How to Avoid the Greenwashing Trap: Recommendations on transparency and minimum requirements for sustainable investments approaches and products

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Abstract
Regulatory Extracts from this
The recommendations set out in this paper are directed at the asset management industry with the intention to build a bridge between asset managers, other financial service providers and endinvestors. It focuses on the products designed by the fund and asset management industry and sold by financial service providers to investors. and has three main goals: • Define the various sustainable investment approaches and instruments in more detail and set minimum criteria for the implementation of each of them. • Specify minimum requirements for investor information on the different investment approaches and instruments. • Identify which of these sustainable investment approaches satisfy the three main sustainable investor goals most effectively.
Extracts
To allow investors to assess the quality and format of exclusion criteria, asset managers should publish the following information: 1. Name of the sustainable investment approach. 2. List of all business areas/products/incidents leading to exclusion. 3. The revenue threshold at which a specific business activity can trigger exclusion. 4. Criteria dictating when negative business practices lead to exclusion. 5. Description of the benchmark used: how is exclusion reflected in the index. 6. Percentage of a benchmark not considered investible from the outset based on the defined screening criteria.
For investors to be able to assess the quality and configuration of a ratings-based approach, asset managers should also publish the following information: 1. Name of the sustainable investment approach 2. Rating, metric or index the approach is based upon, as well as a description in the case of a proprietary rating. 3. Dimensions (i.e. ESG criteria) that the applied rating or alignment method takes into consideration. 4. Essential minimum threshold , i.e. the percentage of the portfolio that is still investable (for best-in-class). 5. Average sustainability rating or degree of alignment of the portfolio relative to the benchmark (for positive screening/positive tilt/alignment). 6. Exclusive use of external research or are internal resources available as well? For best-in-class or positive screening, the ratings/metrics used must consider all three ESG dimensions of sustainability and may not limit itself to just one or two dimensions.
For investors to be able to assess the quality and configuration of an ESG integration approach, asset managers should publish the following information: 1. Name of the sustainable investment approach. 2. Elements in the financial analysis influenced by the inclusion of sustainability factors (such as the assessment of the company’s competitive position, estimate of future cash flows, discount factor, etc.). 3. The extent to which the inclusion of ESG factors is binding for analysts (e.g. fixed element of each factsheet, part of the discussion when making any purchase decision). 4. Type of information available to the analysts (external ratings, databases, etc.).
For the description “ESG integration” to be justified, it must be mandatory for analysts to actually consider ESG information in their analysis. If suitable information is available but is only used on a voluntary basis, claiming the use of an ESG integration approach is unwarranted. ESG factors can be made binding by integrating them into a shared factsheet or including them on the agenda of investment meetings.
For investors to be able to assess the quality and configuration of sustainable thematic investments, asset managers should publish the following information: 1. Name of the sustainable investment approach. 2. Naming the sustainability theme(s) addressed by the fund. Helpful reference points here include the UN Sustainable Development Goals, or a taxonomy of sustainable economic activities. 3. Information on criteria defined as a condition for an investment and details on how such a theme is actually operationalised. 4. Information on the minimum revenue threshold for a company to become eligible for the theme. 5. Percentage of the portfolio that can be allocated to the themes identified.
For investors to be able to assess the quality and configuration of impact investments, asset managers should publish the following information: 1. Name of the sustainable investment approach. 2. Description of the intended impacts (via a “Theory of Change”). 3. Key performance indicators (KPIs) that illustrate the actual impact achieved. 4. Applied standards underlying the operational management and measurement of impacts (e.g. the IFC’s “Operating Principles for Impact Management”).
For investors to be able to assess the quality and configuration of active ownership, asset managers should publish the following information: 1. Name of the sustainable investment approach. 2. Publication of the voting rights policy. 3. Proportion of the share portfolio for which voting rights were actively exercised. 4. Percentage of votes that did not support the board‘s recommendation. 5. Breakdown of negative votes by topic.
For an investor to aspire to active ownership, an ESG policy should be in place for the exercising of voting rights and be published on the website. This should not concern itself exclusively with matters of good governance, but also include statements about priorities relating to environmental or social themes. In addition, the votes – at least for a specific, defined market segment – should be exercised for a significant proportion of the portfolio and voting details reported on an annual basis.
For investors to be able to assess the quality and configuration of an active engagement process, asset managers should publish the following information: 1. Name of the sustainable investment approach 2. Engagement policy (incl. goals and most important engagement themes) 3. Percentage of the portfolio for which engagement applies 4. Number of interactions with companies 5. Proportion of demands where progress has been made
For an investor to aspire to active engagement, a suitable engagement policy should be in place and be published on the website. This could also be the policy of a relevant service provider. In addition, annual information should be published on the website on the engagement priorities, how many dialogues were held and what progress was made.
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