
Many newspapers now talk of the declining demand for ESG funds (defined as funds with ESG or sustainability-related terms in their name).
So is investment into ESG funds really falling? Yes - but not for the reasons you may think.
A key reason behind this is that the actual number of 'ESG funds' on the market has decreased, due to the regulatory clampdown on greenwashing.
The bar on greenwashing is rising
In most jurisdictions, financial regulators are increasingly determined that the sustainability characteristics of any fund marketed under an ESG banner are robust, transparent and quantifiable. Unsurprisingly, this has made the marketing teams and legal compliance units of most asset managers very nervous.
As an example, Blackrock has just dropped sustainability-related terms from 56 funds, representing ~£40bn of managed assets. Blackrock has admitted there will be no change to the actual investment strategies of these funds - but these 56 funds do not meet the new EU criteria for sustainability-related fund names.
So are investors leaving the funds that retain ESG nomenclature?
Even with this name-change trend, inflows into ESG-named funds are still rising. Global inflows in Q4 2024, using Morningstar data, were $16.0bn. This was up on the Q3 2024 inflow of $9.4bn.
The US however, is seeing ESG fund outflows. This is all because of the socio-political backlash against ESG, right?
Wrong. The US has seen ESG fund outflows for every quarter since Q2 2022. The Biden administration was still driving a sustainability agenda then, but then 2 very important things happened around Q2 2022:
🇷🇺 Russia invaded Ukraine in February, causing a surge in oil & gas prices
📈 US interest rates started rising in April
A majority of US ESG funds share 2 characteristics: they have no oil & gas exposure, and they are long renewable energy generation.
Renewable energy generators are what investors call a ‘long duration asset’; meaning the bulk of the net cash flow comes far out in time, and therefore the asset’s present value will be particularly hurt by rising interest rates.
So, both the macroeconomic events of Q2 2022 badly impacted ESG funds, and the ongoing impacts led to a widespread loss of confidence in 'ESG as an investment'.
Will this continue to be the case?
At this point, there are too many unknown variables to make a definitive judgment.
For example, if oil prices started a reversion to where they started this decade ($20 per barrel), the landscape for investment in ESG funds might improve sharply once again.
Global demand for sustainable funds is not going away. And once we see a period of stronger investment performance, convincing wary investors that sustainability does not reduce returns, we will see a boost to demand.
An activist investor group is urging Woodside Energy shareholders to vote against the re-election of all three directors.
This was shared in our sentiment round up last week, with the investors concerned citing poor returns and failures in managing climate risks.
Are these investors right?
The data speaks for itself - Woodside’s absolute emissions increased by 8% year-over-year from 2023 to 2024.
Their Global Scope 1 and Scope 2 greenhouse gas emissions, scaled by revenue, place them in the bottom quartile - not just compared to the entire Integrum ESG universe, but also among their global sector peers.
It is Woodside’s poor performance relative to other Oil and Gas E&P companies which underscores why investors are losing confidence.
Why is this important?
Boards that fail to align with the energy transition will face increasing scrutiny from investors who expect more than empty promises.
With regards to Woodside, the key question remains: will they change course, or will shareholders force their hand?
Are the Net Zero Alliances falling apart?
Sadly yes.
But the reason why is not what many observers believe.
Most of the large banking and investment management groups who have withdrawn from the Net Zero Banking Alliance or Asset Managers Alliance have publicly reiterated their commitment to net zero targets, and continue to invest in their sustainability advisory teams.
𝗧𝗵𝗲 𝗿𝗲𝗮𝘀𝗼𝗻 𝘄𝗵𝘆 𝘁𝗵𝗲𝘆 𝗵𝗮𝘃𝗲 𝗽𝘂𝗹𝗹𝗲𝗱 𝗼𝘂𝘁 𝗼𝗳 𝘁𝗵𝗲𝘀𝗲 𝗮𝗹𝗹𝗶𝗮𝗻𝗰𝗲𝘀 𝗶𝘀 𝗳𝗲𝗮𝗿 𝗼𝗳 𝗹𝗶𝘁𝗶𝗴𝗮𝘁𝗶𝗼𝗻.
The House of Representatives Committee on the Judiciary has written to most members of these alliances and, essentially, accused them of having joined a cartel, which is colluding to defund the American oil and gas industry.
The recipients of these accusatory letters, after extended deliberations with their lawyers, have concluded (or likely will do soon) that the probability of successful legal action against them is too great.
𝗪𝗶𝗹𝗹 𝘁𝗵𝗲𝗿𝗲 𝗯𝗲 𝗮 𝗳𝗶𝗴𝗵𝘁𝗯𝗮𝗰𝗸? 𝗜𝘁 𝗱𝗼𝗲𝘀𝗻'𝘁 𝗹𝗼𝗼𝗸 𝗹𝗶𝗸𝗲 𝗶𝘁.
NZAM (The Net Zero Asset Managers alliance) has even suspended its activities, after Blackrock, the world's largest asset manager pulled out recently. The only news we now see is incremental departures.
Looking at the pullback on DEI we are seeing from many of the US' largest companies, it seems no one wants to pick a fight with the new Republican-led US legislature.
And Mark Carney, the principal architect of these alliances (which sit under the umbrella known as GFANZ), has remained quiet.
As of this week, he arguably has bigger battles to fight. 🇨🇦
DEI (standing for Diversity, Equity and Inclusion) has become a popular buzzword in recent years, linked with targets and priorities for many businesses.
However, the re-appointment of President Trump has caused many of the largest US companies to scale back or entirely drop their DEI targets.
How have companies reacted?
Accenture, the global consulting firm is one example, sharing an internal memo to their 700,000 employees saying, “the company will start “sunsetting” the diversity goals it set in 2017, along with career development programmes for “people of specific demographic groups”.
Other corporates who have either axed or rolled back their DEI commitments since Trump’s inauguration include Target, Google and Amazon.
This roll back has also extended to financial institutions including Deloitte, Goldman Sachs and Blackrock amongst others.
What reason have corporates given for moving away from DEI?
One of the arguments anti-DEI advocates have made is that it may negatively impact performance and returns.
This argument has been best illustrated by the Florida State Board of Administration, who oversee public employee retirement funds, bringing a class action lawsuit against American retailer Target.
They allege that the company’s board of directors deceived shareholders about the true risk of its 2023 Pride Month campaign, a campaign which provoked consumer backlash and “wiped out over $25 billion in Target’s market capitalization”.
This lawsuit of course does not mention the number of other issues that Target have faced in the past few years that has led to their declining performance.
How are consumers and shareholders reacting?
Amidst the roll back, companies John Deere and Apple are proving that shareholder appetite for DEI is still prevalent.
Both companies recently held votes on their respective DEI plans, with both sets of shareholders recording a rejection rate greater than 95%.
The Securities and Exchange Commission (SEC) also looks to be taking a firm stance on this, having recently blocked an attempt from Boeing to “no action” a civil rights audit proposal, filed in response to their alleged DEI roll back.
Companies who have already decided to scale back their programs are also facing the risk of consumer backlash.
This has been demonstrated by the “Target-Fast” boycott that started on Wednesday, a 40-day consumer boycott driven by the BAME community.
The boycott stems from disappointment that Target, who pledged to add products from more than 500 Black-owned businesses by 2025, have scaled back their DEI efforts with minimal resistance. Upwards of 100,000 people have already signed up.
What next?
The retreat from DEI targets by major US companies shows how vulnerable corporate commitments can be to political trends and is symbolic of how politicised ESG continues to be.
Genuine DEI progress requires long-term commitment, regardless of political pressure, and the recent response by shareholders and consumers alike proves that we will not see a complete erasure of these standards anytime soon.
The People’s Pension (TPP), managed by one of the U.K.’s largest independent trusts, has reallocated £28 billion away from their previous manager State Street.
Amundi and Invesco have instead been chosen to oversee this mandate, with a TPP Chairperson Mark Condron stating the pension fund chose “to prioritize sustainability, active stewardship, and long-term value creation for our nearly seven million members”.
This follows shortly after a group of financial institutions and pension funds, including TPP, publicly asked their asset managers to engage more actively with investee companies regarding climate risk.
Why does this matter?
Following Donald Trump’s inauguration, the common rhetoric has been that most corporates and investors will need to wheel back their sustainability commitments to avoid negative scrutiny.
Even in recent conversations with some emerging asset managers, they have expressed some reluctance to actively incorporate ESG into their processes, due to the fear of it harming their capital raising efforts.
This is the clearest example that that there is still significant appetite from the largest and most influential European investors for ESG integration into fund management, which they regard (to quote TPP) as creating long-term value.
TPP identified two asset managers who actively market their responsible investing efforts as clearly differentiating them from their peers.
Amundi integrates ESG considerations across all of its funds and has credited responsible investing for being one of the key cornerstones of their process.
Likewise, Invesco carries out over 2,200 engagements with portfolio companies annually on ESG topics - and TPP referred to this active engagement as being key to the manager's selection.
Integrum ESG is constantly in discussions with new and emerging fund managers who - despite making it clear they are not running sustainable/responsible/environmental funds - have been asked by would-be investors to demonstrate how they are managing ESG risks in the portfolio.
Rather than being pressured to de-prioritise ESG, unless their client is a US governmental organisation, most fund managers are being asked to produce more ESG data - in order to back up their claims of integrating sustainability with ever more granularity.
Savvy emerging managers should see this for the opportunity it is - a chance to truly differentiate themselves from their peers, and reassure potential investors that they understand ESG as a set of non-traditional risks that need to be managed.
On Wednesday, the 26th February, the Climate Change Committee (CCC) published the UK’s Seventh Carbon Budget (CB7), outlining the nation's roadmap towards achieving its Net Zero target by 2050.
The CCC has recommended setting an ambitious (but achievable) emissions limit of 535 million tonnes of CO2e for the 2038-2042 period, which also includes “international aviation and shipping”.
Achieving the above target marks a crucial step in the UK’s transition to a low-carbon economy and to be achieved the UK will require emissions to decrease “to 87% below their 1990 levels”.
See the table below showing a sector breakdown of emissions reductions by 2040:
WiseTech Global Ltd's [WTC:ASX] share price has tanked, caused mainly by a boardroom fallout in response to the ongoing role of highly controversial founder Richard White.
We reviewed the company's ESG profile to breakdown what investors should know, and should have known, about this ongoing controversy:
What actually happened?
Last Monday, four out of six board members resigned from their roles at WiseTech. This included the chair Richard Dammery, standing down due to “differing views around the ongoing role of the founder”.
Founder Richard White has been involved in a number of different scandals in the past few months regarding allegations of inappropriate relationships and behaviour towards women.
In October 2024 when allegations initially broke, White stepped down as CEO and agreed to a role as an external consultant.
However new allegations came out this month which led to the exodus from the board, and has also led to White controversially returning as Executive Chairman.
How did investors react?
WiseTech's share price has been volatile since these stories broke out.
Looking back to when these allegations first emerged, share price fell 31.62% (137.46 AUD on Oct 1 2024 to a low of 99.37 AUD on Oct 24 2024).
With the new allegations coming out against the founder and the subsequent board exodus, a trading halt on WiseTech Global shares was put in was put in place from Thursday 20 October to Monday 24 October.
As the halt was lifted, share price immediately fell 20.1% to 97.25 AUD, and as of the time of writing is currently sitting at a low of 89.50 AUD.
Could ESG data have helped investors mitigate this loss?
It depends on what ESG data solution you have access to.
Looking at MSCI and Sustainalytics' ratings on this company, for example, one might think there was little to be concerned about.
MSCI give WiseTech the highest possible overall ESG rating of an 'AAA', stating they are a leader among 451 companies in their industry. This data was unhelpfully only updated in June 2024, prior to the emergence of these scandals.
Sustainalytics' ESG rating similarly raises no immediate red flags - WiseTech is a 'low risk' company, which is concerning given the last update is listed as having been done on 27 February 2025.
Both solutions provide 'controversies' offerings which would have flagged these scandals, but only after the damage was done - giving conviction to the argument that ESG data and analysis is 'backwards looking'.
What did Integrum pick up on WiseTech?
Integrum ESG provides transparent actionable data on companies, including WiseTech.
Not only does the Platform score the company a middling 'C' grade, but has a 'Live ESG Sentiment Score' of negative 100%.
In both October 2024 and this month, when the controversies surrounding WiseTech's founder and governance broke, the real-time sentiment tracker picked up these stories early.
This real-time sentiment tracker is updated every 15 minutes and looks over 47,000 data sources to alert users to emerging stories before they become a full blown controversy.
Taking advantage of this combination of timely data, any investor would have the ammunition they needed to mitigate the losses they were due to make from WiseTech's share price falling.
Late last year, the European Commission published the final rules for regulating ESG ratings providers in the EU.
These rules have now ‘entered into force’, although this is a rather misleading legal term - ratings firms like us will only have to comply from the ‘application date’, which is in July 2026.
So, we should have another 18 months of opaqueness, at least. 👎
The EU rules will share the same principles as the proposed UK ESG ratings regulation, aiming to:
🚫 Prohibit conflicts of interest
🔎 Enforce greater transparency of both ratings methodology and supporting information
📖 Open the process by which ESG ratings are set and reviewed to regulatory scrutiny
We at Integrum ESG will be in scope of this new regulation, and we are quite looking forward to seeing the light it will shine on our industry.
For example, if you scroll to Annex III on page 45, you will see that the regulation demands a set of “minimum disclosures to the public”.
The 8th disclosure required of “an aggregated ESG rating”, is “the weighting of the three overarching E, S and G categories of factors, and the explanation of the weighting method, including weight per individual E, S and G category.”
This new disclosure requirement shouldn’t be demanding right?
We for example, use the SASB/IFRS framework to determine which individual categories are material, and we weight each of them equally. If a client wants to override this, then can click on ‘customisation’ and do so. Simple.
But I have not yet met anyone who can tell me exactly how the largest legacy ESG ratings firms set their weightings.
When I say “exactly”, I mean explain how a precise % weighting is calculated, not offer a general approach statement like :
“The selection of Key Issues and their respective weights are readjusted on an annual basis, through a process that combines quantitative assessment of industry exposures to emerging issues and wide consultation with investment practitioners” (MSCI Ratings Methodology, November 2022) ❓
The importance of how one weights different categories (sustainability issues) is that it can influence the overall rating as much as how one scores each category.
Indeed, analyses of the disparity between the ESG ratings for the same company, from different ratings providers, suggest that very different category weights are a key reason.
