GRI Index

This report covers calendar year 2022 and aligns with the Global Reporting Initiative (GRI) reporting guidelines and its core reporting option and Sustainability Accounting Standards Board (SASB) metrics for Asset Management & Custody Activities. The table below shows where you can find the information related to the various metrics. While most information is found in this report, other primary sources include: Invesco’s 2022 Annual Report, Form 10-K, 2022 Proxy Statement, 2022 CDP submission, Climate Change Report, 2022 ESG Investment Stewardship Report and our corporate website.

Disclosure Number Disclosure Location/Response
General Disclosures
GRI 2: General Disclosures 2022
The organization and its reporting
2-1 Organizational details

Invesco Ltd.

Atlanta, GA, USA

2-2 Entities included in the organization’s sustainability reporting 2022 Form 10-K, pg. 2
2-3 Reporting period, frequency and contact point


Year end: December 31, 2022

2-4 Restatements of information We restated environmental data (pgs. 43, 46) from years 2019, 2020 and 2021 following updates to methodology as a result of the data assurance process in 2022.
2-5 External assurance Invesco seeks limited assurance for Scope 1 and Scope 2 data.
Activities and workers
2-6 Activities, value chain and other business relationships 2022 Form 10-K, Business, pgs. 2–8
2-7 Employees CR indicators>Social Indicators
2-8 Workers who are not employees CR indicators>Social Indicators
2-9 Governance structure and composition 2022 Proxy, Committee Membership and Meetings, pgs. 14–15
2-10 Nomination and selection of the highest governance body 2022 Proxy, Director Recruitment, pgs. 19–20
2-11 Chair of the highest governance body Marty L. Flanagan serves as president of the Board of Directors and chief executive officer.
2-12 Role of the highest governance body in overseeing the management of impacts 2022 Proxy, Our Risk Management Framework pg. 23
2022 Proxy, Board’s Role in Risk Oversight, pg. 22
2-13 Delegation of responsibility for managing impacts 2022 Proxy, Environmental, Social and Governance (ESG) responsibility, pgs. 24-28
2-14 Role of the highest governance body in sustainability reporting Our CR program
2-15 Conflicts of interest Ethics & compliance
2-16 Communication of critical concerns 2022 Proxy, Communications with the Chair and other non-executive directors, pg. 22
2-17 Collective knowledge of the highest governance body 2022 Proxy, Director orientation and continuing education and development, pg. 20
2-18 Evaluation of the performance of the highest governance body 2022 Proxy, Board evaluation process, pg. 20
2-19 Remuneration policies 2022 Proxy, Our compensation framework, pgs. 45-50
2-20 Process to determine remuneration 2022 Proxy, The committee’s process for determining executive compensation, pgs. 57-58
2-21 Annual total compensation ratio 2022 Proxy, CEO pay ratio, pg. 72
Strategy, policies and practices
2-22 Statement on sustainable development strategy A message from Invesco’s President & CEO
2-23 Policy commitments
  • Code of Conduct
  • Code of Ethics and Personal Trading Policy
  • Conflict of Interest Policy
  • Director’s Code of Conduct
  • Global Anti-Bribery and Corruption Policy
  • Global Anti-Money Laundering/Counter-Terrorist Financing Policy
  • Global Financial Crime Prevention Policy
  • Global Fraud Escalation Policy Global Gifts and Entertainment Policy
  • Global Outside Business Activities Policy
  • Global Political Contributions
  • Global Remuneration
  • Global Violation Escalation
  • Identity Theft Prevention Program
  • Insider Trading Policy
2-24 Embedding policy commitments Ethics & compliance
2-25 Processes to remediate negative impacts Ethics & compliance
2-26 Mechanisms for seeking advice and raising concerns Ethics & compliance
2-27 Compliance with laws and regulations There were zero instances of non‑compliance in 2022.
2-28 Membership associations

A member of:

