An investor insists on excluding companies with low diversity and inclusion scores from their portfolio.

Diversity and inclusion criteria constitute a legitimate non-financial investment restriction and should form part of the client’s documented objectives, needs and preferences. The RR must therefore respect the restriction when developing the investment recommendation. Option B is correct, even though the resulting portfolio may have a narrower investment universe and reduced diversification within the client’s preferred sector.

The RR should clearly explain the consequences before implementing the strategy. These may include greater issuer or sector concentration, increased tracking error against conventional benchmarks, fewer suitable securities, different expected returns and potentially higher volatility. The client can then decide whether the values-based restriction remains a priority after understanding the financial trade-offs.

The RR cannot simply exclude or override the restriction, making options A and D incorrect. Doing so would produce a portfolio inconsistent with the client’s documented mandate. Option C is also inappropriate because the RR should not pressure the investor to abandon a personal preference merely to simplify portfolio construction. The RR may discuss whether the restriction should be refined, but the final recommendation must reflect the client’s informed instructions.

CIRO’s competency framework expressly includes equity, diversity and inclusion considerations, ESG criteria and other personal preferences within KYC constraints and investment recommendations.

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