossil fuel industry pose a material, sociopolitical, reputational, and financial risk to shareholders.

How disruptive would it be for a person if their default provider changed?

Any other feedback?

I support the submission of 350 Aotearoa and also urge the government to adopt a wider certification regime, beyond default providers, to reinstate trust in KiwiSaver members and ensure transparency and accountability of fund providers in adhering to responsible investments.

Anonymous submitter 18

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

I am no expert on this, but I feel that we must reduce our reliance on fossil fuels and that, ultimately, the future of fossil fuels will fall into doubt due to growing concerns about climate change.

It therefore seems folly to invest in an industry whose future is uncertain. From this point of view, I'm not keen to see my Kiwisaver funds invested in what surely must become a sunset industry.

On top of that, ethically I would never choose to invest in this sector and therefore I don't wish my funds to be invested there at all and don't want to be continually comparing providers and their approach to investment. I'm not sure I understand the question completely, but I think this is asking whether we should or shouldn't give the providers a mandate to invest where they like for default funds (and I'm also assuming this is in the case where you have not chosen a specific provider yourself).

Which fees option do you prefer and why?

I think I prefer that the Government sets the fee for default providers. I know this might be hard to determine but I think that Kiwisaver's goal is to provide security for people in retirement and that the less variability and more security around fees the better. This is possibly a more level playing field in my view. I don't like providers having the ability to keep passing on costs.

Should default funds be used to promote responsible investment? If yes, how should this be done?

This question relates to what I wrote above. We owe it to all New Zealanders to invest responsibly and specifically not to invest in fossil fuels. I'm also keen to ensure funds do not get invested in weapons or other unethical/anti-humanitarian sectors). Therefore, the first option of prohibiting providers from investing in particular sectors is the one I would support.

How disruptive would it be for a person if their default provider changed?

I'm not sure I can answer this. I think for many New Zealanders (myself included), I tend to just sit back and watch my Kiwisaver do what it's going to do. It's pretty easy to make changes within the scheme in my opinion. However, I understand that everyone is different and for some people there might be a small degree of disruption.

Any other feedback?

No.

Anonymous submitter 19

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

Default funds must be invested responsibly, regardless of of which investment strategy is used. Our national investments must meet the highest ethical standard possible. In particular, it is imperative that the fossil fuel industry is completely excluded from default fund portfolios.

Fund providers should be required to meet strict policies on transparency, accountability, and responsible investment. People expect their money to be invested ethically and responsibly. It is not possible for all Kiwisaver members to stay completely up to date with all portfolio information, or have 100% consensus on whether industries such as munitions manufacturers should receive KiwiSaver investment. Therefore, the highest ethical standard should be the default.

Which fees option do you prefer and why?

I support Zero-fees for under 18s or people with low KiwiSaver balances (eg under $5,000 or $10,000). I would also support government-mandated fees for default providers. My priority is ensuring those with low balances are not discouraged from contributing.

Should default funds be used to promote responsible investment? If yes, how should this be done?

Yes, as noted above. Default fund portfolios should have the highest ethical standard possible so that all KiwiSaver members can feel comfortable with where their money is invested. Should some members wish to invest in controversial industries, they can elect to do so through other funds.

Default fund portfolios should use sector exclusion policies to screen out unethical investments, including but not limited to:

the fossil fuel industry
firearms and weapons industries
tobacco
alcohol

How disruptive would it be for a person if their default provider changed?

Not disruptive at all if changes are communicated well in advance, giving people the opportunity to decide whether the new default provider meets their needs.

Any other feedback?

Anonymous submitter 20

Organisation

In what capacity are you making this submission?

Other

What is your feedback on the investment mandate options for default funds?

Which fees option do you prefer and why?

Should default funds be used to promote responsible investment? If yes, how should this be done?

Yes.

Adopt a certification regime for all KiwiSaver providers, so investment funds are transparent and accountable so they cannot greenwash their way around responsible investments.

How disruptive would it be for a person if their default provider changed?

Any other feedback?

Anonymous submitter 21

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

Which fees option do you prefer and why?

Should default funds be used to promote responsible investment? If yes, how should this be done?

How disruptive would it be for a person if their default provider changed?

Any other feedback?

Ultimately I am calling for 2 main things:

Adopt a certification regime for all KiwiSaver providers, so investment funds are transparent and accountable so they cannot greenwash their way around responsible investments.

Anonymous submitter 22

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

Which fees option do you prefer and why?

Should default funds be used to promote responsible investment? If yes, how should this be done?

How disruptive would it be for a person if their default provider changed?

Any other feedback?

Ultimately I am calling for 2 main things:

Adopt a certification regime for all KiwiSaver providers, so investment funds are transparent and accountable so they cannot greenwash their way around responsible investments.

Anonymous submitter 23

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

Change the default KiwiSaver settings to a robust ‘responsible investment’ criteria, which uses sector exclusion policies, in particular, mandatory exclusion of the fossil fuel industry

Which fees option do you prefer and why?

I prefer a range from 3% to 15% as I personally have changed my rate according to my current income. I consider it important to have the flexibility to increase or decrease according to current circumstances

Should default funds be used to promote responsible investment? If yes, how should this be done?

Adopt a certification regime for all KiwiSaver providers, so investment funds are transparent and accountable. I hate not knowing if my KiwiSaver funds are supporting armaments etc

How disruptive would it be for a person if their default provider changed?

If there is adequate advance notification, this could be altered if the person preferred to remain with their current provider ie the same bank they use for everyday transactions

Any other feedback?

I think it's imperative that NZ moves to a transparent system where KiwiSaver investors can see exactly what their savings is supporting. It is lamentable that there has been a lack of ethical KiwiSaver schemes and this will redress the ethical dilemma of having to decide whether to save for retirement in schemes which fund fossil fuels & armaments etc

Anonymous submitter 24

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

Change the default KiwiSaver settings to a robust ‘responsible investment’ criteria, which uses sector exclusion policies, in particular, mandatory exclusion of the fossil fuel industry

Which fees option do you prefer and why?

Option 1 Has the best balance and should also set the maximum % fee charged.

And option 5 to help and encourage younger saving incentives to set good habits for the future

Should default funds be used to promote responsible investment? If yes, how should this be done?

How disruptive would it be for a person if their default provider changed?

Most would not notice, I am in a default and while I don't like it as they cant tell me if they are a 'responsible investment' also could not tell me who i could change to that was. It's such a small amount i don't really care.

Any other feedback?

Anonymous submitter 25

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

I support the adoption of Option 1 and would like the fossil fuel industry to be excluded from default fund portfolios, as investments in the fossil fuel industry pose a material, sociopolitical, reputational, and financial risk to shareholders.

Which fees option do you prefer and why?

Should default funds be used to promote responsible investment? If yes, how should this be done?

I believe that the default funds should follow robust criteria for ‘responsible investment’, which utilises negative-screening through sector exclusion policies - most essentially, the exclusion of the fossil fuel industry. The fossil fuel industry poses a material, sociopolitical, reputational, and financial risk to shareholders.

How disruptive would it be for a person if their default provider changed?

Any other feedback?

I believe the government should institute a wider certification regime, beyond default providers, to ensure transparency and accountability of fund providers in adhering to responsible investments.

Anonymous submitter 26

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

Kiwisaver fund providers should be excluding harmful investments by default and instead prioritise responsible investments. Providers are better equipped to make these decisions than most people.

Which fees option do you prefer and why?

Option One, removing harmful investments including fossil fuels because the impacts of climate change are a pressing issue.

Should default funds be used to promote responsible investment? If yes, how should this be done?

Yes, through renewable investments added by default. Additionally, to give users more control, to be able to include and exclude certain investments easily.

How disruptive would it be for a person if their default provider changed?

Not very, as long as enough notice is provided.

Any other feedback?

Anonymous submitter 27

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

350 Aotearoa urge the government to change the default KiwiSaver settings and implement a robust criteria for ‘responsible investment’, which utilises negative-screening through sector exclusion policies, in particular, the exclusion of the fossil fuel industry.

350 Aotearoa support the adoption of Option 1 and advise that the fossil fuel industry be excluded from default fund portfolios, as investments in the fossil fuel industry pose a material, sociopolitical, reputational, and financial risk to shareholders.

Which fees option do you prefer and why?

Should default funds be used to promote responsible investment? If yes, how should this be done?

Responsible investment with mandatory exclusion of the fossil fuel industry and a stable economy do not necessarily fall into conflict. Given the rate of climate breakdown and negative feedback loops in the Earth’s cooling systems, the government cannot afford to make compromises for the current economic model. The economy must be shifted and transformed to account for a fast and just transition away from fossil fuels. 350 Aotearoa urge the government to require mandatory exclusion of the fossil fuel industry in default Kiwisaver providers in order to signal this necessary shift.

We believe the duty to invest responsibly should fall on fund providers rather than Kiwisaver members. Given those fund providers have the economic literacy, access to information, and ultimately the decision-making over investments, there should be stricter policies in place to ensure fund providers are transparent and accountable to the public. For example, Partners for Carbon Accounting Financials have developed a model for the finance sector to accurately report on carbon emissions. This sort of reporting is effective because it holds the finance sector to account for its role in enabling fossil fuel projects to go ahead. 350 Aotearoa believe a reporting model like this would increase transparency and accountability.

How disruptive would it be for a person if their default provider changed?

Any other feedback?

Anonymous submitter 28

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

Default funds should not be permitted to invest in fossil fuel companies.

All Kiwisaver providers should be obliged to list any investments in the fossil fuel industry.

Which fees option do you prefer and why?

No opinion

Should default funds be used to promote responsible investment? If yes, how should this be done?

Yes, they should be used to promote investment in companies that are trying to mitigate climate change.

How disruptive would it be for a person if their default provider changed?

Any other feedback?

Anonymous submitter 29

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

Change the default KiwiSaver settings to a robust ‘responsible investment’ criteria, which uses sector exclusion policies, in particular, the exclusion of the fossil fuel industry (Option 1).

Adopt a certification regime for all KiwiSaver providers, so investment funds are transparent and accountable so they cannot greenwash their way around responsible investments.

Which fees option do you prefer and why?

Set by the government. Fair & level playing field. Financial products are very complex & hard for individuals to work out the total fees.

Should default funds be used to promote responsible investment? If yes, how should this be done?

Yes, responsible from an environmental impact point of view. No investment in fossil fuels.

How disruptive would it be for a person if their default provider changed?

Not much. Kiwisaver is a long term investment.

Any other feedback?

Anonymous submitter 30

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

Prefer life-stages option, or balanced. Should definitely change away from conservative.

Which fees option do you prefer and why?

Government should set the fee and find mechanism/transparency to ensure providers don't compensate in other ways.

Should default funds be used to promote responsible investment? If yes, how should this be done?

100% emphatically yes. should be ethical and environmentally responsible investment. NO weapons. NO fossil fuels. Require certification standards for transparency and accountability.

good idea to support NZ based growth but should not restrict to this. I like the concept of a proportion invested in early-stage NZ businesses.

How disruptive would it be for a person if their default provider changed?

not sure.

Any other feedback?

Anonymous submitter 31

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

I support the adoption of Option 1 and advise that the fossil fuel industry be excluded from default fund portfolios, as investments in the fossil fuel industry pose a material, sociopolitical, reputational, and financial risk to shareholders. I further more suggest that all default fund portfolios exclude investments in other unethical enterprises such as armaments, nuclear power, pornography, and non-medical drugs.

Which fees option do you prefer and why?

Should default funds be used to promote responsible investment? If yes, how should this be done?

Yes. The default fund portfolios should only include responsible investments. When it comes down to what is considered responsible investment I suggest that three things be taken into account:

Material risk: The fossil fuel industry has over five times the amount of coal, oil, and gas than is safe to burn in order to curb temperature rise to 1.5C warming pre-industrial levels. Given the direct link between the fossil fuel industry’s business model and the impacts of climate change, investments in this industry pose a material risk for shareholders.
Financial risk: Failure to account for falling power prices, the rapid growth of renewable energy, flat or falling energy demand, and new emissions-control policies can result in coal, oil, and gas projects becoming stranded assets. Various fossil fuel products have entered structural decline, which by definition is a long-term shift that transcends cyclical ups and downs. Therefore, it is irresponsible for default KiwiSaver products, which in nature are long-term investments to invest in a high-risk industry, like the fossil fuel industry.
Reputational risk: The socio-political landscape is rapidly changing as the majority of New Zealanders report being concerned about climate change. There is increased scrutiny on government, investment fund providers, among other institutions to be accountable for their relationship to the fossil fuel industry and the emissions their finance is enabling. Notable social indicators signal the public’s disapproval of the fossil fuel industry that include the divestment movement, which globally has shifted over USD$11 trillion worth of investment portfolios away from the fossil fuel industry, the large mobilisations of students and supporters for School Strike for Climate, and the government’s signal policy to ban new offshore oil and gas permits.

How disruptive would it be for a person if their default provider changed?

At the moment the default KiwiSaver scheme is super easy, so I can't imagine the provider changing being a disruption, as long as it is smoothly managed to make the transition with little asked of the individual.

Any other feedback?

