The question the Financial Inclusion Centre raises in our new report ‘Making an impact or making a return?’ is whether we can distinguish between finance that genuinely prioritises making a social impact and impact washing, essentially the social version of greenwashing.
The market for social impact, and sustainable finance generally, is burgeoning. The absence of clear standards and definitions means that as the market grows so do the risks of impact washing.
It is hard enough to validate the contribution finance makes to environmental goals. Corporate Adviser magazine should be congratulated on leading the way in producing hard data on the carbon footprints contained in pension funds in its ESG in DC Pensions report. Yet, it is even harder to validate the impact finance makes on social issues.
Special recognition should be reserved for investing in companies with top quartile performance on social issues such as fair wages, ethnicity and gender pay gaps rather than simply meeting expectations not to behave badly.
We also argue that substituting state funding with private finance eventually comes at a cost to the taxpayer and the public who use these services, with some of the current financing models sold as social impact reminiscent of the controversial PFI programme.
Investment returns we observed during the research were eye-watering. We found asset managers claiming to generate annual returns of between 8 to 13 per cent investing in ‘social’ and student housing.
Worryingly, the FCA’s flagship sustainable investment label could actually provide official legitimacy for what we think would be social impact washing. The FCA suggested an example of a hypothetical investment fund called the ‘ABC Social Impact Real Estate Fund’, investing in and making profits from properties used by local authorities to house homeless people and counting as eligible assets for using the Sustainability Impact label.
This opens the door for investment funds to claim that making profits from other social assets such as children’s residential care, should also be classified as ‘Impact’ with a knock-on effect across TPR-regulated entities. We would like the FCA to think again.
These tests can be used to distinguish between finance that prioritises positive social impact, sustainable finance that makes an impact while making returns, socially neutral finance, socially harmful finance, and impact washing.
To emphasise, we are not saying that financial activities which do not pass all the tests are ‘bad’. These tests can also be aligned with users’ own expectations. For example, a pension fund may seek to generate a market return but only by investing in companies which comply with the other tests. The fund can at least be said to be not causing social harm. However, we would argue this is ‘socially sustainable’ or ‘socially neutral’, not a positive social impact strategy.
These tests would set a new, but not unreasonably high, bar. Otherwise, our fear is that unless we start to apply tougher tests, we could see a huge extraction of market returns from social assets coupled with impact washing.
▪ To be classified as true social impact finance, financial institutions should be willing to forgo market level returns. Investment which seeks to generate a market return and makes a positive, evidence-based, impact should be classified as socially sustainable to distinguish from dedicated social impact finance
▪ To qualify as social impact or sustainable finance, there should be no corporate
welfare involved
▪ Financial institutions should drive the highest standards on issues such as fair wages, diversity and inclusion, and working conditions not just meet minimum standards
▪ Follow the do no harm principle. Finance which produces a positive social impact in one area should not cause harm in another
▪ Financing ‘social sector’ or ‘inclusion’ assets (eg social care, social housing, education, levelling up, community lending) should not be automatically classified as social impact or sustainable finance unless the other conditions are met.
▪ Domestic or overseas ‘development finance’, such as investing in deprived areas of UK or Low or Middle Income Countries (LMICs), should not be automatically classified as social impact unless the other tests are met