We expect companies involved in animal research to take seriously their obligation to avoid and reduce animal suffering. We also believe that companies commissioning animal research can play an important role to help drive greater use of alternatives and better animal welfare practices by research institutions.
A genuine commitment to the 3Rs
In Australia, there is little regulatory oversight of animal research and limited coordinated effort to advance 3R principles in the private sector. We see it as our responsibility to explore opportunities to address these issues with healthcare companies we invest in.
in the number of animals
of conditions and methods
We have five indicators to assess whether companies involved in animal research can demonstrate genuine application of the 3Rs.
- Engagement of research institutions with adequate animal welfare standards.
- Use of research institutions which uphold the 3Rs principle.
- Consultation with individuals or organisations with scientific expertise in alternatives to animal research at the design stage of proposed animal studies.
- Engagement contracts with research institutions which include requirements that research institutions will:
- apply high animal welfare standards,
- apply the 3Rs at all stages, and
- report on their application of the 3Rs.
- Does at least one of the following:
- Puts funding towards developing alternatives to animal research models.
- Supports regulatory changes and public funding of research to improve application of the 3Rs and the use of alternatives.
- Has a public statement on the company website that outlines the steps they are taking in relation to the 3Rs.
did you know?
190 million animals
were estimated to have been used for scientific purposes in 2015 worldwide (not including animals used in observational research).1
Action we’ve taken
We engaged with 14 companies and other stakeholders (including scientists on animal ethics committees and animal protection organisations) to help us better understand how companies approach the 3Rs, what best practice looks like, and where there are areas for improvement.
We developed five indicators of genuine application of the 3Rs for companies involved in animal research to demonstrate genuine application of the 3Rs.
We wrote to nine Australian & NZ companies to assess if they were meeting our expectations. At the end of FY22:
5 substantially meet our expectations;
2 provided inadequate responses;
1 is yet to respond;
1 we will not continue with engagement as there were no prospects of imminent investment.
What the companies have done
CSL and Immutep have introduced animal welfare policies.
Fisher & Paykel has committed to introducing an animal welfare policy.
Pharmaxis reassessed the external research organisations it worked with and stopped working with all that do not have AAALAC accreditation (an independent accreditation on animal welfare).
Antisense published a statement on its website that commits to meeting all five of our 3R indicators.
Where we draw the line
Where healthcare companies are involved in animal research, we require evidence of genuine commitment to the 3Rs.
Animal welfare policies only go so far, and replacing animals with alternatives must be the focus. We think there is opportunity to shift the dial on this issue through industry collaboration to fund, validate and commercialise alternatives to animal research. We are beginning to form a roadmap of work on this issue in consultation with companies and NGOs. This could include:
bringing this issue to the attention of other investors to increase pressure on companies (e.g. through the UNPRI collaboration platform);
speaking to international industry associations to understand whether they could facilitate an industry-wide 3R initiative;
exploring the possibility of benchmarking companies and other research institutions on their efforts as this works well in other contexts to nudge company action; and
pushing for regulatory and government change such as better funding and support for alternatives and better scrutiny of the 3Rs by government funding organisations like the NHMRC.
Proposed FY23 activities
Escalate engagements with companies that did not adequately respond to our minimum expectations in FY22.
Commence engagement program with select Australian universities.
Publish a statement on animal research on the UNPRI collaboration platform to encourage investor engagement on this issue.
Engage with industry associations to understand their perspectives on an industry-wide 3R initiative.