I also urge the government to adopt a wider certification regime, beyond default providers, to reinstate trust in KiwiSaver members and ensure transparency and accountability of fund providers in adhering to responsible investmentsI believe the duty to invest responsibly should fall on fund providers rather than Kiwisaver members. Given those fund providers have the economic literacy, access to information, and ultimately the decision-making over investments, there should be stricter policies in place to ensure fund providers are transparent and accountable to the public. For example, Partners for Carbon Accounting Financials have developed a model for the finance sector to accurately report on carbon emissions. This sort of reporting is effective because it holds the finance sector to account for its role in enabling fossil fuel projects to go ahead. I believe a reporting model like this would increase transparency and accountability.

Anonymous submitter 32

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

I'm happy for this to sit at the conservative level - I would personally never invest in a riskier fund myself, and believe this decision needs to be an active one on the Kiwisaver owner's account, failing which they will automatically sit at a safer level.

Which fees option do you prefer and why?

Government sets fees for default schemes - on the basis that the government has contracted the providers and has some right/responsibility in this area.

Should default funds be used to promote responsible investment? If yes, how should this be done?

Absolutely - a combination of both approaches, i.e. investment in certain sectors (such as weapons, polluting industries, etc.) should be prohibited and Kiwisaver owners also need to be given clear information on precisely where their money is being invested to help them make informed choices on whether they're in the best scheme.

How disruptive would it be for a person if their default provider changed?

Assuming that processes are in place to ensure a seamless transfer and clear and timely communication to the customer, it shouldn't be disruptive at all.

Any other feedback?

Thanks :)

Anonymous submitter 33

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

Default funds should have both a balanced and ethical mandate.

A balanced mandate seems the best way to ‘balance’ the risk for those first home buyers against the longer term benefits of higher returns.

As owning a home is becoming increasingly difficult for younger generations of New Zealanders, the focus of the default funds as a priority should be to maximise returns for individuals at the age of retirement.

Which fees option do you prefer and why?

Fees make such a big impact on returns over time. Fees for default funds should be low and set by the government for all default providers.

The maximum default fund fee level should be set at 1%.

Should default funds be used to promote responsible investment? If yes, how should this be done?

All default funds should have a mandate to be ethical and sustainable. Default providers should be prohibited from investing in particular sectors and industries (especially fossil fuels, weapons, tobacco, palm oil and companies wth questionable human rights and environmental violations).

All providers should be required to give members standard information in relation to their responsible investment practices, so that members can make informed decisions about whether to stay in the fund.

How disruptive would it be for a person if their default provider changed?

Any other feedback?

Anonymous submitter 34

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

Which fees option do you prefer and why?

Should default funds be used to promote responsible investment? If yes, how should this be done?

I support the adoption of the first option: "Prohibit default providers from investing in particular sectors or industries or require them to meet certain certification standards.

I ask that the government implement robust criteria for responsible investment that use negative-screening through sector exclusion policies - in particular, the exclusion of the fossil fuel industry.

I urge the government in the strongest possible terms to exclude the fossil fuel industry from default fund portfolios. Investing for the future in an industry that is actively destroying that future is nonsensical and deeply immoral. Moreover, it is unacceptably risky. Investments in the fossil fuel industry pose a whole raft of risks, including:

Material risk: The fossil fuel industry has over five times more coal, oil, and gas than is safe to burn in order to limit temperature rise to 1.5C warming pre-industrial levels. Given the direct link between the fossil fuel industry’s business model and the impacts of climate change, investments in this industry pose a material risk for shareholders.
Financial risk: Failure to account for falling power prices, the rapid growth of renewable energy, flat or falling energy demand, and new emissions-control policies could result in coal, oil, and gas projects becoming stranded assets. Various fossil fuel products have entered structural decline, which by definition is a long-term shift that transcends cyclical ups and downs. KiwiSaver is by its nature a long-term investment, so it is irresponsible for default KiwiSaver schemes to invest in a high-risk industry like the fossil fuel industry.
Reputational risk: The socio-political landscape is rapidly changing as the majority of New Zealanders report being concerned about climate change. There is increased scrutiny on government, investment fund providers, and other institutions to be accountable for their relationship to the fossil fuel industry and the emissions their finance is enabling. The public's disapproval of the fossil fuel industry has been clearly signalled, for example in the divestment movement, which globally has shifted over USD$11 trillion worth of investment portfolios away from the fossil fuel industry; the large mobilisations of students and supporters for School Strike for Climate; and in the government’s own policy to ban new offshore oil and gas permits.

It is clear that New Zealanders are concerned about climate change and want to do something about it. Unfortunately, individuals' capacity to align their Kiwisaver with their expressed values is limited by availability; there is a disappointing lack of responsibly invested products. It is up to the government to address such barriers - and to address the urgent threat that climate change poses to all New Zealanders - by requiring mandatory exclusion of the fossil fuel industry.

Responsible investment with mandatory exclusion of the fossil fuel industry and a stable economy do not fall into conflict. Given the rate of climate breakdown and negative feedback loops in the Earth’s cooling systems, the government cannot afford to make compromises for the current economic model. The economy must be shifted and transformed to account for a fast and just transition away from fossil fuels. I urge the government to require mandatory exclusion of the fossil fuel industry in default Kiwisaver providers in order to signal this necessary shift.

Furthermore, I urge the government to adopt a wider certification regime, beyond default providers, to reinstate trust in KiwiSaver members and ensure transparency and accountability of fund providers in adhering to responsible investments. The government must hold KiwSaver providers accountable so that they cannot 'greenwash' their way around responsible investment.

I believe that the duty to invest responsibly should fall on fund providers rather than Kiwisaver members. Given those fund providers have the economic literacy, access to information, and ultimately the decision-making over investments, there should be stricter policies in place to ensure fund providers are transparent and accountable to the public. For example, Partners for Carbon Accounting Financials have developed a model for the finance sector to accurately report on carbon emissions. This sort of reporting is effective because it holds the finance sector to account for its role in enabling fossil fuel projects to go ahead. I believe a reporting model like this would increase transparency and accountability.

How disruptive would it be for a person if their default provider changed?

Any other feedback?

Anonymous submitter 35

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

Which fees option do you prefer and why?

Should default funds be used to promote responsible investment? If yes, how should this be done?

Yes!! Option 1: Require mandatory exclusions of certain industries or companies, in particular, the exclusion of the fossil fuel industry.

This could be done by adopting a certification regime for all KiwiSaver providers, so investment funds are transparent and accountable and they cannot greenwash their way around responsible investments. For example, Partners for Carbon Accounting Financials have developed a model for the finance sector to accurately report on carbon emissions and this looks well placed to become an industry standard around the world.

It might be trickier, it might impact on returns, there might be higher fees, but in the not so far away future none of that will matter in the slightest if we are all fighting for survival due to climate change.

Divestment from environmentally damaging companies such as those involved in fossil fuels is the best lever we have to make a difference. In our modern world money is the loudest one in the room.

It is absolutely the Governments role to take the lead here and offer kaitiakitanga for our earth, our country, our children and our future. If the Government is prepared to make a stand on smoking, drink driving and guns, why not use this lever for climate change? The Climate Leaders Coalition representing many of our largest companies is showing the paradigm shift that is underway, and what can happen when those in positions of influence take responsibility instead of making excuses.

New Zealand has always been a world leader in doing what is right before everyone else was ready - we are determined, adaptable and courageous in fighting for what matters. And this matters.

Please go home today and tell your children you did the right thing by them. Lets embrace this opportunity for New Zealand to show the world how to make the transition to a zero-carbon future!!

How disruptive would it be for a person if their default provider changed?

Not disruptive at all for the 60% of people who are not taking any role in the decision. Less disruptive for the other 40% than the predicted effects on their health, security and livelihoods from climate change.

Any other feedback?

Anonymous submitter 36

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

The default scheme should be relevant for the person. This means an age-based approach would be best, gradually getting more conservative as time goes on.

Which fees option do you prefer and why?

No comment.

Should default funds be used to promote responsible investment? If yes, how should this be done?

Default funds should set a good example and invest responsibly. This should at a minimum mean no fossil fuel investments - we should not be investing our future funds in industries that are destroying our future.

Besides that, fossil fuel investments are banking on a rapidly becoming obsolete technology. You only have to look at the huge amount of divestment (USD$11 trillion) that has occurred so far worldwide to see the tide turning.

There are also the social and material risks to consider. We cannot afford to burn what we have already extracted, and the social license to back fossil fuels is eroding.

I would like to also urge the government to adopt a wider certification regime for responsible investment. This will ensure transparency and pressure for more providers to provide ethical investments.

How disruptive would it be for a person if their default provider changed?

It should not have any noticeable impact, ideally once they have approved the change, it should be processed automatically behind the scenes.

Any other feedback?

Anonymous submitter 37

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

I would like to urge the government to change the default KiwiSaver settings and implement a robust criteria for ‘responsible investment’, which utilises negative-screening through sector exclusion policies, in particular, the exclusion of the fossil fuel industry.

Responsible investment with mandatory exclusion of the fossil fuel industry and a stable economy do not necessarily fall into conflict. Given the rate of climate breakdown and negative feedback loops in the Earth’s cooling systems, the government cannot afford to make compromises for the current economic model. The economy must be shifted and transformed to account for a fast and just transition away from fossil fuels. 350 Aotearoa urge the government to require mandatory exclusion of the fossil fuel industry in default Kiwisaver providers in order to signal this necessary shift.

Which fees option do you prefer and why?

Should default funds be used to promote responsible investment? If yes, how should this be done?

I would like to urge the government to adopt a wider certification regime, beyond default providers, to reinstate trust in KiwiSaver members and ensure transparency and accountability of fund providers in adhering to responsible investments.

We believe the duty to invest responsibly should fall on fund providers rather than Kiwisaver members. Given those fund providers have the economic literacy, access to information, and ultimately the decision-making over investments, there should be stricter policies in place to ensure fund providers are transparent and accountable to the public. For example, Partners for Carbon Accounting Financials have developed a model for the finance sector to accurately report on carbon emissions. This sort of reporting is effective because it holds the finance sector to account for its role in enabling fossil fuel projects to go ahead. 350 Aotearoa believe a reporting model like this would increase transparency and accountability.

How disruptive would it be for a person if their default provider changed?

Any other feedback?

Anonymous submitter 38

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

I think that it would be better to apply a simple investment option based on age. 17-35, default to growth, 36-54 balanced, 55- Conservative.

There should be a compulsory review when you cross and age boundary. If you do nothing, you'll get moved to the investment option recommended for your age group. You should be easily able to change this.

Which fees option do you prefer and why?

The reduction of percentage based fees over time appeals to me. I believe that when people have small amounts invested they don't necessarily see the fees as a cost, however as the value of an individual's portfolio increases these fees can become quite substantial.

Should default funds be used to promote responsible investment? If yes, how should this be done?

Yes, however I would envisage that this would mean some form of examination and enforcement of what "responsible" is by some overseeing body. Further I believe that this could be a minefield when investment seen as profiteering (i.e. 3rd world clean water supply) could also be seen as responsible.

How disruptive would it be for a person if their default provider changed?

I don't think that it's overly disruptive, however if you were considering buying a first home or about to retire this might cause you a little difficulty during the changeover process. My experience of changing providers was that I lost visibility of my fund for a month or so during the changeover.

Any other feedback?

This form doesn't have feedback on NZ investment options. I favour the option of having a portion of default funds being NZ based. I think the early NZ business option might add an additional element of hidden risk.

Anonymous submitter 39

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

Which fees option do you prefer and why?

Should default funds be used to promote responsible investment? If yes, how should this be done?

I support the the adoption of Option 1 for responsible investment, including the mandatory exclusion of the fossil fuel industry from default fund portfolios.

There are currently a lack KiwiSaver funds that exclude fossil fuels, limiting choice for members who wish to ensure that their money is not invested in fossil fuels. Requiring default providers to exclude the fossil fuel industry would ensure there are more fossil fuel-free fund choices for everyone.

I understand there is an argument that it is inappropriate for the government to impose a particular set of investment criteria on the default product, particularly if it could limit potential returns. However I believe many New Zealanders would expect the government to be using all the tools it has to transition the economy away from fossil fuels as quickly as possible, and to ensure that we meet our obligations under the Paris climate agreement. (Personally I would rather be confident that that my children and grandchildren have a safe future, even if it meant having a little less in my pocket at retirement.)

Lastly I would like to add my support for the points made in the submission by 350 Aotearoa, that investments in the fossil fuel industry pose a material, sociopolitical, reputational, and financial risk to shareholders.

How disruptive would it be for a person if their default provider changed?

Any other feedback?

Anonymous submitter 40

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

The fossil fuel industry should be excluded from default fund portfolios, as investments in the fossil fuel industry pose a material, sociopolitical, reputational, and financial risk to shareholders

Which fees option do you prefer and why?

Should default funds be used to promote responsible investment? If yes, how should this be done?

Yes. The fossil fuel industry should be excluded from default fund portfolios, as investments in the fossil fuel industry pose a material, sociopolitical, reputational, and financial risk to shareholders

How disruptive would it be for a person if their default provider changed?