Consider the table below, which snapshots how MSCI weights the same “individual category” (in this case, employee health and safety) for three beverage sectors:
We asked ChatGPT what Impact Investing is, and this is what it said:
𝘐𝘮𝘱𝘢𝘤𝘵 𝘪𝘯𝘷𝘦𝘴𝘵𝘪𝘯𝘨 𝘪𝘴 𝘰𝘧𝘵𝘦𝘯 𝘢𝘭𝘪𝘨𝘯𝘦𝘥 𝘸𝘪𝘵𝘩 𝘧𝘳𝘢𝘮𝘦𝘸𝘰𝘳𝘬𝘴 𝘭𝘪𝘬𝘦 𝘵𝘩𝘦 𝘜𝘯𝘪𝘵𝘦𝘥 𝘕𝘢𝘵𝘪𝘰𝘯𝘴 𝘚𝘶𝘴𝘵𝘢𝘪𝘯𝘢𝘣𝘭𝘦 𝘋𝘦𝘷𝘦𝘭𝘰𝘱𝘮𝘦𝘯𝘵 𝘎𝘰𝘢𝘭𝘴 (𝘚𝘋𝘎𝘴) 𝘢𝘯𝘥 𝘪𝘴 𝘨𝘢𝘪𝘯𝘪𝘯𝘨 𝘵𝘳𝘢𝘤𝘵𝘪𝘰𝘯 𝘢𝘮𝘰𝘯𝘨 𝘪𝘯𝘥𝘪𝘷𝘪𝘥𝘶𝘢𝘭𝘴, 𝘪𝘯𝘴𝘵𝘪𝘵𝘶𝘵𝘪𝘰𝘯𝘴, 𝘢𝘯𝘥 𝘧𝘶𝘯𝘥𝘴 𝘴𝘦𝘦𝘬𝘪𝘯𝘨 𝘵𝘰 𝘢𝘭𝘪𝘨𝘯 𝘵𝘩𝘦𝘪𝘳 𝘪𝘯𝘷𝘦𝘴𝘵𝘮𝘦𝘯𝘵𝘴 𝘸𝘪𝘵𝘩 𝘵𝘩𝘦𝘪𝘳 𝘷𝘢𝘭𝘶𝘦𝘴.
Large Impact funds generally have their own bespoke, highly sophisticated frameworks.
But when other funds are asked to report on their impact, they typically consider the extent to which the issuers of the fund's investments support the UN SDGs.
So how hard is that to do? 🧮
It depends on the degree of granularity.
We have seen asset managers breaking down an investee company's revenues into highly-specific activities, and map these not only to the 17 UN SD Goals, but also the 169 SD Targets that sit beneath the overall goals.
We however favour the Cambridge Impact Framework. We adopted it as our Impact framework because it is simple, sensible and comparable.
Moreover, the CISL is gaining ever more respect as an academic centre for sustainability analysis, which gives the Framework credibility with asset owners.
We are sometimes challenged on why we deploy a framework where the overall assessment is not intensely focused on the investee companies' products and services.
The answer is that a company's products can have a considerable positive impact on the world, but its activities also have considerable 'operational impact' that should be assessed.
Consider this hypothetical example 💭
An Asian company produces a branded pharmaceutical that reliably treats childhood cancers.
This company may appear in many impact funds, due to its life-saving product – highlighting its role in supporting SDG 3 (Good Health and Well-Being).
However, the price point of the product is unaffordable outside of Western markets, the product is packaged by child workers paid $2 per day, and the net waste and emissions generated by the manufacturing process are vast.
Thus by using the Cambridge Impact Framework, we can see how these activities are actually detrimental to SGDs 1, 8,10, 13 & 15.
So should we look at sustainability or impact? 🤔
Since inception, we have always believed that a true sustainability assessment must involve what is now called 'double materiality'; how sustainability issues affect the company, and how the company impacts the world.
So we apply a SASB/IFRS ESG Risk framework to every company, and also apply the Cambridge Impact Framework alongside it.
And when one considers recent EC proposals and the enquiries we are receiving, it is clear this will be the expectation from fund managers moving forward.
The President of the European Commission Ursula von der Leyen has said that the commission would launch a "far-reaching simplification of our sustainable finance and due diligence rules".
She was doubtless referring to the 'Omnibus Simplification Package', the first draft of which is due to be published on 26th February – and her comment echoes that of the Commission's EVP Stéphane Séjourné, who has warned corporates to expect a "massive simplification".
This was perhaps to be expected given that the governments of the two largest economies in Europe, Germany and France, have both recently called for 2-year postponements to CSRD and CSSSD.
The regulation being targeted for simplification would surely include these two disclosure requirements, and most likely the EU Taxonomy, given that the 'omnibus' seems focused on the reporting burden on corporates.
Proposals to streamline sustainability disclosure requirements for asset managers, such as SFDR, are likely to remain separate to the omnibus.
The CSRD's data collection requirements for large companies came into effect at the start of this month, albeit most companies are still figuring out what sort of sustainability data they should be collecting, given their first CSRD reports are not due until 2026.
Daniella Woolf, founder of the sustainability advisory firm Danesmead, said that it was "welcome for certain European corporates to hear that there may be some kind of simplification or delay of CSRD, especially those who have not yet made a start...'', but that "most organisations we are working with on CSRD are continuing as though reporting timelines will remain intact.''
CSRD is unlikely to disappear; a draft EC document outlining plans to improve EU competitiveness said the EC will cut 25% of reporting requirements for larger companies and 35% for small businesses.
That is still onerous, and most companies will require help from a specialist consultancy - but there is a growing probability that the reporting date of '2026' will become '2028'.
𝗧𝗵𝗶𝘀 𝗮𝗿𝘁𝗶𝗰𝗹𝗲 𝘄𝗮𝘀 𝘄𝗿𝗶𝘁𝘁𝗲𝗻 𝗯𝘆 𝗜𝗻𝘁𝗲𝗴𝗿𝘂𝗺 𝗘𝗦𝗚 𝗙𝗼𝘂𝗻𝗱𝗲𝗿 𝗮𝗻𝗱 𝗖𝗘𝗢 𝗦𝗵𝗮𝗶 𝗛𝗶𝗹𝗹.
Another legislative proposal, missed over the festive period, was the publication of a PSF report on categorising sustainable funds (click here to read the full report).
The PSF (Platform of Sustainable Finance) was mandated by the European Commission to advise it on making the SFDR (Sustainable Finance Disclosure Requirement) more effective.
Asset Managers are using terms like ‘Article 8’ as a product label, and the EC doesn’t like that - it argues Article 8 is a set of disclosure requirements, not a fund categorisation.
So the PSF has recommended that ‘SFDR 2.0’, as many now call it, creates 4 new fund categories:
1. Sustainable 💚
These funds make taxonomy-aligned investments, or sustainable investments with no significant harmful activities, and also apply the Paris-Aligned Benchmark exclusions.
2. Transition 🌱
These funds make investments which support the transition to net zero and a sustainable economy, in accordance with the EC’s June 2023 recommendations on ‘financing the transition to a sustainable economy’.
3. ESG collection 📊
These funds would exclude investments in significantly harmful activities, and invest in assets with higher-scoring environmental and/or social characteristics.
Funds in categories 1, 2 and 3 would be subject to minimum criteria, meaning at least x% of the fund’s investments must demonstrably meet this or that requirement. These % values are yet to be proposed and they are also subject to minimum disclosure requirements.
4. Unclassified ❓
A fund that does not fall within one of the 3 categories above would be labelled as ‘unclassified’.
Category 4 funds are not subject to minimum criteria, and may not use ESG/sustainability terms in their marketing material within the EU.
But unclassified funds are subject to minimum disclosures.
Minimum disclosures for an unclassified fund include:
📝 % of the investments’ revenues and capex aligned to the EU Taxonomy
📝 PAIs (Principle Adverse Indicators) 1, 2 and 3 (Greenhouse Gas emissions, footprint and intensity)
📝 PAI 10 (violations of the UNGC and OECD guidelines, although PSF recommends amending this to violations of the UN Guiding Principles, to focus on human rights)
What does this really mean for fund managers moving forward?
Daniella Woolf, founder of the sustainability advisory firm Danesmead ESG, predicted that there would be some ''bumps in the road'' for fund managers in adapting to these regulatory changes.
The two most notable hurdles she highlighted were:
-
Mapping existing article 6, 8 or 9 funds to the four new categories will need clear guidance to avoid mass confusion
-
Many funds not currently engaged in SFDR may well need to start collecting and reporting on key PAI data points to make sustainability disclosures
We agree - we predict that changes will create a significant headache for most managers of ‘Article 6’ funds in particular, and other funds that do claim not to incorporate ESG characteristics.
What is the timeline here?
There is in our view no chance that these changes will come into force in 2025.
But given the PSF’s track record in influencing EC legislation, and the general market confusion over SFDR, we do think it very likely that these recommendations will be legislated in 2026, and perhaps brought into legal force in 2027.
So asset managers who distribute their funds in the EU, but do not map their funds to any of the PAIs, do not need to panic. But they should start planning for how they will meet these minimum disclosures.
The Carbon Transitional Benchmark (CTB) and Paris Aligned Benchmark (PAB) exclusions are lists of excluded corporate activities.
The CTB exclusions can be summarised as controversial weapons, tobacco, and violations of UNGC and OECD principles.
The PAB exclusions are more extensive.
Managers are also expected to disclose in their benchmark methodology any additional exclusion criteria they use which are based on climate-related or other environmental, social and governance (ESG) factors.
See the full breakdown below:
𝗧𝗵𝗶𝘀 𝗮𝗿𝘁𝗶𝗰𝗹𝗲 𝘄𝗮𝘀 𝘄𝗿𝗶𝘁𝘁𝗲𝗻 𝗯𝘆 𝗜𝗻𝘁𝗲𝗴𝗿𝘂𝗺 𝗘𝗦𝗚 𝗙𝗼𝘂𝗻𝗱𝗲𝗿 𝗮𝗻𝗱 𝗖𝗘𝗢 𝗦𝗵𝗮𝗶 𝗛𝗶𝗹𝗹.
Any fund marketed in the EU will have to comply with a new set of rules from 21 May this year.
The ESMA guidelines on funds’ names using ESG or sustainability-related terms even includes funds which are closed to new investors.
The new rules vary, depending on which of these 3 categories your fund is in:
1️⃣ Funds with these words or synonyms in the name: transition, net-zero, social, governance
2️⃣ Funds with these words or synonyms in the name: environmental, green, climate, impact, ESG
3️⃣ Funds with this word or synonyms in the name: sustainable
Funds in all categories must reach an 80% threshold; where 80% of the fund holdings must be made to meet the fund's E, S or G objectives.
Funds in category 1 must apply the CTB exclusions, whereas funds in categories 2 or 3 must apply the PAB exclusions.
What are the CTB and PAB exclusions?
The Carbon Transitional Benchmark (CTB) and Paris Aligned Benchmark (PAB) exclusions are lists of excluded corporate activities.
The CTB exclusions can be summarised as controversial weapons, tobacco, and violations of UNGC and OECD principles.
The PAB exclusions are more extensive.
Managers are also expected to disclose in their benchmark methodology any additional exclusion criteria they use which are based on climate-related or other environmental, social and governance (ESG) factors.
See the full breakdown below:
Many asset managers proudly advertise their status as a UN PRI Signatory 🇺🇳.
We have often questioned this, given the 'minimum requirements' for this status are risible. Nonetheless, several thousand signatories go far beyond the minimum requirements and submit detailed annual reports, for grading by the PRI - and many investors value this highly.
But UN Principles for Responsible Investment reporting is about to change very significantly.
🗓️ 𝟮𝟬𝟮𝟱 𝗥𝗲𝗽𝗼𝗿𝘁𝗶𝗻𝗴, 𝘄𝗵𝗶𝗰𝗵 𝗼𝗽𝗲𝗻𝘀 𝗶𝗻 𝗠𝗮𝘆 𝘁𝗵𝗶𝘀 𝘆𝗲𝗮𝗿, 𝘄𝗶𝗹𝗹 𝗯𝗲 '𝗰𝗹𝗼𝘀𝗲𝗹𝘆 𝗮𝗹𝗶𝗴𝗻𝗲𝗱' 𝘁𝗼 𝗿𝗲𝗰𝗲𝗻𝘁 𝘆𝗲𝗮𝗿𝘀.
Yet the PRI also states that there will be some meaningful changes, to provide 'a bridge towards the introduction of Progression Pathways'.
🗓️ 𝗜𝗻 𝟮𝟬𝟮𝟲 𝘁𝗵𝗲 𝗰𝘂𝗿𝗿𝗲𝗻𝘁 𝗥𝗲𝗽𝗼𝗿𝘁𝗶𝗻𝗴 𝗙𝗿𝗮𝗺𝗲𝘄𝗼𝗿𝗸 𝘄𝗶𝗹𝗹 𝗯𝗲 𝗿𝗲𝗽𝗹𝗮𝗰𝗲𝗱 𝗯𝘆 '𝗙𝗼𝘂𝗻𝗱𝗮𝘁𝗶𝗼𝗻𝗮𝗹 𝗥𝗲𝗽𝗼𝗿𝘁𝗶𝗻𝗴'.
This is a 'significantly streamlined' report that demonstrates one's commitment to the 6 Principles.
This will become the only mandatory report for signatories. Its precise format is a work-in-progress, as is 'Progressional Reporting', but all the language suggests it will be basic rather than detailed.
🗓️ 𝗙𝗿𝗼𝗺 𝟮𝟬𝟮𝟳 𝘁𝗵𝗲 𝗳𝗼𝗰𝘂𝘀 𝘄𝗶𝗹𝗹 𝗯𝗲 𝗼𝗻 𝘃𝗼𝗹𝘂𝗻𝘁𝗮𝗿𝘆 𝗿𝗲𝗽𝗼𝗿𝘁𝗶𝗻𝗴 𝘁𝗼 '𝗣𝗿𝗼𝗴𝗿𝗲𝘀𝘀𝗶𝗼𝗻 𝗣𝗮𝘁𝗵𝘄𝗮𝘆𝘀'.
These are pathways created by the PRI to help asset managers 'maximise returns by incorporating ESG factors'.
They choose their topics (e.g. 'setting sustainability targets' or 'engaging with investee companies'), and then choose whether to pursue Level 1, 2 or 3 ('introductory' to 'advanced') practices.
Signatories will be provided with materials and support to help instil those practices.