  • 30% Club Japan Investors Group
  • Asian Corporate Governance Association (ACGA)
  • Asia Investor Group on Climate Change (AIGCC)
  • Better Building Partnership (BBP)
  • Bipartisan Policy Center ESGTask Force
  • Carbon Disclosure Project
  • Coalition for Climate-Resilient Investment (CCRI) (founding member)
  • Climate Bonds Initiative
  • Confluence Philanthropy (Associate Advisor Menu)
  • Corporate Responsibility Interface Center (CRIC) (DACH countries)
  • Council of Institutional Investors (CII) (US)
  • Disclosures and Labels Advisory Group (DLAG)
  • Farm Animal Investment Risk & Return Initiative (FAIRR)
  • Global Real Estate Sustainability Benchmark (GRESB)
  • EFAMA Sustainable Finance Committee
  • ESG Disclosure Study Group (Japan)
  • Hong Kong Green Finance Association (HKGFA)
  • Investment Company Institute (ICI) (ICI Fund Disclosure Working Group, ICI Global ESG Task Force, and ICI Proxy Issues Working Group)
  • Investment Association (UK)
  • Investor Forum (UK)
  • Institutional Investors Group on Climate Change (IIGCC), including Net Zero Investment Framework working group
  • Italian Sustainable forum (ItaSIF)
  • Investment Management Education Alliance (IMEA)
  • Irish Funds ESG Legal committee
  • One Planet Asset Manager Initiative
  • Quoted Companies Alliance (QCA)
  • Responsible Investment Association (RIA) (Canada)
  • Responsible Investment Association Australasia (RIAA)
  • SASB Alliance
  • Task force on Climate-Related Financial Disclosures (TCFD) (Supporter and Discloser), TCFD Consortium
  • Transition Pathway Initiative
  • Task force on Nature-Related Financial Disclosures’ (TNFD) Forum
  • UK Sustainable Investment and Finance Association (UKSIF), including Board of Directors
  • World Economic Forum Financing the Transition to a Net Zero Future Working Group

A signatory to:

  • Principles for Responsible Investment (PRI)
  • EFAMA Stewardship Code
  • Indian Stewardship Code
  • Japan’s Stewardship Code
  • UK Stewardship Code
  • Net Zero Asset Managers Initiative

Additionally, GRESB provides the basis for the reporting, scoring and peer ranking of Invesco Real Estate’s (IRE’s) ESG management and policies:

  • IRE has submitted data to GRESB since 2012 and has been a GRESB member since 2014
  • In 2022, five IRE-managed strategies achieved five out of five Green Stars, placing them in the top 20% of all global submissions in 2022
Stakeholder engagement
2-29 Approach to stakeholder engagement Our CR program
2-30 Collective bargaining agreements Invesco retains strong relationships with its employees and does not disclose collective bargaining agreements at this time.
Material topics
GRI 3: Material Topics 2022
3-1 Process to determine material topics Our CR program
3-2 List of material topics Our CR program
3-3 Management of material topics Our CR program
GRI 200: Economic
GRI 201: Economic performance
3-3 Management of material topics 2022 Form 10-K, Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations, pgs. 27-59
201-1 Direct economic value generated and distributed 2022 Form 10-K, Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations, pgs. 27-59
201-2 Financial implications and other risks and opportunities due to climate change 2022 Form 10-K, Risks Related to Operations and Technology, pg. 13
201-3 Defined benefit plan obligations and other retirement plans 2022 Form 10-K, Retirement Benefit Plans, pgs. 89-93
201-4 Financial assistance received from government No financial assistance was received from the government in 2022.
GRI 205: Anti-corruption
3-3 Management of material topics Ethics & compliance
205-1 Operations assessed for risks related to corruption Ethics & compliance
205-2 Communication and training about anti-corruption policies and procedures Ethics & compliance

Anti-Bribery and Corruption and Fraud Prevention trainings are mandatory for all employees and directors and administered every other year.
205-3 Confirmed incidents of corruption and actions taken Zero incidents of corruption took place in 2022.
GRI 302: Energy
3-3 Management of material topic Energy & emissions
302-1 Energy consumption within the organization Energy & emissions
302-2 Energy consumption outside of the organization Energy & emissions
302-3 Energy intensity 3,083.51 kWh/employee
302-4 Reduction of energy consumption Energy & emissions
GRI 303: Water and effluents
3-3 Management of material topic Water & waste
303-1 Interactions with water as a shared resource Water & waste
303-2 Management of water discharge‑related impacts Water & waste
303-3 Water withdrawal Water & waste
303-4 Water discharge Water & waste
303-5 Water consumption Water & waste
GRI 305: Emissions
3-3 Management of material topic