Any other feedback?

Anonymous submitter 41

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

Balanced fund

Which fees option do you prefer and why?

Requiring percentage-based fees to reduce over time as the provider’s funds under management increase.

Should default funds be used to promote responsible investment? If yes, how should this be done?

Prohibit default providers from investing in particular sectors or industries or require them to meet certain certification standards.

A requirement that parts of the management of KiwiSaver default funds should be New Zealand-based.

How disruptive would it be for a person if their default provider changed?

Any other feedback?

Fossil fuel industry be excluded from default fund portfolios, as investments in the fossil fuel industry pose a material, sociopolitical, reputational, and financial risk to shareholders.

Responsible investment with mandatory exclusion of the fossil fuel industry and a stable economy do not necessarily fall into conflict. Given the rate of climate breakdown and negative feedback loops in the Earth’s cooling systems, the government cannot afford to make compromises for the current economic model. The economy must be shifted and transformed to account for a fast and just transition away from fossil fuels. 350 Aotearoa urge the government to require mandatory exclusion of the fossil fuel industry in default Kiwisaver providers in order to signal this necessary shift.

We believe the duty to invest responsibly should fall on fund providers rather than Kiwisaver members. Given those fund providers have the economic literacy, access to information, and ultimately the decision-making over investments, there should be stricter policies in place to ensure fund providers are transparent and accountable to the public. For example, Partners for Carbon Accounting Financials have developed a model for the finance sector to accurately report on carbon emissions. This sort of reporting is effective because it holds the finance sector to account for its role in enabling fossil fuel projects to go ahead. 350 Aotearoa believe a reporting model like this would increase transparency and accountability.

Anonymous submitter 42

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

Option 1 -advise that the fossil fuel industry be excluded from default fund portfolios, as investments in the fossil fuel industry pose a material, sociopolitical, reputational, and financial risk to shareholders.

Change the default KiwiSaver settings to a robust ‘responsible investment’ criteria, which uses sector exclusion policies, in particular, the exclusion of the fossil fuel industry (Option 1).

Adopt a certification regime for all KiwiSaver providers, so investment funds are transparent and accountable so they cannot greenwash their way around responsible investments.

Which fees option do you prefer and why?

Should default funds be used to promote responsible investment? If yes, how should this be done?

Responsible investment with mandatory exclusion of the fossil fuel industry and a stable economy do not necessarily fall into conflict. Given the rate of climate breakdown and negative feedback loops in the Earth’s cooling systems, the government cannot afford to make compromises for the current economic model. The economy must be shifted and transformed to account for a fast and just transition away from fossil fuels. 350 Aotearoa urge the government to require mandatory exclusion of the fossil fuel industry in default Kiwisaver providers in order to signal this necessary shift.

I believe the duty to invest responsibly should fall on fund providers rather than Kiwisaver members. Given those fund providers have the economic literacy, access to information, and ultimately the decision-making over investments, there should be stricter policies in place to ensure fund providers are transparent and accountable to the public. For example, Partners for Carbon Accounting Financials have developed a model for the finance sector to accurately report on carbon emissions. This sort of reporting is effective because it holds the finance sector to account for its role in enabling fossil fuel projects to go ahead. A reporting model like this would increase transparency and accountability.

How disruptive would it be for a person if their default provider changed?

Not disruptive at all.

Any other feedback?

Thank you for the opportunity to make a submission

Anonymous submitter 43

Organisation

In what capacity are you making this submission?

What is your feedback on the investment mandate options for default funds?

I support Option 1. In my opinion, the fossil fuel industry should be excluded from default fund portfolios, as investments in the fossil fuel industry pose a material, sociopolitical, reputational, and financial risk to shareholders. We have a moral obligation to future generations not to fund our pensions by degrading the environment.

Which fees option do you prefer and why?

Should default funds be used to promote responsible investment? If yes, how should this be done?

How disruptive would it be for a person if their default provider changed?

this question needs to be paired with the costs of allowing ongoing funding of activities we know to be hazardous to the future of human civilisation.

Any other feedback?

We are nearing the point of no return. It is time to save the future with courageous, radical action--no more business as usual.

Anonymous submitter 44

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

The fossil fuel industry should be excluded from all default funds. Investments in the fossil fuel industry are not fair on anyone wanting to use kiwisaver.

Responsible investment with mandatory exclusion of the fossil fuel industry and a stable economy do not necessarily fall into conflict. Given the rate of climate breakdown and negative feedback loops in the Earth’s cooling systems, the government cannot afford to make compromises for the current economic model. The economy must be shifted and transformed to account for a fast and just transition away from fossil fuels. We urge the government to require mandatory exclusion of the fossil fuel industry in default Kiwisaver providers in order to signal this necessary shift.

Which fees option do you prefer and why?

Should default funds be used to promote responsible investment? If yes, how should this be done?

How disruptive would it be for a person if their default provider changed?

Any other feedback?

Anonymous submitter 45

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

Most default fund users would appreciate the potential for higher returns, even if they are not interested in the subject. Most defaulter kiwisavers would expect the government to be looking after them (as we all do), so the higher return would be more appropriate.

Which fees option do you prefer and why?

Simplicity has a good set up in my experience.

Should default funds be used to promote responsible investment? If yes, how should this be done?

By ensuring that they are ethical, sustainable, fossil free and heavily invested in futuristic, environmental technologies.

How disruptive would it be for a person if their default provider changed?

Most likely would be a positive thing as default providers are clearly not the best.

Any other feedback?

Anonymous submitter 46

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

Responsible investment with mandatory exclusion of the fossil fuel industry and a stable economy do not necessarily fall into conflict. Given the rate of climate breakdown and negative feedback loops in the Earth’s cooling systems, the government cannot afford to make compromises for the current economic model. The economy must be shifted and transformed to account for a fast and just transition away from fossil fuels. 350 Aotearoa urge the government to require mandatory exclusion of the fossil fuel industry in default Kiwisaver providers in order to signal this necessary shift.

We believe the duty to invest responsibly should fall on fund providers rather than Kiwisaver members. Given those fund providers have the economic literacy, access to information, and ultimately the decision-making over investments, there should be stricter policies in place to ensure fund providers are transparent and accountable to the public. For example, Partners for Carbon Accounting Financials have developed a model for the finance sector to accurately report on carbon emissions. This sort of reporting is effective because it holds the finance sector to account for its role in enabling fossil fuel projects to go ahead. 350 Aotearoa believe a reporting model like this would increase transparency and accountability.

Make your own

Which fees option do you prefer and why?

Should default funds be used to promote responsible investment? If yes, how should this be done?

Responsible investment with mandatory exclusion of the fossil fuel industry and a stable economy do not necessarily fall into conflict. Given the rate of climate breakdown and negative feedback loops in the Earth’s cooling systems, the government cannot afford to make compromises for the current economic model. The economy must be shifted and transformed to account for a fast and just transition away from fossil fuels. 350 Aotearoa urge the government to require mandatory exclusion of the fossil fuel industry in default Kiwisaver providers in order to signal this necessary shift.

We believe the duty to invest responsibly should fall on fund providers rather than Kiwisaver members. Given those fund providers have the economic literacy, access to information, and ultimately the decision-making over investments, there should be stricter policies in place to ensure fund providers are transparent and accountable to the public. For example, Partners for Carbon Accounting Financials have developed a model for the finance sector to accurately report on carbon emissions. This sort of reporting is effective because it holds the finance sector to account for its role in enabling fossil fuel projects to go ahead. 350 Aotearoa believe a reporting model like this would increase transparency and accountability.

Make your own

How disruptive would it be for a person if their default provider changed?

Any other feedback?

Anonymous submitter 47

Organisation

none

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

Fossil fuel industry should be excluded from default fund portfolios. In order to stay on or below 1.5 RCP, and to reach our goals for the Climate Paris Agreement, we need to divest from fossil fuels. As these industries face continued global and national pressure, they pose too high of risk, both environmentally and financially.

Which fees option do you prefer and why?

I prefer Option 4 and Option 5. There should be a fee waiver or a reduced fee option if people qualify as 'low income' and make under a certain amount per year.

Should default funds be used to promote responsible investment? If yes, how should this be done?

Yes, responsible here would mean taking into account environmental, social and health factors.

How disruptive would it be for a person if their default provider changed?

If communication is timely and consistent and the person has at least 1 month's notice, with sufficient information, then it would be only minimally disruptive.

Any other feedback?

Anonymous submitter 48

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

Change the default KiwiSaver settings to a robust ‘responsible investment’ criteria, which uses sector exclusion policies, in particular, the exclusion of the fossil fuel industry (Option 1).

Which fees option do you prefer and why?

Option 2. Fair fees across the board but competitive.

Should default funds be used to promote responsible investment? If yes, how should this be done?

Yes, by requiring 100% responsible investment and defined by a respected third party.

How disruptive would it be for a person if their default provider changed?

Not very disruptive as long as the process is well managed and clearly communicated.

Any other feedback?

Adopt a certification regime for all KiwiSaver providers, so investment funds are transparent and accountable so they cannot greenwash their way around responsible investments.

Anonymous submitter 49

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

the two important things for government to do:

Change the default KiwiSaver settings to a robust ‘responsible investment’ criteria, which uses sector exclusion policies, in particular, the exclusion of the fossil fuel industry (Option 1).

Adopt a certification regime for all KiwiSaver providers, so investment funds are transparent and accountable so they cannot greenwash their way around responsible investments.

Which fees option do you prefer and why?

Option 1 Excludes fossil fuel industry as an investment option

Should default funds be used to promote responsible investment? If yes, how should this be done?

Yes

By requiring fossil fuel investment to be excluded, and adopting a certification regime for all KiwiSaver providers, so investment funds are transparent and accountable so they cannot greenwash their way around responsible investments

How disruptive would it be for a person if their default provider changed?

It shouldn't be disruptive.

Any other feedback?

The world's climate emergency requires that fossil fuels no longer be available for use within the next decade to keep global warming within a 1.5 degree C limit. It is very unwise to maintain investment in what will be a legacy industry.

Anonymous submitter 50

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

Which fees option do you prefer and why?

Government setting the fees. Seems least risky option.

Should default funds be used to promote responsible investment? If yes, how should this be done?

Definitely. I don't want my money being invested in fossil fuels, palm oil, companies that violate human rights, tobacco, gambling, pornography, etc. Default funds should exclude these and promote responsible investment.

How disruptive would it be for a person if their default provider changed?

Depends how it was done. Doesn't need to be, does it? I'd love to change my default provider but none of the other providers I emailed responded to any of my questions about ethical investments.

Any other feedback?

I see there is a new website (Mindful Money) that is very helpful in learning about ethical investing and our existing funds, but the options still seem limited and I couldn't find a single fund that was ethical enough for my preferences. This should be the Government's job, there's no reason why we should be unwittingly forced to support unethical industries. I feel like my Kiwisaver money being used to fund these industries undermines everything that I try so hard to do in my day-to-day life as a consumer and citizen. Sort it out please!

Anonymous submitter 51

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

Lifestages would benefit younger default savers and also reduce the fluctuations by over time as they got older vs if the saver stayed simply in the balanced fund. Gets them out of the conservative which isnt going to get them a sizeable balance via growth.

Also mirrors what advised savers would see in their portfolios over time aswell.

Which fees option do you prefer and why?

Prefer the Zero-fees for under 18s or people with low KiwiSaver balance option. The wider cohort will likely pick up the tab but under 18s and low balances would be disproportionality hit by fees

Should default funds be used to promote responsible investment? If yes, how should this be done?

Yes - any default funds should meet a minimum bar around low environmental impact & diveristy (plus some others). HAving the default meet this level i'd hope would encourage this to be the "norm" rather than the exception.

How disruptive would it be for a person if their default provider changed?

Any other feedback?

Anonymous submitter 52

Organisation

In what capacity are you making this submission?

What is your feedback on the investment mandate options for default funds?

See "any other" below.

Which fees option do you prefer and why?

Should default funds be used to promote responsible investment? If yes, how should this be done?

How disruptive would it be for a person if their default provider changed?

Any other feedback?

Resolving this issue will be vital to all our futures...

Responsible investment with mandatory exclusion of the fossil fuel industry and a stable economy do not necessarily fall into conflict. Given the rate of climate breakdown and negative feedback loops in the Earth’s cooling systems, the government cannot afford to make compromises for the current economic model. The economy must be shifted and transformed to account for a fast and just transition away from fossil fuels. 350 Aotearoa urge the government to require mandatory exclusion of the fossil fuel industry in default Kiwisaver providers in order to signal this necessary shift.

These reforms are vital for appropriate and effective all future investment.

Antonella Vecchiato

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

Investments in the sectors of oil and gas extractions should be made illegal, as other type of investments that would contribute to global warming.

Which fees option do you prefer and why?

Should default funds be used to promote responsible investment? If yes, how should this be done?

Yes. See my answer to the first question

How disruptive would it be for a person if their default provider changed?

I am not sure

Any other feedback?

Ants Field

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

I urge the government to require mandatory exclusion of the fossil fuel industry in default Kiwisaver providers.

Which fees option do you prefer and why?

I am happy with the current fee structure.