The PRI praises its move away from 'one size fits all' reporting, but the pick-and-choose nature of Progressional Reporting will significantly reduce investors' ability to compare the pathways of different asset managers.
𝗪𝗵𝘆 𝗵𝗮𝘀 𝘁𝗵𝗲 𝗣𝗥𝗜 𝗱𝗼𝗻𝗲 𝘁𝗵𝗶𝘀?
Whilst not entirely clear, it seems the PRI has no appetite to compete against the rise in other ESG reporting frameworks (ISSB, SFDR, TCFD etc). Its reporting framework has been beset by technical problems in recent years, and they now want to guide rather than police.
The risk to the UN PRI is that the value which asset allocators and asset owners place on being a Signatory, declines steeply next year.
𝗧𝗵𝗶𝘀 𝗮𝗿𝘁𝗶𝗰𝗹𝗲 𝘄𝗮𝘀 𝘄𝗿𝗶𝘁𝘁𝗲𝗻 𝗯𝘆 𝗜𝗻𝘁𝗲𝗴𝗿𝘂𝗺 𝗘𝗦𝗚 𝗙𝗼𝘂𝗻𝗱𝗲𝗿 𝗮𝗻𝗱 𝗖𝗘𝗢 𝗦𝗵𝗮𝗶 𝗛𝗶𝗹𝗹.
𝗧𝗵𝗶𝘀 𝗮𝗿𝘁𝗶𝗰𝗹𝗲 𝘄𝗮𝘀 𝘄𝗿𝗶𝘁𝘁𝗲𝗻 𝗯𝘆 𝗜𝗻𝘁𝗲𝗴𝗿𝘂𝗺 𝗘𝗦𝗚 𝗥𝗲𝘀𝗲𝗮𝗿𝗰𝗵 𝗔𝗻𝗮𝗹𝘆𝘀𝘁 𝗜𝗷𝗮𝗵 𝗢𝗳𝗼𝗻.
Microsoft may be forced to pay £1bn in legal fees after seemingly overcharging for their software, forcing UK businesses to use Microsoft Azure, its cloud computing service, and restrict competition in the sector.
𝗪𝗵𝗮𝘁 𝘄𝗮𝘀 𝗽𝗶𝗰𝗸𝗲𝗱 𝘂𝗽 𝗼𝗻 𝘁𝗵𝗲 𝗜𝗻𝘁𝗲𝗴𝗿𝘂𝗺 𝗘𝗦𝗚 𝗣𝗹𝗮𝘁𝗳𝗼𝗿𝗺? 💻
On Tuesday the 3rd of December, the real-time sentiment tracker picked up multiple accounts of this story, flagging it as a rising concern.
𝗪𝗵𝗮𝘁 𝗮𝗰𝘁𝘂𝗮𝗹𝗹𝘆 𝗵𝗮𝗽𝗽𝗲𝗻𝗲𝗱? 📰
A £1bn class action lawsuit has been brought forward in the UK by regulation expert, Dr Maria Luisa Stasi and has been filed with the UK’s Competition Appeal Tribunal.
The suit alleges that customers using competitors such as Google Cloud or Amazon AWS are being forced to pay higher fees for Windows Server licenses on these platforms, rather than those using Microsoft's own Azure cloud platform.
The UK’s Competition and Markets Authority (CMA) has also been investigating and monitoring the cloud computing industry, as concerns continue to stack against tech giants like Microsoft for monopolising the market.
This has a significant impact on UK SME’s, many of whom are facing significant charges from Microsoft as the company continues to push prices up for their Windows Server.
𝗛𝗼𝘄 𝗱𝗶𝗱 𝗶𝗻𝘃𝗲𝘀𝘁𝗼𝗿𝘀 𝗿𝗲𝗮𝗰𝘁? 📉
This type of claim is still relatively new, having only been introduced in the UK in 2015; meaning investors will need to exercise patience before they are able to factor claims like this into their long-term decision making.
While we may not see the true implications of this immediately, it is something to monitor as regulatory standards continue to tighten.
A key aspect to note is that the CMA have demonstrated their willingness to go after a tech giant such as Microsoft, meaning there will be little wriggle room for smaller companies in the sector.
𝗖𝗮𝗻 𝗶𝗻𝘃𝗲𝘀𝘁𝗼𝗿𝘀 𝘂𝘀𝗲 𝗘𝗦𝗚 𝗱𝗮𝘁𝗮 𝘁𝗼 𝗮𝗻𝘁𝗶𝗰𝗶𝗽𝗮𝘁𝗲 𝘁𝗵𝗲𝘀𝗲 𝗲𝘃𝗲𝗻𝘁𝘀? 🗂️
The Integrum ESG Platform has given Microsoft an overall score of 1 out of 4 for the Competitive Behaviour metric.
Whilst we have captured that the company has a Fair Competition Policy in place, their recent actions show this is either not robust enough or they are blatantly contradicting it.
Their poor performance for this metric can be attributed to their opaqueness regarding their lack of disclosure of any legal fines on this issue in their most recent 10-K.
This is just one of many examples demonstrating how ESG data, both fundamental and real-time, can unravel stories and increase awareness on ESG risks.
𝗧𝗵𝗶𝘀 𝗮𝗿𝘁𝗶𝗰𝗹𝗲 𝘄𝗮𝘀 𝘄𝗿𝗶𝘁𝘁𝗲𝗻 𝗯𝘆 𝗜𝗻𝘁𝗲𝗴𝗿𝘂𝗺 𝗘𝗦𝗚 𝗥𝗲𝘀𝗲𝗮𝗿𝗰𝗵 𝗔𝗻𝗮𝗹𝘆𝘀𝘁 𝗔𝗹𝗶𝗰𝗶𝗮 𝗞𝗮𝗽𝗹𝗮𝗻.
Kraft Heinz recently released their 2024 ESG Report but despite their comprehensive set of sustainability targets, progress towards them has clearly faltered.
Up until last year, Kraft Heinz had reported promising progress towards their goal of achieving ‘100% recyclable, reusable or compostable packaging by 2025’, with a steady increase in their proportion of sustainable packaging from 70% in 2019 to 87% in 2022.
However, in their most recently reported year, this progress has stagnated with the proportion remaining at 87%.
This is below the 94% our analyst Molly Frazer had estimated when we ran a trend analysis on the company’s recycling goals last year – and speaks to the challenges we predicted companies like Kraft Heinz would face.
A statement in the company’s latest ESG report also casts doubts on their belief in their ability to meet their goal on time. They wrote:
"While we are proud of the progress we have made and remain committed to our goal, we may not be able to achieve it by the end of 2025 due to the challenges posed by the broader packaging ecosystem required to make the remaining portion of our portfolio recyclable, reusable, or compostable."
When compared against its peers, 87% put Kraft Heinz in the promising position of being in the second quartile on the Integrum ESG Platform.
But as consumer frustration builds over waste caused by unsustainable packaging, it remains to be seen how far off their target Kraft Heinz lands come 2025.
Aviva Investors have been fined by Luxembourg's financial regulator for breaches identified in 5 of their funds categorised as SFDR Article 8.
𝟭. 𝗜𝗻𝘁𝗿𝗼𝗱𝘂𝗰𝘁𝗶𝗼𝗻
The CSSF's investigation took place between October 2022 - May 2023, and took aim at 4 of their current funds and one which had closed in 2023.
The regulator concluded that Aviva did not comply with two of their regulatory requirements and they were fined accordingly.
You can read the full CSSF decision here.
𝟮. 𝗪𝗵𝘆 𝗱𝗼𝗲𝘀 𝘁𝗵𝗶𝘀 𝗺𝗮𝘁𝘁𝗲𝗿?
It was reported that European Article 8 funds have €7.4trn in assets in June of this year - this sanction will therefore have potential consequences for many asset managers.
There are three key reasons we believe fund managers should be concerned:
🇪🇺 Impending European regulatory action on ESG misselling
👎 Reputational damage is hard to recover from
💰 Smaller managers will not have the resources to defend their claims
𝗧𝗵𝗶𝘀 𝗮𝗿𝘁𝗶𝗰𝗹𝗲 𝘄𝗮𝘀 𝘄𝗿𝗶𝘁𝘁𝗲𝗻 𝗯𝘆 𝗜𝗻𝘁𝗲𝗴𝗿𝘂𝗺 𝗘𝗦𝗚 𝗛𝗲𝗮𝗱 𝗼𝗳 𝗥𝗲𝘀𝗲𝗮𝗿𝗰𝗵 𝗛𝗮𝗻𝗻𝗮𝗵 𝗕𝗲𝗻𝗻𝗲𝘁𝘁.
The SEC has charged global asset manager Invesco Advisers Inc. for misleading claims about its ESG-related investments.
You can read the SEC's official findings here.
What happened?
The SEC found that Invesco overstated the extent to which ESG factors were integrated into its assets under management, prompting a $17.5 million civil penalty.
Invesco had made claims in its marketing materials from 2020 to 2022 that between 70% – 94% of its parent company’s assets under management were “ESG integrated”.
However, the SEC's investigation found that these amounts included a significant proportion of assets held in passive ETFs, that did not consider ESG factors in investment decisions.
The SEC also found that despite the ESG integration claims by the asset manager, the firm actually did not have "any written policy defining ESG integration.”
What does the data say?
This risk was captured on the Integrum ESG Platform, with the investment management company scoring just 0.5 on this issue out of a possible 4 — highlighting their lack of disclosure on their responsible marketing and labelling practices.
This case underscores the importance of transparency and robust policies, and follows a broader trend of regulatory crackdowns as authorities push back against greenwashing in response to rising concerns over the integrity of ESG claims.
𝗧𝗵𝗶𝘀 𝗮𝗿𝘁𝗶𝗰𝗹𝗲 𝘄𝗮𝘀 𝘄𝗿𝗶𝘁𝘁𝗲𝗻 𝗯𝘆 𝗜𝗻𝘁𝗲𝗴𝗿𝘂𝗺 𝗘𝗦𝗚 𝗥𝗲𝘀𝗲𝗮𝗿𝗰𝗵 𝗔𝗻𝗮𝗹𝘆𝘀𝘁 𝗔𝗹𝗶𝗰𝗶𝗮 𝗞𝗮𝗽𝗹𝗮𝗻.
Initially proposed in 2015, the 17 UN Sustainable Development Goals cover all areas of sustainability.
They are intended to be met in 2030 but with only a third of the time left how much progress are we really making?
Integrum ESG measures company level support for the UNSDGs using a methodology based on the Cambridge Impact Framework.
The 17 SDGs are mapped to 6 ‘Impact Metrics’ that evaluates companies’ positive impact on sustainability.
The promising news is that over the last reporting year we have seen improvements in the average awareness scores for all 6 metrics, showing that companies are taking more notice of their role in achieving the goals.
Effective from January 2 2025, former Morgan Stanley CEO James Gorman will succeed Mark Parker as Chairman of The Walt Disney Company [NYSE:DIS].
Once he steps into the role finding the company's next CEO to learn from and takeover from Bob Iger, whose contract is set to end at the end of 2026, will be his ''critical priority''. This article looks to forecast what Gorman joining Disney means for their sustainability goals, looking at:
🗣️ Gorman's tenure at Morgan Stanley
📊 Disney's current ESG standing
🛠️ Areas Disney can look to improve
All ESG data referenced can be seen on and exported from the Integrum ESG Platform.
For any sustainable-minded investors, this new hire is positive news.
During his time at Morgan Stanley as CEO and most recently as Executive Chairman, James Gorman successfully manoeuvred the firm through the fallout of the 2008 financial crisis, the COVID-19 pandemic and even events like the Archegos Capital collapse.
He significantly expanding the firm's wealth and asset management business, and as he leaves the firm's stock price is just over 4x what it was when he joined.
Gorman has also made significant moves to position the firm as leaders in the sustainability space, including establishing the MS Institute for Sustainable Investing back in 2013.
Other laudable achievements include achieving carbon neutrality in 2022 across direct Scope 1 emissions, indirect Scope 2 from energy purchasing, and Scope 3 from business travel and owned assets that are leased.
The firm has also made considerable headway towards their goal of mobilising $1 trillion for sustainable solutions by 2030, with the current figure sitting at over £820 billion (including $640 billion mobilised towards low-carbon and green solutions).
James Gorman of course should not take all the plaudits - he has overseen this growth by building a team of individuals who are now considered leaders within the sustainability space, including Jessica Alsford (current CSO, having been Head of Sustainability Research since 2012) and Matthew Slovik (current Head of Global Sustainable Finance, joining from the integration team in 2010).
So what does this mean for Disney?
From an ESG perspective, we can forecast that the personnel Gorman brings in and the influence he has on the company's direction as a whole should only be positive.
Currently Disney score a 'B' on the Integrum ESG Platform, ranking 37th out of 383 companies in the 'Services' sector and 8th out of 62 companies in the 'Media & Entertainment' sub-sector.
There are certainly areas that can be improved under Gorman's watch, including:
◉ Competitive Behavior
Disney only scores a '1' for this metric - the company has a policy in place for anticompetitive practice (including price manipulation), but does not disclose breaches or penalties. They also do not disclose data on financial penalties due to anticompetitive business practices.
This is particularly relevant given Disney is frequently facing a number of anti-trust litigation cases, primarily regarding their popular streaming services. This includes the FuboTV antitrust case against the launch of Disney's new sports streaming service and a class action lawsuit brought by YouTube and DirecTV Stream subscribers amongst others.
◉ Climate Stability
Disney's is placed in the top quartile for their target setting and policies with regards to the company's greenhouse gas emissions, also disclosing a breakdown of all of their scope 1, 2 and 3 emissions (see page 65 of their 2023 Sustainability & Social Impact Report).
However, when looking at the actual numbers they disclose on their combined scope 1 & 2 GHG emissions (1720761 tCO₂e) the company falls into the bottom quartile of its peer group.
Gorman and the CEO he appoints will have a significant role to play in ensuring the company is aligned in achieving their 2030 environmental goals, including achieving net zero emissions for direct operations by 2030.
◉ Reputational Risk
Bob Iger's reign as CEO has been peppered with controversies; be that Elon Musk describing the company’s diversity programs as being “enforced by Disney’s DEI Gestapo”, or Iger's own response to the WGA & SAG-AFTRA strikes (calling the demands of these unions ''unrealistic'', ''disturbing'' and ''very disruptive'').
The new CEO should be one who can navigate the company to their long-term sustainable objectives while dealing with the barrage of scrutiny that a conglomerate and household name like Disney will face for doing so.
