Wisconsin Administrative Code Investment Board

The State of Wisconsin Investment Board (SWIB) is governed not only by Chapter 25 of the Wisconsin Statutes but also by two chapters in the Wisconsin Administrative Code—IB 1 and IB 2—which flesh out the Board’s internal ethics rules and its investment policies.

Chapter IB 1 – Restriction of Investment Board Employees

Promulgated under s. 25.156(4), Stats., to avoid conflicts of interest between employees and the funds they manage, IB 1 sets out:

IB 1.01 – Statutory authority and purpose

IB 1.02 – Definitions

IB 1.03 – Gifts or favors

IB 1.04 – Investments in firms providing services to the Board

IB 1.05 – Personal investments by employees of the Board

IB 1.07 – Other than state employment

IB 1.08 – Service on boards of directors

IB 1.09 – Confidential and privileged information

These sections ensure that SWIB staff—and their immediate activities outside of work—cannot compromise the Board’s fiduciary duties to the Wisconsin Retirement System, the State Investment Fund, or any other trust funds under SWIB’s control.

Chapter IB 2 – General Policies of the Investment Board

Promulgated under s. 25.156(1), Stats., IB 2 articulates the Board’s investment objectives and operating framework:

IB 2.01 – Statutory authority and purpose

Establishes the Board’s mission: “…to help achieve the purpose of each fund … by investing to achieve the best possible return with the least necessary risk subject to legislatively imposed restraints.”

IB 2.02 – General policies relating to all funds

Functions may be delegated to SWIB staff.

For each fund, SWIB must define the fund’s purpose, set management requirements, review plans, audit performance, and apply generally accepted risk–return standards.

Investments must be within authorized criteria, prudent under s. 25.15, Stats., and diversified.

SWIB “seeks investments in organizations which respect basic human rights” and “encourages proposals from Wisconsin‑based companies” with no special advantage for any beneficiary subgroup.

IB 2.03 – Equity ownership evaluation and voting of proxies

Lays out how SWIB evaluates corporate governance, votes proxies (e.g., generally supporting management where prudent), and handles conflicts when voting its equity positions.

IB 2.04 – Title holding companies

Authorizes SWIB to form or use limited‑liability entities to hold title to investments for administrative efficiency.

Key Statutory & Code References:

Statutes creating SWIB: Section 15.76, Stats.

Primary fiduciary mandate: Chapter 25, Stats., and Wis. Admin. Code IB 1 & IB 2

Additional authority: Section 620.22, Stats., and Wis. Admin. Code INS 6.20

 

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