Should default funds be used to promote responsible investment? If yes, how should this be done?

Yes definitely.

I urge the government to require mandatory exclusion of the fossil fuel industry in default Kiwisaver providers in order to signal this necessary shift.

I believe the duty to invest responsibly should fall on all fund providers rather than Kiwisaver members. Given those fund providers have the economic literacy, access to information, and ultimately the decision-making over investments, there should be stricter policies in place to ensure fund providers are transparent and accountable to the public.

How disruptive would it be for a person if their default provider changed?

Not disruptive at all.

I've changed myself and it was easy and painless.

If it happened with zero input from myself it would have not been noticeable at all.

Any other feedback?

I think it's great to have the opportunity to give feedback on Kiwi Saver.

I love the scheme, but think it needs a few improvements.

72% of New Zealanders expect that their investments are being made responsibly, but sadly that’s not the case. 715,000 people have been put in default KiwiSaver funds, without the knowledge that all of these funds are invested in the world’s riskiest industry.

Let's tidy this up by making the default schemes live up to people's expectations.

Arthur Renquist

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

I am retired and drawing down a Kiwisaver account investment, 62% of which is in the default fund by choice. I was dismayed that my provider was slow in offering responsible investment options and when they did it was deficient in that the fund did not exclude the fossil fuel industry. Therefore I support changing the mandate for the many people who are in default-provider funds.

Which fees option do you prefer and why?

Option 1.

Should default funds be used to promote responsible investment? If yes, how should this be done?

Yes. A changed mandate to exclude the fossil fuel sector would be best done by the provider institutions rather than leaving it to the individual investor.

How disruptive would it be for a person if their default provider changed?

Mine was changed once by my employer and it was not a problem for me.

Any other feedback?

Barbara Grant

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

I prefer a balanced approach.

Which fees option do you prefer and why?

Zero fees for under 18s and low KS balances.

Should default funds be used to promote responsible investment? If yes, how should this be done?

How disruptive would it be for a person if their default provider changed?

I don't know – more information would be helpful.

Any other feedback?

It is time our government took a much more proactive, future-oriented, approach to this matter. You are our nation's leaders and we depend on you to lead us with courage and conviction through the terrible challenges of climate change.

Ben Simpson

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

People work hard for their money; it is, after all, an abstract representation of time and labour. As such it is a personal possession and the owner should decide how their hard earned dollars should be invested as an extension of self. To invest an individual's property into a venture that the individual would never knowingly contribute to is a violation of personal freedom. To do so as part of an automated system of default is callous in the extreme.

Which fees option do you prefer and why?

I support any fees option that returns autonomy and choice to the investor so that at no point is the investor having their funds invested in industries and businesses they would never knowingly support. While i acknowledge that, from a practical view point, default settings can be useful, these investments should be open to transfer/redirection at a later date should the investor wish to make such a change.

Should default funds be used to promote responsible investment? If yes, how should this be done?

Responsible investment is, by definition an investment that takes into consideration the rammifacations of a given investment and is prepared to be responsible for those outcomes of invesment, whether for good or bad. Perhaps the greatest test these days for responsible investment is whether the investment is one with a view to sustainability. It is a basic fact that the best investments are long-term ones that yield greater returns over a period of time. Before investment in a venture it should be assessed to see if the venture is sustainable over an extended time frame with a view to maximising ultimate investment return and minimising risk. such assessments should be done independently in a transparent fashion.

How disruptive would it be for a person if their default provider changed?

Considering that most investment processes are opaque and most investors have no idea where their funds are invested, any shift in the default provider would probably go unremarked in a similar fashion.

Any other feedback?

Blaze Forbes

Organisation

N/A

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

Which fees option do you prefer and why?

Should default funds be used to promote responsible investment? If yes, how should this be done?

How disruptive would it be for a person if their default provider changed?

Any other feedback?

Fossil fuels should be excluded from the funds, including indirect investments where feasible. Fossil fuel funds run the risk of becoming stranded assets, and ought not to be socially acceptable anyhow

Brian Cumber

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

For many reasons they need to be moved out of fossil fuels.

Which fees option do you prefer and why?

no preference

Should default funds be used to promote responsible investment? If yes, how should this be done?

Change the default KiwiSaver settings to a robust ‘responsible investment’ criteria, which uses sector exclusion policies, in particular, the exclusion of the fossil fuel industry (Option 1).

Adopt a certification regime for all KiwiSaver providers, so investment funds are transparent and accountable so they cannot greenwash their way around responsible investments.

How disruptive would it be for a person if their default provider changed?

Hopefully not at all.

Any other feedback?

Caitlyn Crivelli

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

I advise that the fossil fuel industry be excluded from default fund portfolios, as investments in the fossil fuel industry pose a material, sociopolitical, reputational, and financial risk to shareholders.

Which fees option do you prefer and why?

Should default funds be used to promote responsible investment? If yes, how should this be done?

YES

How disruptive would it be for a person if their default provider changed?

Hardly disruptive at all.

Any other feedback?

Caro Robertson

Organisation

Spacecraft Architects

In what capacity are you making this submission?

Business

What is your feedback on the investment mandate options for default funds?

At very least negative screened for weapons, deforestation, environmental run off/poisoning and fossil fuels. Preferably all ethically questionable activities.

Which fees option do you prefer and why?

I think Simplicity’s model works well

Should default funds be used to promote responsible investment? If yes, how should this be done?

Yes, I think capping CEO income to a proportion of worker income makes sense, positive screening for environmentally responsible policies and negative screening for weapons/fossil fuels.

How disruptive would it be for a person if their default provider changed?

Not much if they were all ethically grounded and terms were comparible

Any other feedback?

Carol Sumner

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

I think it is important to have the option, and that each individual must choose their preferred investment option. It is hard to set a default that suits everybody because everybody is in a different situation.

Some ideas:

As a default half of their investment could be into balance and half into growth to increase the growth sector but also provide the stability/reliability of having some in the balanced (especially if they have not yet purchased their first home).
Those who haven't used their kiwisaver for their first home purchase could be put into the balanced fund to give them greater stability for an early withdrawal.
exclusion of detrimental sectors from default at the least and preferably all investment options! (especially fossil fuel)

Which fees option do you prefer and why?

I would prefer the government sets the fees, and that the ethical/sustainable/regenerative businesses get no/lower fees as extra incentive, and the industries that are detrimental/damaging to the environment/climate/community (if they are still an option for investing in!) get the fees/higher fees.

Or maybe the investment stategies with the highest return get the highest fees and the investments with the lowest/slowest returns get the lower fees

It is very important to me that businesses and organizations that are regenerative/ethical/eco-friendly are supported more and invested in more to encourage more businesses and organizations into that thinking and to improve the stability of our climate/environment.

Should default funds be used to promote responsible investment? If yes, how should this be done?

Yes. Prohibit default providers from investing in sectors or industries that directly or indirectly damage the environment/community/climate. Higher fees for a better world to live in is an investment itself - not a cost.

Default providers should definitely provide a breakdown of who/what they invest into for transparency and increasing peoples awareness of what they are directly supporting and whether that aligns with their ideals/principles.

How disruptive would it be for a person if their default provider changed?

For me personally, I changed my provider when I became aware that some providers were investing in things that were very much against my ethics/principles, my return is now very low but at least I am satisfied that my kiwisaver is not being used to disrupt the environment. I imagine for those not interested enough to choose, or with not enough time to invest in choosing a provider, would not be particularly bothered/inconvenienced by a change in default provider. Maybe they would be relieved to know that their default provider was an ethical/sustainable investor.

Any other feedback?

I would be very happy to see options for kiwisaver to be used to purchase land (in a group setting/trust setup) for eco-villages/intentional communities. This would meet the need for affordable living options for lower income families, increase productivity of the land (with more hands to work on each individual "farm/village", increase mental health/well-being as the costs on each family would be much reduced, reducing the need to work such long hours, increasing family time and time to connect in the community, increasing time to spend on hobbies therefore increasing productivity/skills and mental health.

Cath Beattie

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

I would like mandatory exclusion of fossil fuel industry

Which fees option do you prefer and why?

Should default funds be used to promote responsible investment? If yes, how should this be done?

Yes . Full information and facts re the importance of funding sustainable companies whilst highlighting the negatives of allowing the fossil fuel industry to continue

How disruptive would it be for a person if their default provider changed?

It shouldn’t be disruptive at all and should be taken care of through the providers involved

Any other feedback?

Catherine Bircher

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

I urge the government to change the default KiwiSaver settings and implement a set of robust criteria for ‘responsible investment’, which utilises negative-screening through sector exclusion policies, in particular, the exclusion of the fossil fuel industry.

Which fees option do you prefer and why?

I support the adoption of Option 1, as this provides the best financial support to the people that KiwiSaver is targetted at (people who are not financially well-informed) However, I strongly advise that the fossil fuel industry be excluded from default fund portfolios, as investments in the fossil fuel industry create an existential risk to the lives of current and future Kiwisaver shareholders, and such investments are therefore in direct opposition to the goals of Kiwisaver. In particular, investment in Fossil fuels contradicts criterion 1 (Better financial position for KiwiSaver default members, particularly at retirement). Kiwisaver members who live in an ecosystem and economy devastated by runaway global heating will have a considerably poorer financial position than members living in a stabilising global climate. Kiwisaver is therefore obligated to pursue a stable climate future for its members.

Should default funds be used to promote responsible investment? If yes, how should this be done?

Yes, default funds should promote responsible and ethical investment.

Whilst many other types of responsible investment might be considered, the most important is the complete exclusion of all investment in fossil fuels. as investments in the fossil fuel industry pose a significant material, financial and reputational risk to all kiwisaver members, and therefore are in direct opposition to the goals of Kiwisaver as a whole.

Material risk: The fossil fuel industry has over five times the amount of coal, oil, and gas in reserve than is safe to burn in order to curb temperature rise to 1.5C warming pre-industrial levels. Given the direct link between the fossil fuel industry’s business model and the impacts of climate change, investments in this industry directly create an existential material risk to Kiwisaver members.

Financial risk: Failure to account for falling power prices, the rapid growth of renewable energy, flat or falling energy demand, and new emissions-control policies can result in coal, oil, and gas projects becoming stranded assets. Various fossil fuel products have entered structural decline, which by definition is a long-term shift that transcends cyclical ups and downs (e.g. the coal industry is now widely acknowledged to be in long-term irreversible decline). Therefore, it is irresponsible for default KiwiSaver products, which by their nature are long-term investments to invest in a high-risk industry, like the fossil fuel industry. Kiwisaver members would make better returns without fossil fuels in their fund portfolios.

Responsible investment aimed at maintaining a stable economy is entirely in accord with mandatory exclusion of the fossil fuel industryfrom said investment. Given the rate of climate breakdown and negative feedback loops in the Earth’s cooling systems, the government cannot afford to make compromises for the current economic model. The economy must be rapidly shifted and transformed to account for a fast and just transition away from fossil fuels. I therefore urge the government to require mandatory exclusion of the fossil fuel industry in default Kiwisaver providers in order to signal this necessary shift.

How disruptive would it be for a person if their default provider changed?

I fail to understand this question. It is exactly as disruptive as we decide to design the law. If we mandate a robust process to handle the change of a default provider, then the change need not be disruptive at all. As most Kiwisaver members are not of high financial literacy, all changes in Kiwisaver to do with the changing of a default provider should aim to do this with the minimum possible impact on members.

Any other feedback?

I believe the duty to invest responsibly should fall on fund providers rather than Kiwisaver members. Given those fund providers have the economic literacy, access to information, and ultimately the decision-making over investments, there should be stricter policies in place to ensure fund providers are transparent and accountable to the public. Models are available for the finance sector to accurately report on carbon emissions. This sort of reporting is effective because it holds the finance sector to account for its role in enabling fossil fuel projects to go ahead. Adopting a rigorous reporting model that incorporates carbon emissions would increase Kiwisaver's transparency and accountability.

Charlie Devenish

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

I would like there to be a change to the default KiwiSaver settings to a robust ‘responsible investment’ criteria, which uses sector exclusion policies, in particular, the exclusion of the fossil fuel industry.

Which fees option do you prefer and why?

Should default funds be used to promote responsible investment? If yes, how should this be done?

Change the default KiwiSaver settings to a robust ‘responsible investment’ criteria, which uses sector exclusion policies, in particular, the exclusion of the fossil fuel industry (Option 1).

How disruptive would it be for a person if their default provider changed?

Any other feedback?

Divest from fossil fuels, arms, tobacco....invest ethically please!

Christian Williams

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

I support Option 1. Default schemes should have strong SRI requirements, including the exclusion of all fossil fuel investments.

Which fees option do you prefer and why?

No opinion

Should default funds be used to promote responsible investment? If yes, how should this be done?

Yes. All default schemes should be required to pass negative-screening benchmarks to ensure they are not investing in high-risk and unethical investments.

How disruptive would it be for a person if their default provider changed?

Not very disruptive. Most people don't know much about the scheme they are placed in by default, which is an extra reason why those schemes should be fit for purpose.

Any other feedback?

The government should also instate a wider certification scheme beyond default providers to ensure all kiwisaver funds are in trustworty and suitable investments for the future.