While there is certainly work to be done for Disney, by bringing in James Gorman investors and onlookers should be confident that a proven figurehead who cares about and understands sustainable growth is at the helm.
Eyes will now be on the choice of CEO.
An E. coli outbreak across multiple U.S. states has been directly linked to McDonald's Quarter Pounder sandwiches.
What was picked up on the Integrum ESG Platform?
On Tuesday 22nd Oct 2024, our real-time ESG tracker picked up this story for McDonald's Corp [NYSE: MCD] and as the red spike continued to grow an alert was sent out to our clients. The company's net real-time ESG score dropped to a low of negative 61.5%.
What actually happened?
The American Centers for Disease Control and Prevention (CDC) announced that they were investigation links between an outbreak of E. coli and McDonald's Quarter Pounder sandwiches. According to the CDC, at least 49 people in 10 states have been sickened, 10 of whom have been hospitalised.
The Quarter Pounder is the one sandwich that the company does not utilise frozen patties for, having used fresh meat for the product since 2018. The product and specific ingredients have been pulled from distribution across multiple states.
In a statement, McDonald’s said that it was taking ''swift and decisive action'' and that their ''initial findings from the investigation indicate that a subset of illnesses may be linked to slivered onions used in the Quarter Pounder and sourced by a single supplier that serves three distribution centers.''
How did investors react?
Closing at 314.70 USD, as the story spready the company's share price fell over 9% in after-hours trading to a low of 284.48 USD.
Investors will be looking at previous E.coli outbreaks, such as those suffered by Chipotle Mexican Grill [NYSE:CMG] and Jack in the Box [Nasdaq:JACK], with both companies at the time seeing sales decline as a direct result.
Can investors use ESG data to anticipate these events?
On 'Product Quality & Safety', Integrum ESG give McDonald's Corp an overall ESG risk score of a '1' (the second lowest score obtainable).
Indeed when comparing them to their sector peers, they are ranked only 37th out of 56 companies.
This poor ranking is due to a lacklustre awareness score (the qualitative data assessing how aware the company is of this issue in absolute terms) and a rock bottom performance score (the quantitative data assessing how the company performs relative it to its sector peers).
Poor quantitative disclosures are an issue for McDonald's across the board, with the company only scoring a higher than a '2' on performance for 6 out of 19 of the metrics they are scored on.
Investors investing in NYSE: MCD should utilise this material fundamental data alongside real-time alerts to properly incorporate ESG risk into their decision making, identifying these areas of concern early to make qualified and timely decisions on holding or trading.
𝗧𝗵𝗶𝘀 𝗮𝗿𝘁𝗶𝗰𝗹𝗲 𝘄𝗮𝘀 𝘄𝗿𝗶𝘁𝘁𝗲𝗻 𝗯𝘆 𝗜𝗻𝘁𝗲𝗴𝗿𝘂𝗺 𝗘𝗦𝗚 𝗥𝗲𝘀𝗲𝗮𝗿𝗰𝗵 𝗔𝗻𝗮𝗹𝘆𝘀𝘁 𝗞𝗶𝘁 𝗠𝗮𝗿𝗸𝘀.
We all know there are many factors that influence how one selects a pint: the weather, the price, the alcohol content, and even the time of day.
But should sustainability be a part of the selection criteria?
The often-overlooked reality is that brewing beer consumes a significant amount of energy, demands large quantities of fresh water, and generates a substantial by-product of spent grain, much of which typically goes to waste.
With this in mind, what actually is the most ‘sustainable’ choice of pint?
The judgment process
An important caveat here – I have limited this analysis to publicly listed alcoholic beverage companies, so I do apologise if you do not see your favourite niche beverage provider on this list.
If there are any other companies you think should be highlighted for their sustainability efforts, mention them in the comments below.
I used the Integrum Screener tool to assess these companies, so we can gauge a holistic understanding of which pints truly are outliers in sustainability.
With almost 50 different ESG metrics to evaluate, it has been whittled down to 3 brands:
🥉 Heineken N.V. [HEIA.AS] – B grade (ESG Score of 2.36)
🥈 Molson Coors [NYSE:TAP] – A grade (ESG Score of 2.80)
🥇 Diageo plc [LSE:DGE] - A grade (ESG Score of 3.07)
Why does Diageo stand above the rest?
Diageo is the top performer in the alcoholic beverage sub-sector within the Integrum universe.
Withgoals to source 100% of energy in their direct operations from renewable energy (50.3% as of 2024) and 100% of their packaging to be recyclable by 2030 (98% as of 2024), coupled with one ofthe most efficient water intensity figures of any brand in their sub-sector (262.56m3 of water per $1,000,000 revenue as of 2024), the company stands ahead of many of its industry peers with regards to sustainability.
However, it is across governance where Diageo really starts to pull away from its competitors, achieving an A-grade in our scoring methodology.
A closer inspection reveals that for 7 out of the 9 governance metrics, Diageo is either the joint or top performer compared with Molson and Heineken (in 5 out of 9 governance metrics Diageo comes out on top).
2 of these metrics are:
🏢 Board Composition, for which Diageo scores significantly higher for Gender diversity on the board (70% female; 28.6% Molson; 36.4% Heineken) and has the optimal board size of 12, compared to Molson’s, and;
👑 Management Process, for which Diageo has a score of 4 when assessing whether the company has full certification of the systems for managing ESG issues, compared to very little sustainable management systems for Molson and Heineken.
As well as producing a host of other alcoholic brands (Smirnoff, Captain Morgans, Tanqueray), Guinness remains one of Diageo’s key assets, with “the brand delivering 15% organic net sales growth, double-digit growth for seven consecutive halves” (pg. 11, Diageo Annual Report 2024).
Diageo also managed to maintain or increase share in their top three markets for Guinness (Great Britain, Ireland and US) in 2024.
So next time you treat yourself to a Guinness I hope it tastes that little bit creamier, knowing it’s a stout solution for a sustainable future (sorry I just had to).
Vanguard Investments Australia were fined a record A$12.9 million ($8.9 million USD) penalty for misleading sustainable investment claims.
The Vanguard Ethically Conscious Global Aggregate Bond Index Fund followed the Bloomberg Barclays MSCI Global Aggregate SRI Exclusions Float Adjusted Index, which Vanguard claimed excluded issuers with significant activities in areas including fossil fuels, alcohol and tobacco.
This was not the case, with the court finding that approximately 74% of the securities in the fund were not properly researched or screened against applicable ESG criteria, exposing investors to investments they would reasonably expect not to be included within the fund.
Our CEO Shai Hill commented on this story when the institution were first found guilty of greenwashing, you can read his commentary here.
The lesson to be learned remains the same.
As an investor, if you base your product on an index where exclusions or inclusions are based on 'guesstimated' ESG data, then unless you have made this methodology crystal clear to investors, you are the ones in regulatory jeopardy.
You cannot hide behind index providers.
𝗧𝗵𝗶𝘀 𝗮𝗿𝘁𝗶𝗰𝗹𝗲 𝘄𝗮𝘀 𝘄𝗿𝗶𝘁𝘁𝗲𝗻 𝗯𝘆 𝗜𝗻𝘁𝗲𝗴𝗿𝘂𝗺 𝗘𝗦𝗚 𝗦𝗲𝗻𝗶𝗼𝗿 𝗔𝗻𝗮𝗹𝘆𝘀𝘁 𝗠𝗼𝗹𝗹𝘆 𝗙𝗿𝗮𝘇𝗲𝗿.
The U.S. Department of Justice has filed a lawsuit against Visa, accusing the company of engaging in practices that stifle competition in the debit card market.
This is the latest competition lawsuit that has arisen following the Biden administration’s crackdown on monopoly concerns.
The case, flagged by the Integrum ESG real-time tracker, underscores rising concerns about Visa’s market dominance; more than 60% of debit transactions in the US are processed by the company, according to the lawsuit.
Visa allegedly used its power to block alternative networks and impose excessive fees, which not only raises costs for businesses and consumers but also hampers innovation in the payments sector.
For investors, this highlights why tracking ESG metrics—notably those related to competitive behaviour —is so critical. Early warnings like these can offer valuable insight into potential legal and regulatory risks before they escalate.
Visa currently performs poorly in the material metric of ‘Competitive Behavior’ on the Integrum ESG Platform, with an overall risk score of 1.5 out of 4. While they do have an anti-trust policy in place, their disclosure lacks clarity regarding potential liabilities from ongoing legal proceedings mentioned in their 10-K report.
A prime example of this transparency gap is highlighted in the Integrum ESG Performance Score Glassbox, where Visa’s statement reads,
"...on June 17, 2020, the Supreme Court found that Visa's UK domestic interchange restricted competition under applicable competition law. On September 30, 2021, Visa reached a confidential settlement agreement resolving on Merchant's claims."
Visa’s failure to disclose how much was spent on fines or legal defence during that fiscal year reflects a lack of transparency. As a result, they’ve been given a Performance Score of 0, placing them among the lowest in their peer group.
This low score serves as a clear warning for investors, signalling that Visa is not adequately managing this significant sector-specific risk.
The recent lawsuit highlights how neglecting such important ESG risks can have significant financial repercussions - evident in the 5% drop in Visa's share price following the news.
In a world increasingly focused on transparency and fair competition, investors must prioritise monitoring such ESG risks to better understand the long-term health and sustainability of their portfolios.
𝗧𝗵𝗶𝘀 𝗮𝗿𝘁𝗶𝗰𝗹𝗲 𝘄𝗮𝘀 𝘄𝗿𝗶𝘁𝘁𝗲𝗻 𝗯𝘆 𝗜𝗻𝘁𝗲𝗴𝗿𝘂𝗺 𝗘𝗦𝗚 𝗥𝗲𝘀𝗲𝗮𝗿𝗰𝗵 𝗔𝗻𝗮𝗹𝘆𝘀𝘁 𝗡𝗲𝗵𝗮 𝗞𝗮𝗻𝗱𝘄𝗮𝗹.
A brief summary of major ESG controversies corporations faced this month - focussing on human rights, consumer protection and regulatory compliance:
Tyson Foods [TSN:NYSE] - Allegations of Greenwashing 🍔
The environmental law firm that filed the lawsuit alleged that the company has made misleading claims regarding its ‘climate-smart beef’, does not have a real climate action roadmap and is falling far behind on its net-zero commitment.
Tyson Foods saw a spike in their negative sentiment owing to news of the company facing a greenwashing lawsuit.
On the Integrum ESG Platform, we can see that Tyson receives an awareness score of 4 on the GHG emissions metric which translates to excellent policies and management of the issue. There is a significant gap between the company's values and its actions.
Despite receiving a top awareness score for GHG emissions - representing excellent policies and reporting on the issue - Tyson Foods' carbon emissions place them in the bottom quartile compared to sector peers.
Volkswagen AG [VOW.DE] - Recalls and Failed Audits 🚙
Volkswagen has faced a challenging month, with its former CEO's "dieselgate" trial unfolding in court and the potential closure of a factory in its home country on the horizon. To top it off, the company found itself at the center of not one, but two controversial news stories this month.
Earlier this month, nearly 99,000 Volkswagen ID.4 electric crossover SUVs were recalled because the door handles may unexpectedly open while driving.
More recently, reports of the company’s audit of its’ Xinjiang manufacturing plant which failed to meet key aspects of the SA8000 standard have surfaced. This independent audit was prompted by investor demand last year, given concerns about the working conditions for their employees in China.
Nike, Inc. [NKE:NYSE] - Workers' Rights Action 👟
Lastly, our sentiment tracker also picked up a story about Nike, where one of its top investors (Norway’s sovereign wealth fund) decided to support a proposal at the AGM held earlier this month, urging the company to review binding labor agreements to address human rights concerns in high-risk countries.
While rival sports brands Adidas and Puma have signed the Pakistan Accord, a legally binding agreement between brands and trade unions, Nike has shied away from it so far.
This action followed pressure from over 60 investors calling on Nike to pay the $2.2 million reportedly owed to more than 4,000 garment workers in Cambodia and Thailand, who lost wages due to factory closures during the COVID-19 pandemic.
𝗧𝗵𝗶𝘀 𝗮𝗿𝘁𝗶𝗰𝗹𝗲 𝘄𝗮𝘀 𝘄𝗿𝗶𝘁𝘁𝗲𝗻 𝗯𝘆 𝗜𝗻𝘁𝗲𝗴𝗿𝘂𝗺 𝗘𝗦𝗚 𝗛𝗲𝗮𝗱 𝗼𝗳 𝗥𝗲𝘀𝗲𝗮𝗿𝗰𝗵 𝗛𝗮𝗻𝗻𝗮𝗵 𝗕𝗲𝗻𝗻𝗲𝘁𝘁.
Last week, Australia passed a law which will require certain organisations to include climate disclosure in their annual reports for financial years commencing after January 1st 2025.
The new reporting requirements are largely in line with the IFRS S2 standards, and will make emissions disclosure mandatory, alongside disclosure on governance, strategy and risk management processes used to assess and manage climate risks.
Currently, data on the Integrum ESG Platform shows that approximately 20% of Australian companies do not disclose their Scope 1 &2 carbon emissions.
This new law means that this number should shrink to 0 by 2028 (there is a phased in approach based on company size).
In Australia, the fiscal year concludes in June, so many annual reports are currently being released for FY24.
That is the case for two large Australian companies;
🗃️ CAR Group [CAR:ASX], who recently published they FY24 report in which they quantified their global carbon footprint for the first time, having previously published data for only Australian operations.
🗃️ Similarly, The Lottery Corporation [TLC:ASX] recently published their inaugural standalone Sustainability report, which included emissions disclosure for the first time.
It will be interesting to see how many more Australian companies adopt these disclosure requirements earlier than mandated. We will be keeping an eye on the impact of this on industry practices and investor confidence.
Integrum ESG have an ongoing partnership with City A.M. as part of their Impact A.M. campaign to provide investors with the latest ESG insights & cutting-edge analyses.