Energy & emissions

EHS management

305-1 Direct (Scope 1) GHG emissions Energy & emissions
305-2 Energy indirect (Scope 2) GHG emissions Energy & emissions
305-3 Other indirect (Scope 3) GHG emissions Energy & emissions
305-4 GHG emissions intensity 2022 CDP Climate Change, C6.1, C6.2, 6.3, 6.4, 6.5, 6.10
305-5 Reduction of GHG emissions

Energy & emissions

EHS management

305-6 Emissions of ozone-depleting substances (ODS) N/A
305-7 Nitrogen oxides (NOX), sulfur oxides (SOX), and other significant air emissions N/A
GRI 306: Waste
3-3 Management of material topic Water & waste
306-1 Waste generation and significant waste‑related impacts Water & waste
306-2 Management of significant waste‑related impacts Water & waste
306-3 Waste generated Water & waste
306-4 Waste diverted from disposal Water & waste
306-5 Waste directed to disposal Water & waste
GRI 400: Social
GRI 401: Employment
3-3 Management of material topic People
401-1 New employee hires and employee turnover CR indicators
401-2 Benefits provided to full-time employees that are not provided to temporary or part-time employees Employee engagement & well-being
401-3 Parental leave CR indicators
GRI 403: Occupational health and safety
3-3 Management of material topic EHS management
403-1 Occupational health and safety management system EHS management
403-2 Hazard identification, risk assessment, and incident investigation EHS management
403-3 Occupational health services EHS management
403-4 Worker participation, consultation, and communication on occupational health and safety

Trained assessors audit each employee’s work space, and a third‑party risk assessment is executed annually for each office site. All offices are required to have an Invesco health and safety representative to manage the on-site occupational health and safety program and work with facilities and employees to ensure proper execution.

EHS management

403-5 Worker training on occupational health and safety Occupational Health and Safety training is required for every Invesco employee.

EHS management
403-6 Promotion of worker health

EHS management

Employee engagement & well-being

403-7 Prevention and mitigation of occupational health and safety impacts directly linked by business relationships EHS management
403-8 Workers covered by an occupational health and safety management system All employees, contractors and clients are covered by our EHS management system.
403-9 Work-related injuries For 2022, the total recordable injury rate (TRIR) was 0.01, and the lost time case (LTC) incident rate was 0.
GRI 404: Training and education
3-3 Management of material topic Professional development
404-1 Average hours of training per year per employee Professional development
404-2 Programs for upgrading employee skills and transition assistance programs Professional development
404-3 Percentage of employees receiving regular performance and career development reviews CR indicators
GRI 405: Diversity and Equal Opportunity
3-3 Management of material topic Diversity, equity & inclusion
Inclusive talent pipeline
405-1 Diversity of governance bodies and employees CR indicators
Inclusive talent pipeline
405-2 Ratio of basic salary and remuneration of women to men Fair compensation
UK Fair Gender Pay Gap Report
GRI 406: Non-discrimination
3-3 Management of material topic Diversity, equity & inclusion
406-1 Incidents of discrimination and corrective actions taken Fair labor practices
GRI 413: Local Communities
3-3 Management of material topic Resilient Communities
413-1 Operations with local community engagement, impact assessments, and development programs Financial literacy
Invesco Cares
Education support
413-2 Operations with significant actual and potential negative impacts on local communities Resilient Communities
GRI 415: Public Policy
3-3 Management of material topic Ethics & compliance
415-1 Political contributions Ethics & compliance
GRI 418: Customer Privacy
3-3 Management of material topic Security & privacy
418-1 Substantiated complaints concerning breaches of customer privacy and losses of customer data Zero substantiated complaints concerning breaches of customer privacy received in 2022.