Claire Newman

Organisation

Seed the Change | He K?kano H?pai

In what capacity are you making this submission?

Other

What is your feedback on the investment mandate options for default funds?

Seed the Change | He K?kano H?pai endorses a life-stages approach to the default funds. Along with this annual communication on the risks should go out to fund holders.

Seed the Change believes investments can be used to enable a sustainable and equitable planet but divesting from shareholdings that have a negative impact on people and the planet, and proactively investing in regenerative industries.

Seed the Change urges the government to change the default KiwiSaver settings to a 'green' investment portfolio, positively screening for regenerative investments, combined with sector exclusion policies, in particular, the exclusion of the fossil fuel industry. Mindful Money is a platform where kiwisaver investors can currently assess the impact of their kiwisaver funds for such positive and negative screens.

Specifically we urge that the fossil fuel industry be excluded from all default fund portfolios, as investments in the fossil fuel industry pose a material, sociopolitical, reputational, and financial risk to shareholders.

We endorse 350.org's view that failure to account for falling power prices, the rapid growth of renewable energy, flat or falling energy demand, and new emissions-control policies can result in coal, oil, and gas projects becoming stranded assets. Various fossil fuel products have entered structural decline, which by definition is a long-term shift that transcends cyclical ups and downs. Therefore, it is irresponsible for default KiwiSaver products, which in nature are long-term investments to invest in a high-risk industry, like the fossil fuel industry.

New Zealand has the opportunity to show global leadership by enabling structural change to meet the demands of its citizens by setting the default fund providers to positively screened providers. The majority of New Zealanders are concerned about climate change. This review presents an opportunity to implement significant socio-political changes that society will be demanding with increasing voice. Showing leadership at governmental level will signal to the fossil fuel industry, and the renewable and regenerative industries the country's future direction.

Consumer choice is confined to structural factors, like a lack of responsibly invested products, and in order to transform the economy sufficiently to meet the needs of New Zealanders, consistent with the impacts of climate change, mandatory exclusion of the fossil fuel industry for default providers is necessary.

We agree when 350.org states green and regenerative investment with mandatory exclusion of the fossil fuel industry and a stable economy do not necessarily fall into conflict. Given the rate of climate breakdown and negative feedback loops in the Earth’s cooling systems, the government cannot afford to make compromises for the current economic model. The economy must be shifted and transformed to account for a fast and just transition away from fossil fuels.

Seed the Change | He K?kano H?pai urge the government to require mandatory exclusion of the fossil fuel industry in default Kiwisaver providers in order to signal this necessary shift.

Which fees option do you prefer and why?

We recommend a blended fees option:

Zero-fees for under 18s or people with low KiwiSaver balances under $10,000, and then over $10,000 a percentage-based fees structure to reduce over time as the provider’s funds under management increase.

This will provide equitable solutions to those on lower incomes, and encourage continued savings into kiwisaver. We urge the government to adopt strategies as market leader, Simplicity have provided to the kiwisaver market, but reducing fees, enabling greater funds to be invested.

Should default funds be used to promote responsible investment? If yes, how should this be done?

Seed the Change urges the government to change the default KiwiSaver settings to a "green" investment portfolio, positively screening for regenerative investments, combined with sector exclusion policies, in particular, the exclusion of the fossil fuel industry. Mindful Money is a platform where kiwisaver investors can currently assess the impact of their kiwisaver funds for such positive and negative screens.

Seed the Change | He K?kano H?pai urge the government to require mandatory exclusion of the fossil fuel industry in default Kiwisaver providers in order to signal this necessary shift.

How disruptive would it be for a person if their default provider changed?

For the majority of people investing in a default provider, the disruption would be neglible. They are not actively investing, and therefore this presents an opportunity to engage with these passive investors, and provide a range of education pathways, such as Mindful Money, to gain knowledge of the impact of investment options on their retirement.

Any other feedback?

We welcome the opportunity to speak to this application.

We urge the government to take bold leadership for the benefit of our future generations.

Clare Moleta

Organisation

N/A

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

I'd be in favour of the balanced option as default, with the option to change to a higher or lower-risk portfolio.

Which fees option do you prefer and why?

I would prefer the government to set fees. While I appreciate this would require careful thinking through, Kiwisaver is a government initiative and I'd support a hands-on management approach; not least because it removes one layer of complication and research for people looking at different funds.

Should default funds be used to promote responsible investment? If yes, how should this be done?

Absolutely. This should have been an integral part of Kiwisaver from the outset, and I'm so pleased this government is taking it seriously.

The lack of a genuine ethical investment option, and the complete disinterest by superannuation providers in offering this, was the reason I did not take up Kiwisaver when it started. Having moved home from Australia, where companies like Australian Ethical Superannuation(external link) provide a high-quality, transparent ethical investment option with as much emphasis on positive screening as negative, I was astounded and frustrated by the disinterest and cynicism of providers, who told me repeatedly that consumer weren't interested in investing their money without causing harm to other people or the environment.

It's great to see some movement on this, due to advocacy by individuals, sustainable business groups and the media, but I believe leadership by government is required and appropriate here, on moral grounds.

While this may mean higher costs initially, it's also a real opportunity to support and reward sustainable, ethical and innovative companies and businesses, both locally and internationally, through positive screening. In the medium to long-term, this should have a beneficial effect on our economy and society. Finally, there is plenty of evidence to show that companies that reject dying industries and invest in sustainable ones perform at least as well as their competitors and are better placed to survive and thrive in the future.

In making this change, it will be essential to lay clear, consistent ground rules so that providers are not able to simply appear to comply by using general and misleading language, or tokenism. I have noticed a tendency towards this by some providers, who see the groundswell of support for responsible investment and would like to cash in on it without actually making any real change.

How should this be done?

At an absolute minimum, default providers (preferably all providers) should be required to meet specific negative screening standards in key areas such as fossil fuels, broader environmental responsibility, human and labour rights, weaponry, gambling and tobacco. This should relate to both direct and (as far as reasonably possible) indirect investment. Companies should provide clear, plain-English documentation of the steps they've taken, measured against sector-wide standards. Where the ethics of secondary investments are difficult to establish, the default position should be NOT to invest.

The next step: Responsible investment should be more than a reactive process. It should be seen as an evolving and active part of core business that rewards good corporate citizens as well as deterring unethical business practices. Providers should be encouraged to assign this portfolio to a specific board member, preferably with experience or skill in this area. They should also be encouraged to go beyond negative screening and take active steps to positively screen for ethical and sustainable investment opportunities, whether local or international. And this should be an overall approach, not something confined to a small, discrete segment of the fund; in the same way a confectionary giant offers a boutique 'fair trade' line simply to capture an additional market, while core business-as-usual remains profoundly unethical.

Australian Ethical Super(external link) is a great model for this fund-wide approach and I believe many New Zealanders would accept slightly higher administration fees and even a more moderate return on investment in exchange for knowing they were not profiting from the suffering of other people, or the degradation of the environment.

Impartial ranking information on responsible investment by default funds (preferably all funds) should be publicly available and regularly updated, with a star ranking system or similar that shows which providers are positively, as well as negatively, screening; which ones are fully responsible or taking active steps towards this (including at Board level); and which ones are dragging their feet.

How disruptive would it be for a person if their default provider changed?

This is a difficult question to answer because it depends on individual circumstance. Advance warning and clear communication would be essential; as would explaining the reasons for the change.

In more than a decade of talking to New Zealanders about ethical investment, I have never met anyone who didn't respond favourably to the idea once they understood it was a possibility.

Any other feedback?

Craig Drown

Organisation

Sustainable Solutions (NZ) Ltd

In what capacity are you making this submission?

Business

What is your feedback on the investment mandate options for default funds?

A life stages approach seems best.

Which fees option do you prefer and why?

We would prefer that the government sets fees for default providers, and monitors their profits. Default provision could be done by a small team for all of New Zealand- the fee structures are far too high, especially the percentage based components.

Should default funds be used to promote responsible investment? If yes, how should this be done?

We strongly support changing the default settings to exclude any investment in the fossil fuel industry.

It is totally unacceptable that the retirement funds of New Zealanders should be invested in industries whose continued long term existence threatens the ability of those people to live safe, secure retirements.

How disruptive would it be for a person if their default provider changed?

Not very.

Any other feedback?

Thanks for considering these responses.

David Chilvers

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

Which fees option do you prefer and why?

Should default funds be used to promote responsible investment? If yes, how should this be done?

How disruptive would it be for a person if their default provider changed?

Any other feedback?

David Henley

Organisation

System Impact Foundation

In what capacity are you making this submission?

Researcher or academic

What is your feedback on the investment mandate options for default funds?

Which fees option do you prefer and why?

Should default funds be used to promote responsible investment? If yes, how should this be done?

How disruptive would it be for a person if their default provider changed?

Any other feedback?

Adopt a certification regime for all KiwiSaver providers, so investment funds are transparent and accountable so they cannot greenwash their way around responsible investments.

David Pate

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

Adopt a certification regime for all KiwiSaver providers, so investment funds are transparent and accountable so they cannot greenwash their way around responsible investments.

Which fees option do you prefer and why?

Should default funds be used to promote responsible investment? If yes, how should this be done?

How disruptive would it be for a person if their default provider changed?

Any other feedback?

David Pate

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

Divest from fossil fuels, oh and make sure we haven't reinvested in land mines SMFH

Which fees option do you prefer and why?

Should default funds be used to promote responsible investment? If yes, how should this be done?

How disruptive would it be for a person if their default provider changed?

Any other feedback?

David Patterson

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

Change the default KiwiSaver settings to a robust ‘responsible investment’ criteria, which uses sector exclusion policies, in particular, the exclusion of the fossil fuel industry (Option 1).

Adopt a certification regime for all KiwiSaver providers, so investment funds are transparent and accountable. Responsible green investments without greenwashing.

Which fees option do you prefer and why?

Zero fees for under 18s and low balances. Or a staggered percentage option where those with higher balances pay fees in higher proportions.

Should default funds be used to promote responsible investment? If yes, how should this be done?

Prohibit certain sectors = yes<

Require standard information = yes

'Some people might think that it isn’t the government’s role to ensure that investments are made responsibly.'

Given the climate and ecological crisis I think we're past that. The zeitgeist around investment has had a massive gear shift in recent years towards ethics-first investment. Every individual has a role to act responsibly, and the govt acting on behalf of those people must act accordingly.

How disruptive would it be for a person if their default provider changed?

For me, not disruptive. I'd be happier and more secure in the knowledge that the funds are being invested ethically.

Any other feedback?

NZ capital markets = yes.

Investment in local and early stage businesses = yes

Dharan Longley

Organisation

Training Source Ltd

In what capacity are you making this submission?

Business

What is your feedback on the investment mandate options for default funds?

Change the default KiwiSaver settings to a robust ‘responsible investment’ criteria, which uses sector exclusion policies, in particular, mandatory exclusion of the fossil fuel industry. Fossil fuel industry should be excluded from default fund portfolios, as investments in the fossil fuel industry pose a material, sociopolitical, reputational, and financial risk to shareholders.

Which fees option do you prefer and why?

Should default funds be used to promote responsible investment? If yes, how should this be done?

Investments must be transparent and accountable so individual contributors know what they are invested in. Full disclosure is essential. The duty to invest responsibly should fall on fund providers rather than Kiwisaver members.

How disruptive would it be for a person if their default provider changed?

A lot. Consult with the client always first.

Any other feedback?

Adopt a certification regime for all KiwiSaver providers, so investment funds are transparent and accountable so they cannot greenwash their way around responsible investments.

Diana Robertson

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

Which fees option do you prefer and why?

Should default funds be used to promote responsible investment? If yes, how should this be done?

Yes absolutely. It is time consuming and difficult to research responsible investments for an individual or business.

Under a range of international agreements and New Zealnd legal frameworks how we manage our impacts on the environment (including climate change, biodiversity, waer quality) social connectivity and wellbeing and cultural diversity and expression are fundamental considerations. Responsible investment seems one of the most obvious expressions of this, and therefore also with our identification as people of Aotearoa / New Zealand.

I have read, and agree with the main points raised by 350, copied below:

'350 Aotearoa urge the government to change the default KiwiSaver settings and implement a robust criteria for ‘responsible investment’, which utilises negative-screening through sector exclusion policies, in particular, the exclusion of the fossil fuel industry.

Responsible investment with mandatory exclusion of the fossil fuel industry and a stable economy do not necessarily fall into conflict. Given the rate of climate breakdown and negative feedback loops in the Earth’s cooling systems, the government cannot afford to make compromises for the current economic model. The economy must be shifted and transformed to account for a fast and just transition away from fossil fuels. 350 Aotearoa urge the government to require mandatory exclusion of the fossil fuel industry in default Kiwisaver providers in order to signal this necessary shift.

We believe the duty to invest responsibly should fall on fund providers rather than Kiwisaver members. Given those fund providers have the economic literacy, access to information, and ultimately the decision-making over investments, there should be stricter policies in place to ensure fund providers are transparent and accountable to the public. For example, Partners for Carbon Accounting Financials have developed a model for the finance sector to accurately report on carbon emissions. This sort of reporting is effective because it holds the finance sector to account for its role in enabling fossil fuel projects to go ahead. 350 Aotearoa believe a reporting model like this would increase transparency and accountability.'