To read all of Integrum ESG's latest insights, please follow the link below:
𝗧𝗵𝗲 𝗳𝗼𝗹𝗹𝗼𝘄𝗶𝗻𝗴 𝗶𝘀 𝗮 𝘄𝗿𝗶𝘁𝗲-𝘂𝗽 𝗯𝘆 𝗜𝗻𝘁𝗲𝗴𝗿𝘂𝗺 𝗘𝗦𝗚 𝗮𝗻𝗮𝗹𝘆𝘀𝘁 𝗠𝗼𝗹𝗹𝘆 𝗙𝗿𝗮𝘇𝗲𝗿 𝗮𝗳𝘁𝗲𝗿 𝗵𝗮𝘃𝗶𝗻𝗴 𝗮𝘁𝘁𝗲𝗻𝗱𝗲𝗱 𝗣𝗼𝗿𝘁𝗳𝗼𝗹𝗶𝗼 𝗜𝗻𝘀𝘁𝗶𝘁𝘂𝘁𝗶𝗼𝗻𝗮𝗹’𝘀 𝗘𝗦𝗚 𝗖𝗹𝘂𝗯 𝗖𝗼𝗻𝗳𝗲𝗿𝗲𝗻𝗰𝗲 𝗼𝗻 𝟭𝟯 𝗦𝗲𝗽𝘁𝗲𝗺𝗯𝗲𝗿 𝟮𝟬𝟮𝟯. 𝗧𝗵𝗶𝘀 𝘄𝗮𝘀 𝗮𝗻 𝗲𝘃𝗲𝗻𝘁 𝗮𝘁𝘁𝗲𝗻𝗱𝗲𝗱 𝗯𝘆 𝗺𝗮𝗻𝘆 𝗹𝗲𝗮𝗱𝗶𝗻𝗴 𝗳𝗶𝗴𝘂𝗿𝗲𝘀 𝗶𝗻 𝘁𝗵𝗲 𝗨𝗞 & 𝗘𝗨 𝗔𝘀𝘀𝗲𝘁 𝗢𝘄𝗻𝗲𝗿 𝗰𝗼𝗺𝗺𝘂𝗻𝗶𝘁𝘆, 𝘄𝗵𝗲𝗿𝗲 𝗶𝗻𝘀𝘁𝗶𝘁𝘂𝘁𝗶𝗼𝗻𝗮𝗹 𝗶𝗻𝘃𝗲𝘀𝘁𝗼𝗿𝘀 𝗲𝗻𝗴𝗮𝗴𝗲𝗱 𝗼𝗻 𝗵𝗼𝘄 𝘁𝗼 𝗿𝗲𝗱𝘂𝗰𝗲 𝘁𝗵𝗲 𝘄𝗼𝗿𝗹𝗱’𝘀 𝗿𝗲𝗹𝗶𝗮𝗻𝗰𝗲 𝗼𝗻 𝗳𝗼𝘀𝘀𝗶𝗹 𝗳𝘂𝗲𝗹𝘀, 𝗽𝗿𝗼𝘁𝗲𝗰𝘁 𝘁𝗵𝗲 𝗲𝗰𝗼𝘀𝘆𝘀𝘁𝗲𝗺, 𝗮𝗻𝗱 𝗽𝗿𝗼𝗺𝗼𝘁𝗲 𝗴𝗿𝗲𝗮𝘁𝗲𝗿 𝗲𝗾𝘂𝗮𝗹𝗶𝘁𝘆.
“𝙃𝙤𝙬 𝙘𝙖𝙣 𝙥𝙚𝙤𝙥𝙡𝙚 𝙩𝙧𝙪𝙨𝙩 𝙀𝙎𝙂 𝙧𝙖𝙩𝙞𝙣𝙜𝙨 𝙩𝙝𝙚𝙮 𝙙𝙤𝙣’𝙩 𝙪𝙣𝙙𝙚𝙧𝙨𝙩𝙖𝙣𝙙?”
During the event, our CEO Shai participated in a panel discussion focused on the question of whether investors can place trust in ESG ratings and take them seriously.
One of the many questions he raised was why are people taking ESG ratings which they don’t understandseriously?
Investors need to see the underlying data behind these ratings to explain the scores. Transparency around methodology and reason for score should therefore be a key priority for EGS ratings providers.
𝙉𝙚𝙩 𝙯𝙚𝙧𝙤, 𝘽𝙞𝙤𝙙𝙞𝙫𝙚𝙧𝙨𝙞𝙩𝙮 & 𝙩𝙝𝙚 ‘𝙎’ 𝙞𝙣 𝙀𝙎𝙂
The other three panel discussions also provided many invaluable insights, including but not limited to:
♳ On the discussion of transition assets and the net zero pathway, it was emphasised that public markets are not going to be able to solve the issue on their own, emphasising the need for clear, uniform regulation to drive progress in this area.
♴ There is no silver bullet when it comes to measuring biodiversity loss; but we do not need perfection in data to start trying to reverse biodiversity loss.
♵ While in environmental issues we can think about ‘offsets’ to counter poor behaviour in one area, this cannot be the same for social issues. Providing a universal living wage for your employees does not negate the poor treatment of a company’s tier 2 supplier workforce.
𝘼𝙘𝙩𝙞𝙤𝙣 𝙥𝙤𝙞𝙣𝙩𝙨 𝙛𝙤𝙧 𝙩𝙝𝙚 𝙛𝙪𝙩𝙪𝙧𝙚
The conference revealed a path forward in ESG investing; transparency, collaboration, and holistic approaches. Imperfect data shouldn’t hinder action on pressing environmental and social challenges.
Asset owners and managers alike have the capacity and responsibility to shape a more sustainable and equitable future – act now!
𝗧𝗵𝗶𝘀 𝗮𝗿𝘁𝗶𝗰𝗹𝗲 𝘄𝗮𝘀 𝘄𝗿𝗶𝘁𝘁𝗲𝗻 𝗯𝘆 𝗜𝗻𝘁𝗲𝗴𝗿𝘂𝗺 𝗘𝗦𝗚 𝗮𝗻𝗮𝗹𝘆𝘀𝘁 𝗞𝗶𝘁 𝗠𝗮𝗿𝗸𝘀.
Although not the first topic that springs to mind, ESG is a significantly polarising topic between Democrats and Republicans.
This year it adopted a new symbol of partisanship: Biden’s rejection of a Republican proposal in March, which prevented pension fund managers from basing investment decisions on factors like climate change, was the first veto of his presidency.
The US Department of Labor ruling would make it easier for fund managers to consider ESG issues in investments and shareholders in decision making. Republicans believe ESG politicises investing by allowing managers to pursue ‘liberal’ causes, which would hurt financial performance.
The Dems have expanded the scope of ESG through large investment in green infrastructure from the Inflation Reduction Act, as well as the aforementioned DoL rule on pension plans (and other legislation).
However, across the House, the two front-runners for the 2024 Republican nomination, Trump and DeSantis, both vehemently oppose ESG; the former in a 2024 campaign video blasted ESG as Wall Street “radical-left garbage.”
In March, DeSantis formed an alliance with 18 US states to pushback against the DoL’s new rule allowing ESG-aligned funds in 401(k) plans. Florida’s Senate also approved a bill banning state and local governments from using ESG criteria when selling debt or investing public money in April. It also prohibits Florida municipalities from selling bonds related to ESG projects and bans seeking ESG ratings.
A Republican victory, even if the potency of any future legislation is diluted by Democrat defiance, would be a far cry for ESG compared to the Biden administration.
According to Morningstar, anti-ESG sentiment, coupled with rising interest rates, have resulted in a pullback of $US5.2bn from sustainable funds in Q1 of 2023, making it the third quarter of continuous withdrawal in a year.
ESG debt, according to Bloomberg, made up only 2.5% of US$248bn of bonds issued by US companies in Q1 of 2023, as opposed to 6.08% of US$209bn of bonds issued in Q1 2022.
Owing partly to this backlash, it’s likely that greeniums could diminish on US ESG debt, as demand for ESG bonds may decrease significantly.
𝗪𝗵𝗮𝘁 𝗱𝗼𝗲𝘀 𝘁𝗵𝗶𝘀 𝗺𝗲𝗮𝗻 𝗳𝗼𝗿 𝗘𝗦𝗚 𝗶𝗻 𝟮𝟬𝟮𝟰?
In 2024, the House and one-third of the 100-seat Senate will be up for election.
Currently, Republicans have a slim majority in the House, while the Democrats have a slim majority in the Senate. A clear majority in both the houses after the elections will give greater clarity on the future of ESG in the US.
However, if the narrow majority margins in the two houses persist after the elections, ESG will continue to be the centre of a big political divide.
"Let's talk about why you need high quality & transparent ESG data"
Every week, we speak to a new fund manager or private equity investor. They vary in size, AUM and purpose, and the level of ESG integration within their reporting systems they can boast can be significant or minimal.
Recently, a lot of these investors seem to say the same thing:
"We do not have the budget for better ESG data right now."
The majority of these investment firms seem to accept the idea that implementing good ESG data is costly - and it is no surprise why.
The existing large legacy ESG ratings and data providers offer exorbitant subscription fees and lock you in for years at a time.
These prices have only continued to rise despite difficult market conditions.
Their data is often opaque and their scores are built upon unclear methodologies - which only serves to increase the cost to you of implementing these systems. Investment analysts are required to do more work to unpack any ratings or leave themselves vulnerable to 'greenwashing' claims.
"But good ESG data does not need to be expensive."
When we tell these same managers the cost of our entirely transparent, customisable and yet still comprehensive ESG ratings and data solution, they are usually surprised. Their suspicion grows when we tell them that we do not need them to sign on for years, we just offer a rolling quarterly subscription.
💭 "Are you really able to offer all of this for so little?"
💭 "Is the quality of your data really as good as you say?"
💭 "Is your company even able to survive with these low costs?"
The simple answer to all of the above is yes - the reason why, is also relatively simple. It is because we are an AI-powered ESG data provider.
How does AI save you costs exactly?
We are the only ESG data provider able to provide you with this level of speed and precision, built upon our innovative data-centric AI methodologies - this is what makes us stand out from the rest:
➡️ Quality and Accuracy.
Our systems' focus on transparency and 'explainability' means the ESG scores you see are always up to date and trustworthy - you can export all data we pick up and verify its quality for yourself.
➡️ Better and broader Benchmarking.
The thousands of data sources we are able to pull from ensures that the level of benchmarking we provide is industry leading.
➡️ Ability to scale up at a low cost.
Our unique 'Human-in-the-loop' approach effectively blends Artificial and Human Intelligence - meaning that we only need a small team of ESG experts overseeing the rating process of every company.
These systems mean that we can continue to expand our coverage and improve data quality while saving on the costs usually anticipated with this level of growth - and we can then share these savings with you.
𝗔 𝗴𝗹𝗼𝗯𝗮𝗹 𝘀𝗲𝘁 𝗼𝗳 𝗘𝗦𝗚 𝗱𝗶𝘀𝗰𝗹𝗼𝘀𝘂𝗿𝗲 𝘀𝘁𝗮𝗻𝗱𝗮𝗿𝗱𝘀 𝗵𝗮𝘀 𝗲𝗺𝗲𝗿𝗴𝗲𝗱.
It will be known as the IFRS Sustainability Disclosure Standards (https://www.ifrs.org/issued-standards/ifrs-sustainability-standards-navigator/).
The Standards will be managed by the International Sustainability Standards Board, but they are the intellectual property of the IFRS Foundation, and will sit alongside the IFRS International Accounting Standards.
The G7 Finance Ministers have already endorsed them (when the draft standards were released). The UK financial regulator has already said these standards will form the core of its 'Sustainable Disclosure Regulation', and several of the largest accountancy firms are already building assurance practices around these standards.
So whilst some prefer the broader GRI Standards, and the EU wants to advance its EFRAG Sustainability Reporting Standards, we think it is clear that the battle to become the global benchmark has now been won by ISSB.
𝗪𝗵𝗮𝘁 𝗱𝗼 𝘁𝗵𝗲𝘀𝗲 𝗻𝗲𝘄 𝗜𝗙𝗥𝗦 𝗦𝘁𝗮𝗻𝗱𝗮𝗿𝗱𝘀 𝗹𝗼𝗼𝗸 𝗹𝗶𝗸𝗲?
Well, they are not really new;
➡️ The 'IFRS S1 General Requirements for Disclosure of Sustainability-related Financial Information' will apply the SASB Standards that have been in the market for many years.
➡️ The only addition will be the 'IFRS S2 Climate-related disclosures', based on the FSB Task Force on Climate-related Financial Disclosures (TCFD) recommendations.
Integrum ESG is pleased to announce that it is a founding member of the European Association of Sustainability Rating Agencies (EASRA). The EASRA stands for transparency, rigor, independence and the promotion of double materiality.
The association aims to become the representative body of a new breed of sustainable finance service providers, with a view to enhancing the functioning of ESG rating provision and its contribution to a more sustainable European economy.
EASRA founding members are 𝗖𝗼𝘃𝗮𝗹𝗲𝗻𝗰𝗲 (𝗖𝗛), 𝗘𝘁𝗵𝗶𝗙𝗶𝗻𝗮𝗻𝗰𝗲 (𝗙𝗥, 𝗚𝗘, 𝗦𝗣), 𝗜𝗻𝗿𝗮𝘁𝗲 (𝗖𝗛) and 𝗜𝗻𝘁𝗲𝗴𝗿𝘂𝗺 𝗘𝗦𝗚 (𝗨𝗞) and other leading independent players are expected to join in the coming weeks.
Emmanuel de La Ville, founder of EthiFinance and EASRA Acting Chairman said:
"We are proud of setting up this association. European ESG rating providers need a forum to exchange views, share best practices and align themselves where possible on an evolving regulatory agenda. All stakeholders should benefit from this new organization at a time when sustainable finance is facing considerable challenges and opportunities. We look forward to welcoming additional ESG rating services providers in the membership and to engaging with all interested stakeholders in due course."
Earlier this year FTSE Russell published their annual global asset owner survey, focusing on their attitudes, priorities and decisions being made on sustainable investment.
You can read the full results of the survey here.
One of the key readings taken from this survey was that over half of asset owner participants believe that the primary obstacle to increased sustainable investment adoption is concerns about availability of ESG data and the use of estimated data.
We have written about the issue with guesstimated data before.
Some large ESG ratings firms have padded their systems with estimates and averages in order to provide larger (and more expensive) coverage and more 'comprehensive' data solutions.
However, there are many issues with this approach - three key problems being:
𝟭. 𝙎𝙝𝙤𝙧𝙩-𝙩𝙚𝙧𝙢𝙞𝙨𝙢 𝙞𝙨 𝙖 𝙗𝙧𝙚𝙖𝙘𝙝 𝙤𝙛 𝙛𝙞𝙙𝙪𝙘𝙞𝙖𝙧𝙮 𝙙𝙪𝙩𝙮.
Many investors blindly trust these large legacy brands and their ESG ratings; in fact some asset owners demand that their asset managers use one of them.
