E3G letter to the UK Infrastructure Bank on Key Performance Indicators (KPIs) for Success 

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The Royal Exchange, London, United Kingdom. Photo by Klaudia Piaskowska on Unsplash.

E3G has written to the Chief Executive Officer of the UK Infrastructure Bank, on behalf of leaders from a group of UK organisations representing business, finance, trade unions, academia, and civil society – highlighting the importance of the Bank ‘baking in’ the right key performance indicators (KPIs) from the start to ensure it can invest for success.

The signatories welcome the progressive approach taken by the Bank to establishing KPIs across the three impact assessment categories set out in the discussion paper: Climate Change, regional and local economic growth (Levelling Up), and Financial Indicators. These categories provide a solid framework to support the Bank in investing in a wide range of projects which address market failures and create markets in crucial infrastructure sectors, many of which were suggested in the previous joint briefing.

The letter suggests the following five actions to help guide the next iteration of the Bank’s investment strategy: 

  1. Take a broad interpretation of return when evaluating portfolio-level investment performance i.e. not just financial, but also social, climatic, and environmental. 
  2. Define an ex-ante investment screening process that uses a broad range of KPIs. For example, we agree with the suggestion in the discussion paper that the Bank’s investments should eventually align with the UK green taxonomy and implement minimum Do No Significant Harm Standards, aligning these with the taxonomy as soon as possible. Projects should also be screened against measures of whether they will contribute to a nature positive economy.  
  3. Expand the impact assessment categories to include Resilience and Nature Positive assessment. This should come through as part of the plan to align with the UK green taxonomy, as the criteria for all six environmental objectives are developed but should also be explicitly acknowledged by the Bank. 
  4. Expand the impact assessment categories to include Just Transition. As stated in the framework document, an investment screening list and the Do No Significant Harm principle should be used to ensure that the pursuit of one objective does not create actively harmful outcomes to the other. 
  5. Over time, expand the list of potential KPIs to ensure a broad range of co-benefits is assessed. 

The signatories also encourage the Bank to maintain a high level of transparency when reporting against these impact KPIs and welcome the mention of the Bank providing expert advisory services for local authorities. This would ensure that the Bank can drive meaningful investment to deliver place-based transformation and scale up the sustainable markets of tomorrow.  

Read the letter in full here.


Shane Tomlinson, Acting CEO, E3G 

Nick Molho, Executive Director, Aldersgate Group 

Steve Waygood, Chief Responsible Investment Officer, Aviva Investors 

Dimitri Zenghelis, Special Advisor, Bennett Institute for Public Policy, University of Cambridge  

Alice Bordini Staden, Managing Director, GLC Advisors Ltd 

Nick Robins, Professor in Practice – Sustainable Finance, Grantham Research Institute, London School of Economics 

Brendan Curran, Policy Fellow, Just Transition and Place-Based Investment, Grantham Research Institute, London School of Economics 

Sarah Gordon, CEO, Impact Investing Institute 

James Cameron, Senior Advisor, Pollination Group 

Paul Nowak, Deputy General Secretary, Trades Union Congress 

Polly Billington, Chief Executive Officer, UK100 


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