How disruptive would it be for a person if their default provider changed?

Personally, not a big deal.

Any other feedback?

Donald Chandler

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

Which fees option do you prefer and why?

Should default funds be used to promote responsible investment? If yes, how should this be done?

How disruptive would it be for a person if their default provider changed?

Any other feedback?

Every action of government needs to reflect the urgency of the climate crisis. Even kiwisaver default funds.

Dr kit withers

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

I support the position of 350:

September 15, 2019

KiwiSaver Review: Submission Guide

Make a submission today and urge the government to keep our default KiwiSaver funds fossil free!

The government is seeking feedback from New Zealanders on how Kiwisaver default funds could do better, and they want to know if default funds should be invested responsibly. Around 715,000 New Zealanders still use their default Kiwisaver provider, and together we have the power to ensure that every New Zealander’s default option is fossil free.

Submissions are due Wednesday 18th September at 5pm. Make your own submission to MBIE here

Here’s a summary of our main points:

Responsible investment with mandatory exclusion of the fossil fuel industry and a stable economy do not necessarily fall into conflict. Given the rate of climate breakdown and negative feedback loops in the Earth’s cooling systems, the government cannot afford to make compromises for the current economic model. The economy must be shifted and transformed to account for a fast and just transition away from fossil fuels. 350 Aotearoa urge the government to require mandatory exclusion of the fossil fuel industry in default Kiwisaver providers in order to signal this necessary shift.

We believe the duty to invest responsibly should fall on fund providers rather than Kiwisaver members. Given those fund providers have the economic literacy, access to information, and ultimately the decision-making over investments, there should be stricter policies in place to ensure fund providers are transparent and accountable to the public. For example, Partners for Carbon Accounting Financials have developed a model for the finance sector to accurately report on carbon emissions. This sort of reporting is effective because it holds the finance sector to account for its role in enabling fossil fuel projects to go ahead. 350 Aotearoa believe a reporting model like this would increase transparency and accountability.

Which fees option do you prefer and why?

Should default funds be used to promote responsible investment? If yes, how should this be done?

How disruptive would it be for a person if their default provider changed?

Any other feedback?

Dr Logan Muller

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

No funds ( my money) to go to fossil fuel industry please

Which fees option do you prefer and why?

- not fossil fuels, how about carbon zero fuels ? Hydrogen, electricity from solar, wind Geothermal ?

Should default funds be used to promote responsible investment? If yes, how should this be done?

As above invest in future energy solutions not the failed previous fossil ones !!

How about planting programs? Native Forestación

How disruptive would it be for a person if their default provider changed?

Not at all. I’d change tomorrow to a cleaner provider

Any other feedback?

Ellery Daines

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

Which fees option do you prefer and why?

Not sure

Should default funds be used to promote responsible investment? If yes, how should this be done?

Yes - negative screening on irresponsible investments, in particular the fossil fuel industry, should be a mandstory part of all kiwisaver schemes

How disruptive would it be for a person if their default provider changed?

Not sure

Any other feedback?

Ellie Craft

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

The defualt kiwisaver should be climate friendly. The government has a responsibility to assure New Zealanders who are put in default funds that their savings are being put towards a safe climate future, not high-risk investments like the fossil fuel industry.

Which fees option do you prefer and why?

Should default funds be used to promote responsible investment? If yes, how should this be done?

How disruptive would it be for a person if their default provider changed?

Any other feedback?

Emily

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

I agree with the views of 350 Aotearoa which are as follows:

Responsible investment with mandatory exclusion of the fossil fuel industry and a stable economy do not necessarily fall into conflict. Given the rate of climate breakdown and negative feedback loops in the Earth’s cooling systems, the government cannot afford to make compromises for the current economic model. The economy must be shifted and transformed to account for a fast and just transition away from fossil fuels. 350 Aotearoa urge the government to require mandatory exclusion of the fossil fuel industry in default Kiwisaver providers in order to signal this necessary shift.

We believe the duty to invest responsibly should fall on fund providers rather than Kiwisaver members. Given those fund providers have the economic literacy, access to information, and ultimately the decision-making over investments, there should be stricter policies in place to ensure fund providers are transparent and accountable to the public. For example, Partners for Carbon Accounting Financials have developed a model for the finance sector to accurately report on carbon emissions. This sort of reporting is effective because it holds the finance sector to account for its role in enabling fossil fuel projects to go ahead. 350 Aotearoa believe a reporting model like this would increase transparency and accountability.

Which fees option do you prefer and why?

I agree with the views of 350 Aotearoa, please see above.

Should default funds be used to promote responsible investment? If yes, how should this be done?

I agree with the views of 350 Aotearoa, please see above.

How disruptive would it be for a person if their default provider changed?

I agree with the views of 350 Aotearoa, please see above.

Any other feedback?

For me, the most important thing is that we are not investing in industries which are adversely impacting our environment e.g. fossil fuels.

Erna Mackintosh

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

Which fees option do you prefer and why?

Should default funds be used to promote responsible investment? If yes, how should this be done?

How disruptive would it be for a person if their default provider changed?

Any other feedback?

Come on KiwiSaver do what you know and have shown in the past to do the right thing with investments from New Zealanders. We don't want to see our savings being tainted by investments in organisations that are making money by destroying the planet. Show you really care for our future and invest in environmentally, ethical organisations.

Felix Morgenstern

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

I don't really know enough to give an informed opinion on this, a balanced fund as a default option seems intuitive to me. However, if growth funds typically perform better then maybe it should be a growth fund. Perhaps it could also be based on the age of the individual concerned.

Which fees option do you prefer and why?

Again not too qualified to comment on this, but I think government setting fees for default users on a percentage base is probably best.

Should default funds be used to promote responsible investment? If yes, how should this be done?

I think responsible funds should at a minimum be the default option, and I absolutely think it is government's role to make sure investments are made responsibly. I think government should ensure default kiwisaver schemes are accredited ethical and responsible, i.e. no investments in weapons, tobacco, fossil fuels, and other forms of exploitation where possible. With climate change being the leading issue affecting our future, it would be ironic that the fund helping you save for your future is simultaneously undermining that future.

How disruptive would it be for a person if their default provider changed?

I think in cases where people haven't bothered to investigate options outside the default option it would make no difference to them whether it changes. For people that have consciously chosen the default option, if they were notified of the change and it's implications they could make an informed decision as to whether or not to stay in the scheme, and wouldn't take much out of their day. For those that haven't thought about their scheme, it might also be a good opportunity for them to think about their investments. So in summary, I think the default provider changing wouldn't be overly disruptive.

Any other feedback?

Fern Donovan

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

I think that default funds should be ethical and focus on sustainable and practices. They most definitely should not have anything to do with fossil fuels.

Which fees option do you prefer and why?

Should default funds be used to promote responsible investment? If yes, how should this be done?

How disruptive would it be for a person if their default provider changed?

Any other feedback?

Finn Ross

Organisation

Lake hawea Station

In what capacity are you making this submission?

Business

What is your feedback on the investment mandate options for default funds?

Change the default KiwiSaver settings to a robust ‘responsible investment’ criteria, which uses sector exclusion policies, in particular, mandatory exclusion of the fossil fuel industry.

Which fees option do you prefer and why?

Should default funds be used to promote responsible investment? If yes, how should this be done?

How disruptive would it be for a person if their default provider changed?

Any other feedback?

Frank Jensen

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

Should change to responsible investment

Which fees option do you prefer and why?

Conservative

Should default funds be used to promote responsible investment? If yes, how should this be done?

Yes

Move investment default away from pollution industries

How disruptive would it be for a person if their default provider changed?

Not a big problem

Any other feedback?

Nz needs to be a world leader in responsible investment.

Gail Powell

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

Change the default KiwiSaver settings to a robust ‘responsible investment’ criteria, which uses sector exclusion policies, in particular, the exclusion of the fossil fuel industry (Option 1).

Adopt a certification regime for all KiwiSaver providers, so investment funds are transparent and accountable so they cannot greenwash their way around responsible investments.

Which fees option do you prefer and why?

No view

Should default funds be used to promote responsible investment? If yes, how should this be done?

Absolutely.

How disruptive would it be for a person if their default provider changed?

Not at all.

Any other feedback?

Gavin James

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

Which fees option do you prefer and why?

No comment

Should default funds be used to promote responsible investment? If yes, how should this be done?

Yes.

Change the default KiwiSaver settings to robust ‘responsible investment’ criteria, which use sector exclusion policies, in particular, mandatory exclusion of the fossil fuel industry (Option 1).

Adopt a certification regime for all KiwiSaver providers, so investment funds are transparent and accountable so providers cannot greenwash their way around responsible investments.

How disruptive would it be for a person if their default provider changed?

Not for me if I knew the reason. I suspect that would be the case for many contributors.

Any other feedback?

Gerald Parsonson

Organisation

Parsonson Architects

In what capacity are you making this submission?

Business

What is your feedback on the investment mandate options for default funds?

Option 1 is preferred as it is tailored to age. We request that the fossil fuel industry be excluded from default fund portfolios, as investments in the fossil fuel industry pose a material, sociopolitical, reputational, and financial risk to shareholders.

Which fees option do you prefer and why?

If a provider is putting in good effort and providing a good or above average return they should charge a better fee. If providers fees are restricted to the minimum through a tight tendering process then it is human nature this will reflect itself in the performance of the fund, just look at examples of building companies and building consultants having to peel costs to the bone to win a government tender, and the fall out afterwards, leaky buildings, bankruptcy etc.

Option 3, fees decreasing as the investment increases is desirable.

Option 4, encouraging young to sign into Kiwisaver is important.

Should default funds be used to promote responsible investment? If yes, how should this be done?

Definitely yes. We are in a climate crisis. Political and industry action is just too slow. Apart from school kids striking, one way of waking up is to bring these considerations into the financial arenas.

The fossil fuel industry has over five times the amount of coal, oil, and gas than is safe to burn in order to restrict temperature. Given the direct link between the fossil fuel industry’s business model and the impacts of climate change, investments in this industry pose a serious risk for shareholders.

Financial risk: Investment in coal, oil, and gas projects will become stranded assets. Various fossil fuel products have entered structural decline. Therefore, it is irresponsible for default KiwiSaver products, which in nature are long-term investments to invest in the fossil fuel industry. A review of Australian ethical investment funds are high performing.

Responsible investment with mandatory exclusion of the fossil fuel industry and a stable economy do not necessarily fall into conflict. Given the rate of climate breakdown and negative feedback loops in the Earth’s cooling systems, the government cannot afford to make compromises for the current economic model. The economy must be shifted and transformed to account for a fast and just transition away from fossil fuels. 350 Aotearoa urge the government to require mandatory exclusion of the fossil fuel industry in default Kiwisaver providers in order to signal this necessary shift.

How disruptive would it be for a person if their default provider changed?

Not very disruptive

Any other feedback?

We urge the government to adopt a wider certification regime, beyond default providers, to reinstate trust in KiwiSaver members and ensure transparency and accountability of fund providers in adhering to responsible investments.

We believe the duty to invest responsibly should fall on fund providers rather than Kiwisaver members. Given those fund providers have the economic literacy, access to information, and ultimately the decision-making over investments, there should be stricter policies in place to ensure fund providers are transparent and accountable to the public. For example, Partners for Carbon Accounting Financials have developed a model for the finance sector to accurately report on carbon emissions. This sort of reporting is effective because it holds the finance sector to account for its role in enabling fossil fuel projects to go ahead. 350 Aotearoa believe a reporting model like this would increase transparency and accountability.

Gisela Gordo

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

My preferable option is a Balanced fund for default Kiwisaver option. My second

option is the life-stages.

Which fees option do you prefer and why?

The government sets the fee for default providers. I believe this should be done to ensure everyone has access to an ethical and responsible option of a low-fee Kiwisaver fund, that also has a reasonable return on investment.

Should default funds be used to promote responsible investment? If yes, how should this be done?

YES, this is essential to steer investment in the right direction for the changes that need to happen at a systematic level (e.g clean energy). The default Kiwisaver should absolutely exclude investments in fossil fuels (to help comply with the Zero Carbon Bill and the Paris agreement&#39;s target), gambling, pornography and weapons

I also fully support 350.org Aotearoa's statements as follows:

Financial risk: Failure to account for falling power prices, the rapid growth of renewable energy, flat or falling energy demand, and new emissions-control policiescan result in coal, oil, and gas projects becoming stranded assets. Various fossil fuel products have entered structural decline, which by definition is a long-term shift that transcends cyclical ups and downs. Therefore, it is irresponsible for default KiwiSaver products, which in nature are long-term investments to invest in a high-risk industry, like the fossil fuel industry.

The economy must be shifted and transformed to account for a fast and just transition away from fossil fuels. I urge the government to require mandatory exclusion of the fossil fuel industry in default Kiwisaver providers in order to signal this necessary shift.