However, it should be noted that relying on the estimated ESG data provided by these firms could constitute a breach of fiduciary duty.
That is to say, relying on data you can not validate or interrogate in order to satisfy a short-term reporting or regulatory requirement is not acting in the best interest of the investors that these funds truly serve.
𝟮. 𝙏𝙝𝙚 𝙬𝙤𝙧𝙙 '𝙚𝙨𝙩𝙞𝙢𝙖𝙩𝙚𝙙' 𝙨𝙪𝙜𝙜𝙚𝙨𝙩𝙨 𝙖𝙣 𝙖𝙣𝙖𝙡𝙮𝙨𝙩 𝙢𝙞𝙜𝙝𝙩 𝙝𝙖𝙫𝙚 𝙨𝙩𝙪𝙙𝙞𝙚𝙙 𝙩𝙝𝙖𝙩 𝙘𝙤𝙢𝙥𝙖𝙣𝙮 𝙖𝙣𝙙 𝙞𝙩𝙨 𝙞𝙣𝙙𝙪𝙨𝙩𝙧𝙮 𝙖𝙣𝙙 𝙢𝙖𝙙𝙚 𝙖𝙣 𝙞𝙣𝙛𝙤𝙧𝙢𝙚𝙙 𝙘𝙤𝙢𝙥𝙖𝙣𝙮-𝙨𝙥𝙚𝙘𝙞𝙛𝙞𝙘 𝙚𝙨𝙩𝙞𝙢𝙖𝙩𝙚.
In reality, although their precise methodology is typically opaque, the estimated value is just an average, calculated from that company's regional and sectoral peer group. That's why we call it a 'guesstimate'.
The example we give to investors is that it is like hiring an analyst after you were reassured that they got 70% in their final mathematics exam. You then learn that actually, they never showed up for that exam and this score was in fact a class average. Which leads onto the next key point:
𝟯. 𝙄𝙩 𝙞𝙨 𝙣𝙤𝙩 𝙘𝙡𝙚𝙖𝙧 𝙬𝙝𝙖𝙩 𝙘𝙤𝙢𝙥𝙖𝙣𝙮 𝙙𝙖𝙩𝙚 𝙞𝙨 𝙛𝙖𝙘𝙩𝙪𝙖𝙡 𝙖𝙣𝙙 𝙬𝙝𝙖𝙩 𝙞𝙨 𝙚𝙨𝙩𝙞𝙢𝙖𝙩𝙚𝙙.
Depending on the third party data provider you may be subscribed to, you can sometimes click through some of the data they have collected - for example, a company's CO2 emissions number.
But you won't know whether it is an actual value disclosed by the company, or a value estimated by the many analysts working for that ratings firm.
No estimated data - no black boxes.
Here at Integrum ESG, we have always committed to never using estimated data and only providing a 'glass box' to our investor clients.
Our affordable, customisable and transparent ESG solution was built by investors with over 20 years of experience in equity research - therefore we understand the real dangers of using opaque data which is only updated once every so often.
𝗧𝗵𝗶𝘀 𝗮𝗿𝘁𝗶𝗰𝗹𝗲 𝘄𝗮𝘀 𝘄𝗿𝗶𝘁𝘁𝗲𝗻 𝗯𝘆 𝗜𝗻𝘁𝗲𝗴𝗿𝘂𝗺 𝗘𝗦𝗚 𝗮𝗻𝗮𝗹𝘆𝘀𝘁 𝗠𝗼𝗹𝗹𝘆 𝗙𝗿𝗮𝘇𝗲𝗿.
Last month, my colleague Hazel Cranmer wrote a post on the issues of companies relying solely on carbon ‘offsetting’ to reach decarbonisation goals.
She argued carbon offsets fail to make genuine carbon reductions, and that we should instead invest in ‘carbon insetting’; avoiding emissions at the source “rather than being forced to clean them up”.
As the carbon market heads into turmoil following the recent announcement from Zimbabwe (https://www.bloomberg.com/news/articles/2023-05-18/global-carbon-market-in-turmoil-after-zimbabwe-grabs-offset-money?leadSource=uverify%20wall), offset schemes have become more unreliable in achieving carbon neutral status.
It has become apparent that this sentiment is widely shared, with both the EU parliament and UK’s advertising watchdog proposing bans last week on adverts making ‘carbon neutral’ product claims using offsets. (https://www.theguardian.com/environment/2023/may/15/uk-advertising-watchdog-to-crack-down-on-carbon-offsetting-claims-aoe & https://us10.campaign-archive.com/?e=6cd1763d23&u=f89d68518db6e2585b0808206&id=35b50e16fc) .
The crackdown comes as no surprise, given the seemingly endless cases of companies being exposed for greenwashing.
Examples include the TotalEnergies lawsuit, who claimed their Thermoplus heating oil was carbon neutral through compensating for emissions via offsetting schemes in India and Peru, and the banning of Lufthansa’s recent campaign declaring their green efforts (carbon offsets) were ‘protecting the world’s future’.
𝗛𝗼𝘄 𝗺𝗶𝗴𝗵𝘁 𝘁𝗵𝗲𝘀𝗲 𝗽𝗿𝗼𝗽𝗼𝘀𝗮𝗹𝘀 𝗮𝗳𝗳𝗲𝗰𝘁 𝘁𝗵𝗲 𝘀𝘂𝘀𝘁𝗮𝗶𝗻𝗮𝗯𝗶𝗹𝗶𝘁𝘆 𝗹𝗮𝗻𝗱𝘀𝗰𝗮𝗽𝗲?
I believe we will see two changes:
1. More accurate sustainable purchasing decisions
Despite growing success in exposing dubious green claims, it is likely that many other companies make similar statements but evade consequences. The recent proposals should hopefully discourage such behaviour, prompting companies to either verify their claims or refrain from making them altogether. We should then, in theory, be able to trust what companies are advertising to us and make more accurate decisions on what we buy based on sustainability grounds.
2. A shift towards carbon ‘insetting’
Apprehension of lawsuits could push companies towards more credible initiatives to substantiate their green claims. In essence, the crackdown should serve as a catalyst for companies to shift their reliance on feeble offsetting schemes and embrace more robust approaches in reducing the carbon footprint of their offerings.
𝗜𝘀 𝘁𝗵𝗲𝗿𝗲 𝗮𝗻𝘆 𝘂𝘀𝗲 𝗳𝗼𝗿 𝗰𝗮𝗿𝗯𝗼𝗻 𝗼𝗳𝗳𝘀𝗲𝘁 𝘀𝗰𝗵𝗲𝗺𝗲𝘀 𝗶𝗻 𝘀𝘂𝘀𝘁𝗮𝗶𝗻𝗮𝗯𝗶𝗹𝗶𝘁𝘆 𝘀𝘁𝗿𝗮𝘁𝗲𝗴𝗶𝗲𝘀?
We at Integrum ESG do not include carbon offsets in calculating the carbon footprint of companies (as per GHG Protocol guidelines).
However, investments in offsetting schemes should not be discouraged entirely. Not only do they contribute to the pool of climate finance needed to reach international climate goals, but they also demonstrate a company’s dedication to global climate mitigation beyond their value chain; a policy valued by ESG ratings providers and investors.
But what do you think?
𝗘𝗦𝗚 𝗥𝗲𝗱 𝗦𝗽𝗶𝗸𝗲𝘀 📈
𝗨𝗻𝗶𝗼𝗻 𝗱𝗶𝘀𝗽𝘂𝘁𝗲𝘀, '𝗣𝗼𝘀𝘁𝗮𝗹 𝗱𝗲𝘀𝗲𝗿𝘁𝘀' & 𝗥𝗲𝗴𝘂𝗹𝗮𝘁𝗼𝗿𝘆 𝗮𝗰𝘁𝗶𝗼𝗻
𝗪𝗵𝗮𝘁 𝗱𝗶𝗱 𝘄𝗲 𝘀𝗲𝗲?
Our Real-time ESG Tracker picked up growth in negative sentiment for Royal Mail (IDS.L), flagging numerous stories across the past week which correlated with falling share value.
Our systems immediately sent out an alert to our clients with Royal Mail in their portfolio.
𝗪𝗵𝗮𝘁 𝗱𝗶𝗱 𝘄𝗲 𝗹𝗲𝗮𝗿𝗻?
In what seems to be a worrying trend for Royal Mail, with the company only earlier this year having threatened to declare insolvency, both investor and consumer confidence continues to be challenged - we were able to capture each different story early and flagged it to our clients.
𝗪𝗵𝗮𝘁 𝗼𝘂𝗿 𝗥𝗲𝗮𝗹-𝗧𝗶𝗺𝗲 𝗘𝗦𝗚 𝗧𝗿𝗮𝗰𝗸𝗲𝗿 𝘀𝗮𝘄
We have summarised the main stories which we captured across wider media and Twitter for you below:
🗓️ 𝗧𝘂𝗲𝘀𝗱𝗮𝘆 𝟵𝘁𝗵 𝗠𝗮𝘆
Reports begin to filter through that Royal Mail CEO, Simon Thompson, is set to announce his departure from the company as a step to finally resolve a long running dispute with the Communication Workers Union (CWU).
Share price for IDS.L had a high of 250.20 🔻 to a low of 244.47. 📈
🗓️ 𝗪𝗲𝗱𝗻𝗲𝘀𝗱𝗮𝘆 𝟭𝟬𝘁𝗵 𝗠𝗮𝘆
The story regarding the soon-to-be resignation of the Royal Mail CEO begins to spread throughout wider media.
Outsourcing firm and government contractor Capita, whose systems are used to administer pensions for the Royal Mail amongst other organisations, reveal it will take a hit of around £20m from a recent cyber attack that saw some customer, supplier and colleague data accessed by hackers.
Share price for IDS.L had a high of 246.62 🔻 to a low of 232.8. 📈
🗓️ 𝗙𝗿𝗶𝗱𝗮𝘆 𝟭𝟭𝘁𝗵 𝗠𝗮𝘆
Reports that Royal Mail reportedly failing to frequently deliver post were causing dozens of areas to become “postal deserts” - with some areas receiving letters as little as once a fortnight.
Share price for IDS.L had a high of 236 🔻 to a low of 229.2. 📈
🗓️ 𝗠𝗼𝗻𝗱𝗮𝘆 𝟭𝟱𝘁𝗵 𝗠𝗮𝘆
It is widely reported that the UK regulator Ofcom has launched an investigation into Royal Mail’s failure to meet its delivery targets in the past year - and will fine the company if it cannot reasonably explain why it missed the targets.
Share price for IDS.L had a high of 229.13 🔻 to a low of 224.9. 📈
𝗧𝗵𝗶𝘀 𝗮𝗿𝘁𝗶𝗰𝗹𝗲 𝘄𝗮𝘀 𝘄𝗿𝗶𝘁𝘁𝗲𝗻 𝗯𝘆 𝗜𝗻𝘁𝗲𝗴𝗿𝘂𝗺 𝗘𝗦𝗚 𝗮𝗻𝗮𝗹𝘆𝘀𝘁 𝗝𝗮𝗰𝗸 𝗠𝗼𝗿𝗽𝗵𝗲𝘁.
When CEOs of large public companies are receiving large wages and bonuses, should these bonuses be rewarded when there is a reduction in company value? Why should shareholders reward poor performance, and therefore reinforce misalignment?
A recent example of this is seen when Uber's CEO Dara Khosrowshahi, was rewarded with a 146.9% increase on his $2 million bonus (on top of his $24 million compensation package) in 2022 due to a vague ‘better-than-baseline company performance’ even though the company stock had fallen by 40% (https://www.cmswire.com/leadership/what-the-heck-is-happening-at-uber/).
Alignment and executive pay
One of the most important governance metrics (with the highest number of sub-metrics captured under this metric by Integrum ESG) is Remuneration Alignment, which evaluates executive pay alignment with company shareholders’ interests.
A long-standing issue exists (particularly in large public companies with many shareholders), where separation of ownership (shareholders) and control (managers/executives) leads to a loss of alignment with the owners’ interests, often now called ‘the agency problem’.
Executive pay in large public companies can be a controversial topic due to leviathan compensation packages, which are used to combat the agency problem, keeping interests aligned with performance-related remuneration goals and long-term incentives that are of importance to the company, usually containing key performance indicators (KPIs).
Many KPIs are increasingly focused on ESG targets such as aiming for net zero by 2050, in line with the Paris Agreement.
Will things change?
Ultimately, the responsibility of executive pay and alignment is down to the Remuneration Committee on the board.
The U.S. Securities and Exchange Commission adopted a Pay Versus Performance disclosure rule in August last year. This makes it mandatory for US companies to disclose the relationship between executive compensation actually paid compared to the financial performance of the company.
It is clear that remuneration alignment is building in importance for regulators and shareholders alike, particularly when considering the desired transparency they expect from corporates and fund managers.
𝗘𝗦𝗚 𝗥𝗲𝗱 𝗦𝗽𝗶𝗸𝗲𝘀 📈
𝗖𝗘𝗢𝘀, 𝗕𝗼𝗻𝘂𝘀𝗲𝘀 & "𝗣𝗶𝘁𝘆 𝗖𝗶𝘁𝘆"
𝗪𝗵𝗮𝘁 𝗱𝗶𝗱 𝘄𝗲 𝘀𝗲𝗲?
Our Real-time ESG Tracker picked up a significant negative red spike for MillerKnoll (MLKN), starting by flagging one of the first tweets made about the controversy.
Our systems immediately sent out an alert to our clients with MillerKnoll in their portfolio.
𝗪𝗵𝗮𝘁 𝗱𝗶𝗱 𝘄𝗲 𝗹𝗲𝗮𝗿𝗻?
MillerKnoll CEO, Andi Owen, came under fire after a video was released of her scolding her employees for complaining about not receiving bonuses - advising them to "leave pity city" and focus on making money for the company.
This was even though she herself had made almost $1.2 million in bonuses in the previous year, as part of a pay package worth nearly $5 million.
These comments had ramifications on public sentiment and their share price.
𝗪𝗵𝗮𝘁 𝗼𝘂𝗿 𝗥𝗲𝗮𝗹-𝗧𝗶𝗺𝗲 𝗘𝗦𝗚 𝗧𝗿𝗮𝗰𝗸𝗲𝗿 𝘀𝗮𝘄 🚩
The video was first leaked on Twitter on Friday 14th April just past midnight (GMT).
Our Real-Time ESG Tracker then immediately caught this tweet and all further tweets and articles relating to it.
The number of stories peaked on the 19th April, being reported on via many mainstream media sources and forcing the CEO to come out and apologise.
Since that initial story, the share price of MillerKnoll has continued to fall and has brought the issue of executive pay and bonuses back into the limelight.
𝗧𝗵𝗶𝘀 𝗮𝗿𝘁𝗶𝗰𝗹𝗲 𝘄𝗮𝘀 𝘄𝗿𝗶𝘁𝘁𝗲𝗻 𝗯𝘆 𝗜𝗻𝘁𝗲𝗴𝗿𝘂𝗺 𝗘𝗦𝗚 𝗖𝗘𝗢 𝗦𝗵𝗮𝗶 𝗛𝗶𝗹𝗹.
The EU regulators (ESA) have just proposed a set of revisions to the SFDR (Sustainable Finance Disclosure Requirement).
The consultation closes July and 2 law firms we have spoken to estimate any changes would come into legal effect in Jan 2024.
𝗛𝗲𝗿𝗲'𝘀 𝗮 𝘀𝘂𝗺𝗺𝗮𝗿𝘆 𝗼𝗳 𝘁𝗵𝗲 𝟱 𝗸𝗲𝘆 𝗽𝗼𝗶𝗻𝘁𝘀 𝗳𝗿𝗼𝗺 𝘁𝗵𝗲 𝟭𝟱𝟴-𝗽𝗮𝗴𝗲 𝗰𝗼𝗻𝘀𝘂𝗹𝘁𝗮𝘁𝗶𝗼𝗻 𝗽𝗮𝗽𝗲𝗿:
1️⃣ The number of mandatory PAIs (indicators that funds making sustainable investments will have to report to) will be increased from 14 to 18.
The new 4 are 'Social' indicators, relating to the companies the fund invests in:
🚩 Revenue earned in countries which don't co-operate with the EU on tax
🚩 Involvement in production of tobacco
🚩 Whether the company tries to block trade unions
🚩 % of staff earning less than an adequate wage
2️⃣ If the fund has an emissions reduction objective, it must publish quantified details.
3️⃣ More disclosure will be required on a fund's EU Taxonomy alignment (bringing SFDR and the Taxonomy closer together).
4️⃣ The requirement for a company to 'do no significant harm' to certain EU environmental and social objectives - if it is to classify as a 'sustainable investment' - will be more precisely defined (with quantified 'thresholds' to limit fund managers' discretion).
5️⃣ The regulatory disclosures that fund managers have to publish (Annexes II-V) will have a summary dashboard at the front, designed for non-professionals to understand.
𝗙𝗼𝗿 𝗮𝗻 𝗔𝗿𝘁𝗶𝗰𝗹𝗲 𝟴 𝗳𝘂𝗻𝗱, 𝗶𝘁 𝘄𝗶𝗹𝗹 𝗰𝗼𝗻𝘁𝗮𝗶𝗻 𝟱 𝗸𝗲𝘆 𝗯𝗼𝘅𝗲𝘀:
🚩 What 'environmental and social characteristics' are promoted by the fund (max 250 characters)
🚩 What % of the fund's investments are sustainable
🚩 What % of the fund's investments are Taxonomy-aligned
🚩 Does the fund consider the PAIs
🚩 If the fund supports an emissions reduction target, what is the total % reduction targeted, and by what year
𝗪𝗵𝗮𝘁 𝗰𝗼𝗻𝗰𝗹𝘂𝘀𝗶𝗼𝗻𝘀 𝘀𝗵𝗼𝘂𝗹𝗱 𝘄𝗲 𝗱𝗿𝗮𝘄 𝗳𝗿𝗼𝗺 𝘁𝗵𝗲𝘀𝗲 𝗻𝗲𝘄 𝗽𝗿𝗼𝗽𝗼𝘀𝗮𝗹𝘀?
💭 The SFDR compliance headache is not going away:
The EU seems determined to keep 'raising the bar' for any fund marketing itself as 'sustainable'.
💭 Investors' need for agile software that can keep up with increasing disclosure requirements is going to increase.
💭 Our argument about 𝐀𝐫𝐭𝐢𝐜𝐥𝐞 𝟴+ (linked here) gets stronger:
If a fund wants to be labelled Article 8 without reporting to the PAI, it will have to publish a front page 'dashboard' every quarter, that says "This product did not make sustainable investments" and then "This product did not consider the most significant negative impacts of its investments on the environment and society" (the regulator wants this wording to replace 'PAIs', to make it clearer).
Which will surely make any investor think "𝘵𝘩𝘪𝘴 𝘧𝘶𝘯𝘥 𝘮𝘪𝘨𝘩𝘵 𝘩𝘢𝘷𝘦 𝘢𝘯 𝘈𝘳𝘵𝘪𝘤𝘭𝘦 8 𝘭𝘢𝘣𝘦𝘭, 𝘣𝘶𝘵 𝘪𝘵 𝘪𝘴 𝘯𝘰𝘵 𝘪𝘯 𝘢𝘯𝘺 𝘮𝘦𝘢𝘯𝘪𝘯𝘨𝘧𝘶𝘭 𝘸𝘢𝘺 𝘢 𝘴𝘶𝘴𝘵𝘢𝘪𝘯𝘢𝘣𝘭𝘦 𝘧𝘶𝘯𝘥".
The ESG Data Converge Initiative (EDCI) was created to provide GPs & LPs with a set of universal ESG data points for all of their PortCos.
Using Integrum ESG’s innovative Direct Entry Model, any GP can easily collect the data needed from their PortCos to submit to the EDCI.
Just send a link to your PortCo - when they have submitted the data, you can see it in the ‘EDCI’ tab on our Dashboard.
All mandatory 11 metrics will be listed and any scores will be colour coded to alert you to any data point which may require your attention.
You can then export all of this information and send it directly to the EDCI.
𝗧𝗵𝗶𝘀 𝗮𝗿𝘁𝗶𝗰𝗹𝗲 𝘄𝗮𝘀 𝘄𝗿𝗶𝘁𝘁𝗲𝗻 𝗯𝘆 𝗜𝗻𝘁𝗲𝗴𝗿𝘂𝗺 𝗘𝗦𝗚 𝗮𝗻𝗮𝗹𝘆𝘀𝘁 𝗛𝗮𝘇𝗲𝗹 𝗖𝗿𝗮𝗻𝗺𝗲𝗿.
Carbon offsetting has been a hot topic in sustainability discussion circles for years and is viewed by many as a vital, if not the sole, option for some companies meeting their net-zero targets. Unless they plan on a complete product shift, Oil and Gas companies will almost entirely rely on offsetting. But how effective is it, and is it our only path forward?
Carbon offsetting is a process of compensating CO2 emissions by investing in external initiatives that actively reduce or remove GHG emissions. In practice, this looks like companies investing in reforestation or renewable energy projects, or simply buying trade-able carbon credits.
The calculated negative emissions associated with these projects (e.g. the carbon captured by newly planted trees) is presented as negating the positive carbon emissions resulting from a company’s business activities.
While offsetting projects can create genuine sustainable outcomes, they are not without criticism. They are seen by many as an attractive quick fix to achieve a clean conscience and present an illusion of sustainable practices to consumers and investors.
Disney, Shell and Gucci have all been caught up in recent backlash following a Guardian investigation into the leading carbon offsets certifier, Verra. The research concluded that more than 90% of their rainforest offset credits were worthless “phantom credits” failing to make “genuine” carbon reductions. Ultimately, it opens all Verra users up to greenwashing allegations.
At Integrum ESG, we follow guidance from the GHG Protocol and do not include Carbon offset figures when evaluating a company’s carbon footprint or when we compare their performance to their sector peers. We do this to effectively communicate the real climate change and reputational risk associated with these emissions and potential carbon inefficiencies in their business activities. Not only that, but climate commentators predict legal scrutiny and regulation to hit the $2bn voluntary carbon market in the near future.
Newly coined carbon ‘insetting’ challenges a reliance on offsetting. It advocates a proactive approach to tackling carbon emissions within a company’s supply chain. Ultimately, it aims to avoid producing emissions at the source rather than being forced to clean them up.
While it is a new buzzword, it’s not a new concept and many companies have already embraced ‘insetting’ initiatives. Examples we’ve found at Integrum ESG include Nestle’s commitment to sustainable farming practises resulting in improvements in biodiversity while reducing water consumption and GHG emissions.
Decarbonisation of a company’s supply chain is clearly the more demanding path to net-zero but it is overwhelmingly the preferred course of action.
Ultimately, carbon offsets should be used as a supplement to cross the net-zero finish line rather than the instrument we rely on to take us the whole way.
𝗘𝗦𝗚 𝗥𝗲𝗱 𝗦𝗽𝗶𝗸𝗲𝘀 📈
𝗚𝗼𝗼𝗴𝗹𝗲 𝘀𝘂𝘀𝗽𝗲𝗻𝗱𝘀 𝗣𝗶𝗻𝗱𝘂𝗼𝗱𝘂𝗼 𝘀𝗵𝗼𝗽𝗽𝗶𝗻𝗴 𝗮𝗽𝗽
𝗪𝗵𝗮𝘁 𝗱𝗶𝗱 𝘄𝗲 𝘀𝗲𝗲?
Our proprietary Real-Time ESG tracker picked up a significant negative red spike for Pinduoduo(PDD), which has continued to rise throughout the day.
Our systems immediately sent out an alert to our clients with Pinduoduo in their portfolio.
𝗪𝗵𝗮𝘁 𝗱𝗶𝗱 𝘄𝗲 𝗹𝗲𝗮𝗿𝗻?
Google has suspended Pinduoduo, one of China’s most popular e-commerce platforms, from its Play Store.
It has been suggested that versions of the app were found to include malware, exploiting zero-day exploits to hack users.
While this accusation has been rejected by a spokesperson of the Chinese company, the app has been suspended from the Play Store while an investigation continues and users of the app have been warned and prompted to uninstall.
𝗧𝗵𝗶𝘀 𝗮𝗿𝘁𝗶𝗰𝗹𝗲 𝘄𝗮𝘀 𝘄𝗿𝗶𝘁𝘁𝗲𝗻 𝗯𝘆 𝗜𝗻𝘁𝗲𝗴𝗿𝘂𝗺 𝗘𝗦𝗚 𝗮𝗻𝗮𝗹𝘆𝘀𝘁 𝗞𝗶𝘁 𝗠𝗮𝗿𝗸𝘀.
Signed into law in August 2022, the Inflation Reduction Act (IRA) has been hailed as “the most significant climate legislation in U.S. history” according to the US Environmental Protection Agency (https://www.epa.gov/green-power-markets/inflation-reduction-act).
The main intention of the IRA is to catalyse investment in clean energy: the act itself includes $370b of energy-related spending; two of the main beneficiaries of this will be clean energy and electric vehicle (EV) companies.
The funds are to be delivered through tax incentives, grants, and loan guarantees. According to McKinsey, US solar, wind, heat pumps and EV industry all stand to gain from production and investment tax credits of $30 billion for manufacturing (https://www.mckinsey.com/industries/public-and-social-sector/our-insights/the-inflation-reduction-act-heres-whats-in-it).
We looked into 4 companies that are starting to benefit from the IRA:
𝗧𝗲𝘀𝗹𝗮 - On 22nd February, Tesla announced a shift in cell production from Germany to the US after considering incentives available through the IRA, making it one of the first firms to declare a strategy shift prompted by the law. [1]
𝗠𝗲𝗿𝗰𝗲𝗱𝗲𝘀-𝗕𝗲𝗻𝘇 𝗚𝗿𝗼𝘂𝗽 - Mercedes are now in the process of building 10,000 fast-charging points in North America from 2023, targeting 2,500 charging points at 400 locations across most U.S. states and Canada by 2027. [2]
𝗟𝗶𝗻𝗱𝗲 - According to a recent Reuters report, Linde has estimated the total investment opportunity for the company in the United States alone could exceed $30 billion over the next decade. [3]
𝗙𝗶𝗿𝘀𝘁 𝗦𝗼𝗹𝗮𝗿 - The company has recently announced a big expansion, planning to invest up to $1.2 billion in scaling production of American-made photovoltaic (PV) solar modules. The investment is forecast to expand the company’s ability to produce American-made solar modules for the US solar market to over 10 gigawatts (GW) by 2025. [4]
𝗧𝗵𝗲 𝗿𝗲𝗮𝗰𝘁𝗶𝗼𝗻 𝗳𝗿𝗼𝗺 𝘁𝗵𝗲 𝗘𝗨 𝗮𝗰𝗿𝗼𝘀𝘀 𝘁𝗵𝗲 𝗽𝗼𝗻𝗱 𝗵𝗮𝘀 𝗯𝗲𝗲𝗻 𝗹𝗲𝘀𝘀 𝗲𝗻𝘁𝗵𝘂𝘀𝗶𝗮𝘀𝘁𝗶𝗰.
European officials have complained that the IRA; which – amongst other things - limits tax credits to EVs assembled in the United States, and violates U.S. commitments not to subsidise domestic industries or discriminate against foreign ones.
There are genuine fears that it could lure businesses away from the bloc with generous tax breaks - and there is no smoke without fire.
The CEO of Enel in December publicly claimed the IRA is more efficient than EU aid to support domestic production of energy sector components.
The response by the European Commission has been to unveil its Green Deal Industrial plan, signifying a potential relaxation of state aid towards clean tech, although this is struggling to get ubiquitous support among all member states. The EU has warned against a subsidy race but has welcomed the commission’s response to the IRA.
This is a post made by our CEO Shai Hill on LinkedIn on 10th March 2023.
The large legacy ESG ratings brands use a vast amount of estimated data.
That's how they are able to cover >10,000 companies, including emerging market companies that don't actually publish any ESG data.
There are 3 problems here:
- 𝗧𝗵𝗲𝘆 𝗱𝗼𝗻'𝘁 𝗺𝗮𝗸𝗲 𝗰𝗹𝗲𝗮𝗿 𝘄𝗵𝗮𝘁 𝗰𝗼𝗺𝗽𝗮𝗻𝘆 𝗱𝗮𝘁𝗮 𝗶𝘀 𝗮𝗰𝘁𝘂𝗮𝗹 𝗮𝗻𝗱 𝘄𝗵𝗮𝘁 𝗶𝘀 𝗲𝘀𝘁𝗶𝗺𝗮𝘁𝗲𝗱.
Depending on your subscription, you can sometimes click through to a CO2 emissions number, but you won't know whether it is an actual value disclosed by the company, or a value estimated by that ratings firm.