I believe the duty to invest responsibly should fall on fund providers rather than Kiwisaver members. Given those fund providers have the economic literacy, access to information, and ultimately the decision-making over investments, there should be stricter policies in place to ensure fund providers are transparent and accountable to the public. For example, Partners for Carbon Accounting Financials have developeda model for the finance sector to accurately report on carbon emissions. This sort of reporting is effective because it holds the finance sector to account for its role in enabling fossil fuel projects to go ahead. I believe a reporting model like this would increase transparency and accountability.

How disruptive would it be for a person if their default provider changed?

Non- disruptive at all. The default option should automatically change to the new one. People should be informed and let know that if they want to opt for a different option they can as it always have been the case.

Any other feedback?

I believe that the Review Discussion Paper's statement about the fact that choosing a responsible and ethical fund as the default may lead to higher fees is unfounded. And this would not be true if the government sets up the fees anyways for the default option

Mindfulmoney.co.nz provides a great tool for people to look into other options for ethical and responsible funds.

Overall, the government should encourage and incentivise financial institutions to provide much more transparency about where each option of Kiwisaver funds is investing people's money so people can better choose with better clarity the option that best suit our values (at the moment the information is very limited)

Glen Crowther

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

Which fees option do you prefer and why?

Zero-fees for under 18s or people with low KiwiSaver balances (e.g. under $10,000).

Should default funds be used to promote responsible investment? If yes, how should this be done?

Yes. Change the default KiwiSaver settings to prohibit default providers from investing in particular sectors or industries or require them to meet certain certification standards. A robust ‘responsible investment’ criteria is needed, which includes mandatory exclusion of the fossil fuel industry.

How disruptive would it be for a person if their default provider changed?

Not very much at all.

Any other feedback?

Adopt a certification regime for all KiwiSaver providers, so investment funds are transparent and accountable, so they can't "greenwash" their way around responsible investments.

Graham Hood

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

Default funds should be fossil free in particular and socially responsible in general

Which fees option do you prefer and why?

Should default funds be used to promote responsible investment? If yes, how should this be done?

Yes

How disruptive would it be for a person if their default provider changed?

Not at all

Any other feedback?

Gunther Gordon Hammer

Organisation

In what capacity are you making this submission?

Business

What is your feedback on the investment mandate options for default funds?

Public investment and default funds should not be used to support fossil fuel and gas exploration any longer.

Which fees option do you prefer and why?

I support option 1.

Should default funds be used to promote responsible investment? If yes, how should this be done?

By informing and revealing to the general public the history of investment funds. The future of our planet is in the balance.

What are the choices? Public awareness campaign that choices have to lead us into the future and be truly sustainable.

How disruptive would it be for a person if their default provider changed?

It is time we all carry some responsibility for the urgently needed change. This has been a long time coming to recognize, (about 40 years since the inception of the 'Club of Rome' study ) and realization and response are still slow.

Any other feedback?

How is possible that shareholders interests and company profits still override climate change emergencies and a looming environmental catastrophe?

Guy Bibby

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

Default schemes must be fossil free. They should also be ethical.

They should have the lowest fees.

Which fees option do you prefer and why?

The fees are far too high for most funds. On a global comparison it’s embarrassing. And most people I have spoken too have no idea and don’t care. Investments are one thing where you don’t get what you pay for. It’s a rort.

Should default funds be used to promote responsible investment? If yes, how should this be done?

Yes. Any default fund must be ethical (and in particular fossil free). It would be best that if an organisation wanting to promote and have a default fund should have all of their funds fossil free (so they can’t hide by just having one that’s ethical)

How disruptive would it be for a person if their default provider changed?

I wouldn’t imagine anyone would care or really notice

Any other feedback?

Harry Curry

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

Which fees option do you prefer and why?

Should default funds be used to promote responsible investment? If yes, how should this be done?

Fossil fuels free.

How disruptive would it be for a person if their default provider changed?

Any other feedback?

Hinrich Schaefer

Organisation

none

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

looks fine

Which fees option do you prefer and why?

the government should set the fees and fees should be zero for under 18 year-olds and people with low balances

Should default funds be used to promote responsible investment? If yes, how should this be done?

Absolutely yes. KiwiSaver schemes must not finance war or environmental destruction. Of particular importance is to divest all KiwiSaver schemes from funds related to fossil-fuel industries. Apart from moral and environmental reasons, the move to divest is necessary to avoid stranded assets as oil gas and coal projects will become unprofitable with inevitably rising carbon costs and competition from cheaper renewable energy sources. The projects will also be unable to find insurance cover. Economic and societal damage created by climate change due to fossil-fuel industries will also disrupt the lives of kiwisavers, therefore possible short-term cuts in savings returns are not a reason to stay invested in fossil fuels.

How disruptive would it be for a person if their default provider changed?

I don't see that it would have to be. I recently changed providers voluntarily and without any difficulties.

Any other feedback?

THe opportunity to regulate responsible investment, particularly divesting from fossil-fuel industries, must not be missed in order to maintain the financial security of kiwisavers and the wider society.

Howard Gover

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

I think that the default option should be a balanced fund with 35 to 60 percent in growth assets.

Which fees option do you prefer and why?

Should default funds be used to promote responsible investment? If yes, how should this be done?

Yes. Avoid investment in fossil fuel industry. Long term this is likely to be in decline.

How disruptive would it be for a person if their default provider changed?

I changed Kiwi fund providers at one stage and it was quite easy. Nowadays with stringent identification procedures with financial providers it may be more difficult. I find Citizen Advice Bureaus that have available a JP, useful when identification is required.

Any other feedback?

I think easily accessible information for people in, or about to be in default funds is important. Unions and schools can do more on financial literacy, particularly on kiwi saver. Some usual references are :

https://fundfinder.sorted.org.nz/must-knows-of-kiwisaver/#returns

https://www.moneycompare.co.nz/compare/kiwisaver.kiwisaver?showFilters=1

I have been asked about investing in a Kiwisaver fund. I referred the person to a site where they could make their own comparison and decisions.

Hugh

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

I think we should ensure that all KiwiSaver funds are fossil fuel free, and ethical investments so that people who are less informed about how their KiwiSaver is invested can have peace of mind.

Which fees option do you prefer and why?

Growth

Should default funds be used to promote responsible investment? If yes, how should this be done?

Yes, choosing funds that are held to the highest ethical standard is necessary because I have witnessed first hand that ‘responsible’ funds upon closer inspection are tied to all sorts of exploititative companies either of people or natural environment.

How disruptive would it be for a person if their default provider changed?

Ideally not disruptive at all. The disrupt should be for KiwiSaver providers not doing the right thing.

Any other feedback?

No thank you.

Ian Wroe

Organisation

GoodTeam Limited

In what capacity are you making this submission?

Business

What is your feedback on the investment mandate options for default funds?

I support the adoption of Option 1 and advise that the fossil fuel industry be excluded from default fund portfolios, as investments in the fossil fuel industry pose a material, sociopolitical, reputational, and (critically for all investors) a financial risk to shareholders. The platform for urgent action is totally evendent in science, news cycle and the natural world. Exclusion not management is the correct route.

Which fees option do you prefer and why?

No comment

Should default funds be used to promote responsible investment? If yes, how should this be done?

Yes,

How disruptive would it be for a person if their default provider changed?

No comment

Any other feedback?

I urge the government to adopt a wider certification regime, beyond default providers, to reinstate trust in KiwiSaver members and ensure transparency and accountability of fund providers in adhering to responsible investments. Greenwashing is arguably the biggest threat to attaining a turnaround of the climate risk, so this measure is essential.

jack Santa Barbara

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

A responsible investment criteria should be used to exclude the fossil fuel industry. Not only is this sector exceedingly harmful to people and the environment, but also costs humanity in excess of $5 Trillion dollars annually ( IMF, 2015 https://www.imf.org/external/pubs/ft/wp/2015/wp15105.pdf ). In addition, this is an increasingly risky sector to invest in as trillions of investment dollars have been withdrawn over the last few years. These investment funds are often being transferred to renewable energy projects. This renewable energy sector should be favored by KiwiSaver given the urgency of dealing with climate change.
Adopt a certification regime for all KiwiSaver providers, so investment funds are transparent and accountable so they cannot greenwash their way around responsible investments.

Which fees option do you prefer and why?

Should default funds be used to promote responsible investment? If yes, how should this be done?

How disruptive would it be for a person if their default provider changed?

Any other feedback?

Jamie Hosking

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

I support the 350 Aotearoa submission, as follows:

Responsible investment with mandatory exclusion of the fossil fuel industry and a stable economy do not necessarily fall into conflict. Given the rate of climate breakdown and negative feedback loops in the Earth’s cooling systems, the government cannot afford to make compromises for the current economic model. The economy must be shifted and transformed to account for a fast and just transition away from fossil fuels. 350 Aotearoa urge the government to require mandatory exclusion of the fossil fuel industry in default Kiwisaver providers in order to signal this necessary shift.

We believe the duty to invest responsibly should fall on fund providers rather than Kiwisaver members. Given those fund providers have the economic literacy, access to information, and ultimately the decision-making over investments, there should be stricter policies in place to ensure fund providers are transparent and accountable to the public. For example, Partners for Carbon Accounting Financials have developed a model for the finance sector to accurately report on carbon emissions. This sort of reporting is effective because it holds the finance sector to account for its role in enabling fossil fuel projects to go ahead. 350 Aotearoa believe a reporting model like this would increase transparency and accountability.

Which fees option do you prefer and why?

Should default funds be used to promote responsible investment? If yes, how should this be done?

How disruptive would it be for a person if their default provider changed?

Any other feedback?

Jane Langley

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

Change the default KiwiSaver settings to a robust ‘responsible investment’ criteria, which uses sector exclusion policies, in particular, the exclusion of the fossil fuel industry (Option 1).
Adopt a certification regime for all KiwiSaver providers, so investment funds are transparent and accountable so they cannot greenwash their way around responsible investments.

Which fees option do you prefer and why?

Should default funds be used to promote responsible investment? If yes, how should this be done?

Change the default KiwiSaver settings to a robust ‘responsible investment’ criteria, which uses sector exclusion policies, in particular, the exclusion of the fossil fuel industry (Option 1).

Adopt a certification regime for all KiwiSaver providers, so investment funds are transparent and accountable so they cannot greenwash their way around responsible investments.

How disruptive would it be for a person if their default provider changed?

Not at all.

Any other feedback?

Jane ough

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

Should be fossil fuel free

Which fees option do you prefer and why?

Should default funds be used to promote responsible investment? If yes, how should this be done?

Yes ensure investing in renewables - plastic and fossil fuel free

How disruptive would it be for a person if their default provider changed?

Not at all

Any other feedback?

Hurry up this is an emergency

Janet Charman

Organisation

N/A

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

They should be ethical. Hence in the face of the intergenerational emergency of irreversible climate heating they must be identified as to their attainment of carbon neutrality and energy renewability.

Which fees option do you prefer and why?

We need a fees option which is transparent and contestable because individuals and businesses should not be shamelessly profiteering off our pensions

Should default funds be used to promote responsible investment? If yes, how should this be done?

Yes.

Key indicators for investment products should factor in the product's ethical 'health'. This should be represented as a graduated scale (traffic light system) in both environmental and human rights issues, which means of measurement is constantly widely publicized to investors in Kiwisaver.

Investors should be able to transparently see at a glance how a particular product measures up on a universally agreed and regularly updated set of ethical and environmental criteria.

How disruptive would it be for a person if their default provider changed?

Not disruptive at all for a person to change their default provider.

But it could be (quite rightly) disruptive for their provider's profits though. That would be an incentive for the provider of investment options to ensure they only promote ethical and renewable investments.

Any other feedback?

There must be a sense of profound urgency about this change to ethical investment in renewables and to genuinely carbon neutral investment products as we only have about a 10 year window of opportunity to make a meaningful alteration in the escalating odds of an irreversible climate change cataclysm.

Ethical investment also includes illuminating and refusing the use of exploitative and dangerous labour practices at every point on the supply chain. Transparency on that front must be equally integral to the ethical assessment of any investment product.

Janet S. Thomson

Organisation

n/a

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

answers to mall boxes as below >>>

Which fees option do you prefer and why?

Should default funds be used to promote responsible investment? If yes, how should this be done?

How disruptive would it be for a person if their default provider changed?

Any other feedback?

I wish to endorse the comments and requests from 350 Aotearoa and request the government to ensure that all default KiwiSaver options are fossil free.

It is not right that New Zealanders are unknowingly contributing to the climate crisis with our KiwiSaver accounts investing in fossil fuel companies that are pushing new projects in other countries. Our money should not be enabling new coal, oil, or gas projects that wreck local ecosystems, pollute waterways, and harm people's health. Our savings should not undermine our chances of limiting warming to 1.5C. It’s time to change the default.

In particular -- Please:

Change the default KiwiSaver settings to a robust ‘responsible investment’ criteria, which uses sector exclusion policies, in particular, mandatory exclusion of the fossil fuel industry (Option 1).
Adopt a certification regime for all KiwiSaver providers, so investment funds are transparent and accountable so they cannot greenwash their way around responsible investments.

Thank you.

Jeffery Saunders

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

It is clear that same old same old approaches to investment must change, and I support government and companies avoiding any investment that is environmentally reckless.

Which fees option do you prefer and why?

Should default funds be used to promote responsible investment? If yes, how should this be done?

It is obvious that blind investment of this sort must not continue. Are weapons companies also invested in by default? Is there any intelligent person or persons who can change the existing default setting to be more responsible?

How disruptive would it be for a person if their default provider changed?

So long as investment decisions are made prudently, surely there wouldn't be a problem. Are there individuals involved in this process who are endowed with intelligence?

Any other feedback?

This situation cannot continue. NZ must lead the world in ethical behaviour because quite clearly larger countries cannot. It is crucial that a country that prizes quality of life for all must act on this issue immediately.

Jennifer Orman

Organisation

Primary School Trustee

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

Please ensure that default funds (I personally am a default fund member) are not invested in hugely irresponsible investments like oil and gas.

Which fees option do you prefer and why?

No comment

Should default funds be used to promote responsible investment? If yes, how should this be done?

Yes, default funds should definitely be used to promote responsible investment. Investing in fossil fuel companies should DEFINITELY BE BANNED!

How disruptive would it be for a person if their default provider changed?

I don't think it would need to be disruptive at all.

Any other feedback?

Jenny Neligan

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

I would like the fossil fuel industry to be excluded from default funds and it be regulated and compulsory that they are. As we move to renewable energy fossil fews are going to become an investment risk.

Which fees option do you prefer and why?

My understanding is that there is no justification for the fees providers charge and that Kiwisaver as been a cash cow for them. As a lay person I prefer option one without fully understanding the implications of the others. I would like to be able to trust the regulators to act in the public interest and set regulations that work for the greater good ie more funds for the public which means more funds invested for the country.

Should default funds be used to promote responsible investment? If yes, how should this be done?

Yes very definitely. If the government doesn't ensure investments are made the responsible who will? Surely government regulations are essential to make providers take responsibility to invest ethically. If it means lower returns in the short term before it leads to higher, possibly, in the long term then so be it. Collectively we have too much to lose, (global heating springs to mind) by not regulating this aspect of Kiwisaver investment.

How disruptive would it be for a person if their default provider changed?

I don't understand why it would be disruptive at all if their default provider changed.

Any other feedback?

Kiwisaver is a fantastic initiative and anything we can do to make it work better for the people of New Zealand and the country as a whole is supported. I dont see why individual businesses (providers) should get filthy rich from this scheme and welcome any regulation that keeps it fair.

Jeroen J Lurling

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

Which fees option do you prefer and why?

Option 1. We should be using every tool we have to reduce new Zealands greenhouse gas emissions. Excluding providers with fossil fuel investments from the default options is in line with our carbon zero act and Paris agreement goal of limiting warming to 1.5 degrees Celsius. It is the responsible option.

Should default funds be used to promote responsible investment? If yes, how should this be done?

Definitely. The fossil fuel industry should be excluded from default fund portfolios, as investments in the fossil fuel industry is risky as our values and policies move towards renewable. It is also incredibly reckless and puts the governments reputation at risk, along with the wellbeing of our cimmunities and environment. It is essential to act now and not by half measures.

Government needs to lead in this role.

I also feel the government needs to adopt a certification regime, to increase transparency and accountability. For example, Partners for Carbon Accounting Financials, to report on carbon emissions.

How disruptive would it be for a person if their default provider changed?

I would not find it disruptive, quite the opposite, I would find it incredibly helpful. People are very busy, they often don't have the time or the info to change their super investments.

Any other feedback?

John Coe

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

Which fees option do you prefer and why?

Should default funds be used to promote responsible investment? If yes, how should this be done?

Yes they should be at all times. Sadly the only thing that will influence people who put profit first [ and many directors see their primary role as making money for their shareholders] is to be affected financially if they take a certain course of action. Having their share price reduced by Kiwisaver not investing in them helps removes the option of them being able to borrow to expand based on loan to ratio percentages. A lot of business people are only interested in next years profits , not any long term perspective, and only the financial threat of losing share pricing power will have any affect on their thinking.

How disruptive would it be for a person if their default provider changed?

Any other feedback?

John Paynter

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

Default funds should not necessarily go to the conservative fund but one that better matches the investor's needs. Preferably they would have to complete a quick appraisal to determine their risk profile. If this cannot be done then they should be put in a fund suitable for their age. This may not always work, as some saving for a home may be better off in a conservative fund whilst others reaching "retirement age" e.g. me next year, may prefer a growth fund (I have other investments and KS is my smallest).

Which fees option do you prefer and why?

The lowest possible cost, so disruptors such as Simplicity should be encouraged. It makes little sense to have a set percentage figure as high $ value investments take no more management than small ones.

Should default funds be used to promote responsible investment? If yes, how should this be done?

Difficult, as who determines what is responsible and what is not? e.g. EVs are said to be environmental but that neglects the child labour exploited in mineral extraction and the cost of disposing of them.

How disruptive would it be for a person if their default provider changed?

Very little.

Any other feedback?

I would rather the NZ Super Fund managed mine and was the default provider. I would rather the profits be kept in the country than channeled off shore (e.g. to the Australian banks who have a large KS market share).

Jonny Osborne

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

Which fees option do you prefer and why?

Should default funds be used to promote responsible investment? If yes, how should this be done?

How disruptive would it be for a person if their default provider changed?

Any other feedback?

Kiwisaver default providers should be banned from investing in the fossil fuel industry, and any other industries that profit directly from the fossil fuel industry.

Kiwisaver default providers should be encouraged - but not forced - to consider investing in industries that will help limit the severity of the climate crisis.

Josh Finegan

Organisation

Victoria University of Wellington

In what capacity are you making this submission?

Researcher or academic

What is your feedback on the investment mandate options for default funds?

N/A

Which fees option do you prefer and why?

N/A

Should default funds be used to promote responsible investment? If yes, how should this be done?

I stand with 350 Aotearoa, who urge the government to change the default KiwiSaver settings and implement robust criteria for ‘responsible investment’, which utilises negative-screening through sector exclusion policies, in particular, the exclusion of the fossil fuel industry.

How disruptive would it be for a person if their default provider changed?

N/A

Any other feedback?

N/A

Judy Newton

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

Change the default KiwiSaver settings to a robust ‘responsible investment’ criteria, which uses sector exclusion policies, in particular, mandatory exclusion of the fossil fuel industry
Adopt a certification regime for all KiwiSaver providers, so investment funds are transparent and accountable so they cannot greenwash their way around responsible investments

Which fees option do you prefer and why?

My priority is that it is a sustainable and ethical investment.

Should default funds be used to promote responsible investment? If yes, how should this be done?

Yes

How disruptive would it be for a person if their default provider changed?

If it were changed to a responsible investment it would be a very positive step.

Any other feedback?

Julia Lindesay

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

Which fees option do you prefer and why?

Should default funds be used to promote responsible investment? If yes, how should this be done?

Change the default KiwiSaver settings and implement a robust criteria for ‘responsible investment’, which utilises negative-screening through sector exclusion policies, in particular, the exclusion of the fossil fuel industry. The fossil fuel industry should be excluded from default fund portfolios, as investments in the fossil fuel industry pose a material, sociopolitical, reputational, and financial risk to shareholders.

How disruptive would it be for a person if their default provider changed?

I have had my kiwisaver provider changed several times - it was not that disruptive.

Any other feedback?

Julia Zhu

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

Unfortunately, climate change is happening more quickly than scientists feared, and will impact our lifetimes and our children.

It may be too late to prevent collapse of western civilisation, but it will definitely be too late if fossil fuels aren't kept in the ground.

Capitalism needs to adapt to the new realities of phasing out fossil fuels.

Please make fossil-free investment options available to all New Zealanders, so money can be diverted away from fossil fuels and towards renewables.

Which fees option do you prefer and why?

no comment

Should default funds be used to promote responsible investment? If yes, how should this be done?

I think divesting from fossil fuels is enough, let consumers choose whether their fund should go further in supporting renewables, sustainable agriculture, and avoiding weapon manufacturers for example

How disruptive would it be for a person if their default provider changed?

not disruptive

Any other feedback?

Government must do what it can to move away from "business as usual". People think there isn't really a problem if no-one is doing anything about the climate crisis.

Julie Burns

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

Please adopt option 1 and minimize the horrendous suffering our grandchildren are facing.

Which fees option do you prefer and why?

Should default funds be used to promote responsible investment? If yes, how should this be done?

How disruptive would it be for a person if their default provider changed?

Any other feedback?

Julie Marshall

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

Which fees option do you prefer and why?

Should default funds be used to promote responsible investment? If yes, how should this be done?

I believe all default funds should go into an ethical investment fund.

How disruptive would it be for a person if their default provider changed?

Any other feedback?

Julie Timmins

Organisation

n/a

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

Balanced.

Which fees option do you prefer and why?

I like the zero fees for those with lower balances and for younger savers. I think the Government should set a cap. A clear message needs to be sent that fees built into offerings is illegal. All fees need to be transparent and the sector threatening to raise fees should be immediately investigated.

Should default funds be used to promote responsible investment? If yes, how should this be done?

Default providers should have a mandate to invest responsibly. This includes no military or harm to children. At this time, it most particularly should exclude fossil fuels. Not only are they harmful in every way, but at this stage are a bad investment. I am weary of hearing that it is hard to invest responsibly and that it may lead to higher fees. There is so much information out there that can be accessed and how about putting higher priniciples before return? If anyone should do this, it should be the default providers who do nothing and are gifted investors.

How disruptive would it be for a person if their default provider changed?

Not at all.

Any other feedback?

June

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

Fossil fuels investments should be excluded from default kiwisaver funds.

Which fees option do you prefer and why?

Should default funds be used to promote responsible investment? If yes, how should this be done?

Sustainable only

How disruptive would it be for a person if their default provider changed?

Any other feedback?

Karl Menzies

Organisation

In what capacity are you making this submission?

Individual consumer

What is your feedback on the investment mandate options for default funds?

I support a change the default KiwiSaver settings to a robust ‘responsible investment’ criteria, which uses sector exclusion policies that are not supportive of any sectors that pose a material, sociopolitical, reputational, and financial risk to shareholders and to a sustainable future for New Zealand.

Which fees option do you prefer and why?

I support the mandatory exclusion on the fossil fuel industry (Option 1)

The use of fossil fuel industry in investments creates multiple risks including

Material risk: The fossil fuel industry has over five times the amount of coal, oil, and gas than is safe to burn in order to curb temperature rise to 1.5C warming pre-industrial levels. Given the direct link between the fossil fuel industry’s business model and the impacts of climate change, investments in this industry pose a material risk for shareholders.
Financial risk: Failure to account for falling power prices, the rapid growth of renewable energy, flat or falling energy demand, and new emissions-control policies can result in coal, oil, and gas projects becoming stranded assets. Various fossil fuel products have entered structural decline, which by definition is a long-term shift that transcends cyclical ups and downs. Therefore, it is irresponsible for default KiwiSaver products, which in nature are long-term investments to invest in a high-risk industry, like the fossil fuel industry.
Reputational risk: The socio-political landscape is rapidly changing as the majority of New Zealanders report being concerned about climate change. There is increased scrutiny on government, investment fund providers, among other institutions to be accountable for their relationship to the fossil fuel industry and the emissions their finance is enabling. Notable social indicators signal the public’s disapproval of the fossil fuel industry that include the divestment movement, which globally has shifted over USD$11 trillion worth of investment portfolios away from the fossil fuel industry, the large mobilisations of students and supporters for School Strike for Climate, and the government’s signal policy to ban new offshore oil and gas permits.

Should default funds be used to promote responsible investment? If yes, how should this be done?

Yes absolutely default funds be used to promote responsible investment - Around 715,000 New Zealanders still use their default Kiwisaver provider.

The default provider should provide clear and easy to understand investment options that benefit the a sustainable future for NZ while enabling investment savings for investors, so these should be high priority on the selection criteria of default fund providers .

The duty to invest responsibly should fall on fund providers rather than Kiwisaver members to provide a clear rating on their investment options and the effect each option has on the New Zealand environment. For example, Partners for Carbon Accounting Financials have developed a model for the finance sector to accurately report on carbon emissions.

Adoption of a certification regime for all KiwiSaver providers, so investment funds are transparent and accountable and promote responsible investments

This model should be required to be applied to default fund investments (and all Kiwisaver fund investments) so that they are transparent on a carbon footprint value for each investment.

To ensure this is applied stricter policies should be in place to ensure fund providers are transparent and accountable to their members

How disruptive would it be for a person if their default provider changed?

There would be a minor disruption to a person if their default provider changed. This is because there is policy in place by the KiwiSaver act and there are secure and protective processes and capabilities in place for Provviders and Inland Revenue to ensure effective transfers to new providers are managed while protecting members funds.

Any other feedback?

This is an important decision that will support the climate change initiative to reduce NZ carbon emission footprint. Please support Option 1 to hcange the default KiwiSaver settings to a robust ‘responsible investment’ criteria, which uses sector exclusion policies, in particular, mandatory exclusion of the fossil fuel industry (Option 1).

Kathleen Gallagher