- 𝗧𝗵𝗲 𝘄𝗼𝗿𝗱 '𝗲𝘀𝘁𝗶𝗺𝗮𝘁𝗲𝗱' 𝘀𝘂𝗴𝗴𝗲𝘀𝘁𝘀 𝗮𝗻 𝗮𝗻𝗮𝗹𝘆𝘀𝘁 𝗺𝗶𝗴𝗵𝘁 𝗵𝗮𝘃𝗲 𝘀𝘁𝘂𝗱𝗶𝗲𝗱 𝘁𝗵𝗮𝘁 𝗰𝗼𝗺𝗽𝗮𝗻𝘆 𝗮𝗻𝗱 𝗶𝘁𝘀 𝗶𝗻𝗱𝘂𝘀𝘁𝗿𝘆 𝗮𝗻𝗱 𝗺𝗮𝗱𝗲 𝗮𝗻 𝗶𝗻𝗳𝗼𝗿𝗺𝗲𝗱 𝗰𝗼𝗺𝗽𝗮𝗻𝘆-𝘀𝗽𝗲𝗰𝗶𝗳𝗶𝗰 𝗲𝘀𝘁𝗶𝗺𝗮𝘁𝗲.
In reality, although their precise methodology is typically opaque, the estimated value is just an average, calculated from that company's regional and sectoral peer group. That's why we call it a 'guesstimate'.
As I warn investors, it's like hiring an analyst after you were reassured that they got 70% in their final mathematics exam. You then learn that actually, they never showed up for that exam and this score was in fact a class average.
You can surely appreciate that if they had sat the exam, their score might have been very different from 70%.
3. 𝗔 𝘀𝗲𝗿𝗶𝗼𝘂𝘀 𝗽𝘂𝘀𝗵𝗯𝗮𝗰𝗸 𝗺𝗶𝗴𝗵𝘁 𝗯𝗲 𝗯𝗲𝗴𝗶𝗻𝗻𝗶𝗻𝗴 𝗳𝗿𝗼𝗺 𝗮𝘀𝘀𝗲𝘁 𝗼𝘄𝗻𝗲𝗿𝘀.
These are the institutions who ultimately own the capital that asset management firms invest (on their behalf).
Many asset owners trust the large legacy brands in ESG ratings; in fact some demand that their asset managers use one of them.
But many never realised how many of the 'reassuring' grades they review each quarter are based on guesstimated data.
Within the UK, some asset owners (public pension fund trustees) are even receiving advice that relying on estimated ESG data might constitute a breach of fiduciary duty.
What do we think?
We only use company-disclosed data behind any fundamental analysis we do - and if the company hasn't disclosed data that a recognised framework like the SASB Standards would expect to be disclosed, we make that clear and mark the company down for it.
Many of you might disagree that this is the best approach. But if you are going to use estimated data - you should at least know it's estimated data.
𝗕𝘂𝘁 𝘄𝗵𝗮𝘁 𝗱𝗼 𝘆𝗼𝘂 𝘁𝗵𝗶𝗻𝗸? When reviewing ESG data and scores for a company, do you see estimated ESG data as necessary gap filling?
Scope 3 emissions make up a large portion of total emissions, yet are under-reported.
For context, approximately 85% of the largest 2,000 companies we cover disclose their GHG emissions, but of these companies only around 60% disclose a breakdown which also includes scope 3.
Even when reported, there are issues with how complete the scope 3 disclosure is, with some companies only disclosing on a few of the 15 GHG protocol categories.
Many LPs and investors doubt the value of scope 3, and the two main criticisms arose during the ‘27 years to Net Zero, are we on track?’ panel at the PEI Responsible Investment Forum last week:
(1) Scope 3 calculations are crude estimates at best – there is no such thing as measured scope 3.
(2) The double, triple, quadruple accounting problem at the fund level. The example given at the conference was a good one; jet fuel emissions.
These could be counted in the scope 1 of the airline operating the flight, the scope 3 of any company whose employees are taking the flight for business, or the scope 3 of the company who refined the jet fuel.
The SEC recently signalled they were scaling back their ambitious disclosure requirements on scope 3 [1], however some disclosure will be required under the new IFRS S2 standards [2]. So, there is mixed opinion from standard setters/regulators.
Scope 4 (measuring avoided emissions) [3] is of growing interest to LPs who take climate investing very seriously; climate funds should invest in companies with technologies/approaches that will reduce global emissions significantly, with the acknowledgement that those companies are often in ‘unattractive’ industries like Steel, or Cement.
Calculating their Scope 4 will reveal their positive impact - but again, estimations will play a large role in their quantification.
Read our Head of Research Hannah Bennett's thoughts here.
Effective today, Integrum ESG’s industry-leading data, scoring, and benchmarking is integrating with the preeminent ESG advisory services of Malk Partners.
More and more, top-tier private market clients tell us they want ESG data and analysis that is accurate, framework-aligned, and comparable. The partnership will deliver exactly that, through a software-and-services pairing aimed at supercharging the ESG performance of portfolio companies.
“We are very excited to be working with Malk, which has been a first mover and leader in the ESG advisory space since its founding in 2009,” said Shai Hill, CEO and Founder of Integrum ESG. “By combining Malk’s preeminent advisory services with our industry-leading repository of public and private company ESG data, we can become even more valuable to our private market clients.”
“Our clients have been very clear. They want the best ESG data available – by which they mean, ESG data that is seamlessly and accurately captured, intuitively displayed, scored in a customizable way, benchmarked against industry peers, and consistent with widely-respected ESG frameworks. In Integrum ESG, we have found the innovative partner that best aligns to our clients’ needs,” said Max Hong, CEO of Malk Partners.
Above all else, client satisfaction is our highest priority, and we are excited about the ways Malk’s field-leading advisory services will complement Integrum ESG’s unmatched data capabilities.
We now look forward to serving top-tier private market investors together.
Please note these are the 12 largest positions only - you can see all 100 holdings by either filling in the form HERE or by requesting the full list via contact@integrumesg.com.
We recently created a post on LinkedIn explaining how regulators in the EU, UK and US are investigating ESG funds as there have been growing concerns that asset managers are promising more than they can deliver in an effort to sell their products.
There are fears that to meet the growing demand for ESG products many asset managers have simply rebranded their existing products rather than trying to create new ones, which has created concerns around greenwashing.
A recent analysis by PwC showed that of 1,061 Article 9 funds -- whereby a product needs to have sustainability as its “objective” -- showed that only 286 were new. The rest were reclassifications of existing funds.
A probe of Article 9 products by Swedish authorities last month found “many cases” in which managers failed to provide necessary information, and as a result the Stockholm based regulator has warned that it will act to stamp out false ESG claims.
Furthermore - the EC has recently announced guidelines suggesting that the hurdle for an Art 9 fund should be 100% which has prompted firms like Amundi and Blackrock to remove Article 9 labels from some of its funds.
This has prompted the team here at Integrum ESG to use our 'Screener Tool' to create an Article 9 fund where every company meets the 12 specific sustainability objectives that a company must support if it is to be compatible with an Article 9.
We are happy to have been recognised as the "Best Global AI-Powered ESG Data Provider" by Corporate Vision Magazine in their annual Artificial Intelligence Awards.
This recognises the incredible work done by the Integrum ESG Machine Learning team.
Their contribution cannot be understated - creating and refining our cutting edge models so that they are able to capture, verify and display granular and relevant ESG data with unrivalled rapidity.
NOTE: This table has been updated as of 29 September 2022, following the news of easyJet switching from a strategy of carbon offsetting to emission reductions.
Below is a list of the top 9 airline companies with the biggest difference between their Awareness Score and their Performance Score - i.e, they have policies and targets in place but they are still the worst performing airlines relative to their peers in the airline industry in terms of CO2e emissions.
The below table shows the countries which are worst at managing risks from climate change.
The Climate Change Risk metric includes two sub-metrics:
1. Vulnerability vs readiness for a changing climate whichlooks at a country's propensity to be impacted by climate change hazards vs its ability to make effective use of investments for adaptation.
2. Demographic Pressures which considers pressures upon the state deriving from the population itself or the environment around (including pressures stemming from extreme weather events).
This metric is scored from 0-4 with 4 being the highest score awarded.
The below table shows the companies within the Chemical sector that do not have a policy in place to protect the environment.
The table below shows, from highest to lowest, the top 10 companies which have seen the largest year on year increase of CO2 emissions.
Question related to Regulation (EU) 2019/2088 of the European Parliament (Sustainable Finance Disclosure Regulation 2019/2088)
Published by the European Commission 14/07/2021:
The “comply or explain mechanism”
The underlying objective of Article 4 of Regulation 2019/2088 is to encourage financial market participants to pursue more sustainable investment strategies in terms of reducing negative externalities on sustainability caused by their investments. The compliance with disclosure requirements under Article 4 should incentivise the interest in investing in activities that do not harm environment or social justice, curb greenhouse gas emissions of their investments, stimulate investee companies to transition away from unsustainable activities and improve their environmental impacts or and even induce portfolio adjustments and divest from investments in activities that are harmful to sustainability. Article 4 also encourages financial advisers to pay more attention to how the consideration of negative externalities is integrated in their investment or insurance advice.
This is why the “comply or explain mechanism” under Article 4(1) of Regulation 2019/2088 distinguishes between ‘principal adverse impacts’ and ‘adverse impacts’.
Whilst the “comply mechanism” under point (a) of paragraph 1 encompasses the consideration of principal adverse impacts of investment decisions, financial market participants that decide not to apply the “comply mechanism”, must under point (b) of that paragraph that establishes “explain mechanism”, provide clear reasons for why they do not consider ‘adverse impacts’ of investment decisions on sustainability factors. Under point (b), by way of example, financial market participants must provide clear reasons for why they do not consider degradation of the environment or social injustice caused by their investments.
The aim of Article 4(3) and (4) of Regulation 2019/2088 is to introduce a more stringent “disclosure mechanism” and reduce a hypothetical incidence of application of “explain mechanism”.
New regulation comes into force in January 2023, called “SFDR” (Sustainable Finance Disclosure Regulation) - setting out rules for asset managers to classify and report on sustainability and ESG factors in investments.
This regulation applies to all investment managers and advisors (a) in the EU, (b) should they have EU-based shareholders, and/or (c) if they are marketing within the EU.
Moreover, the FCA regulator in the UK opened a consultation on its own version, called “SDR”, in November 2021. So even if you plan to market your fund in the UK, and not the EU, you are going to have to meet the requirements.
We have summarised how these new rules could apply to YOU and what steps you should take to best prepare yourself - in a comprehensive but digestible guide below.
Below is a list of the top 10 companies (with remuneration reports) with the largest 'limit on long-term bonuses as a percentage of base salary (%) ' - i.e. the potential size of a CEO bonus ~~can be~~ in comparison to their salary.
The universe is companies that disclose salary and bonus % AND have a remuneration report showing the numbers
The companies not on this list may have larger bonus sizes in absolute values, this table focuses on potential bonus as % of salary
Of the 314 companies we have under full coverage in the sub-sectors of: Commercial Banks, Asset Management & Custody Activities, Insurance, Investment Banking & Brokerage - i.e. the financial subsectors where "Integrating social & environmental concerns into planning & design" is material we have found that the below 9 companies do not clearly disclose sufficient policies for the metric "Integrating social & environmental concerns into planning & design". In the case of these sub-sectors, this could refer to integrating ESG or sustainable finance strategies into their products, for example.
The below list shows the ESG scores of the top 10 and worst 10 extractives & minerals processing companies.
The below table shows the companies within the processed food sub-sector and their awareness scores for auditing their suppliers' labour code of conduct. Most score a 3 out of a possible highest score of 4 as our scoring logic gives a score of 3 for companies with a policy in place for conducting labour audits of suppliers and for disclosing numbers, but does not give detailed percentages or set itself a target.
Only one company has scored a maximum score of 4 as they have also set themselves a target for conducting labour audits of suppliers.
The table below ranks each sub-sector from highest to lowest on how they manage labour relations.
Chile have issued a new USD$2bn 20-year sustainability-linked bond (SLB), the first Sovereign to do so. Unlike green bonds, the proceeds of SLBs are not segregated for use towards specific green or sustainable projects, but instead the payout to investors depends on whether the issuer meets agreed-upon KPIs. The KPIs attached to Chile's SLB are related to their annual greenhouse gas emissions and renewable energy generation.
On the Integrum ESG Sovereign Dashboard, compared to its Latin America & Caribbean peers, Chile ranks no1 on overall ESG and sits within the top 3 on Social and Governance. However, the country is 7th on Environmental issues, due to factors such as water stress, waste and % of power coming from renewable sources
Last week the influential ratings firm Morningstar stripped its 'Sustainable' label off c1,600 funds (1 in 4), and said there will be more downgrades to come.
A huge number of these funds had already declared themselves to be Article 8 (an SFDR categorisation that means ESG has been integrated into the investment process). Morningstar however has criticised these funds that “place themselves into Article 8…say they consider ESG factors in the investment process…but don’t integrate them in a determinative way for their investment selection”.
To qualify as Article 8, a fund must not just establish and declare certain ESG policies, it must assess each holding in the fund according to 14 ‘Principal Adverse Indicators’. It's a detailed process, and the vast majority of self-declared Article 8 funds are not doing this at all.
Morningstar is just a ratings firm - but there are 2 far more concerning developments:
Regulators have had enough of these exaggerated claims.
The EU markets watchdog, ESMA, said it will create a legal definition of “greenwashing” and classify it as a type of mis-selling. When a financial regulator creates a new definition, it is invariably because they intend to weaponize it.
The FCA said back in July that many ESG funds “often contain claims that do not bear scrutiny”. This was perhaps an early warning, and penalties will follow.
The SEC is investigating DWS for possible false ESG claims on some of its funds. This shows that even in markets where sustainability is not being promoted, nor is it clearly defined, regulators are already willing to pursue unsubstantiated ESG claims as a form of mis-selling.
Investors may start to sue.
- Consider this warning from the partnership at Baker McKenzie in Los Angeles, that if people have lost money, “you’ll see plaintiffs step in. You’re hearing the rumblings. It’s not happened that much yet. But it will.”
- Simmons & Simmons in London cites cases brought by shareholders against operating companies, on ESG grounds, and the FT quotes its partner Robert Allen’s warning “you can definitely see how (a case against fund managers) can follow on”.
- North Wall Capital, which funds legal class actions, offers the alarming quote “it is certainly coming”.
What might this mean? It means that a $10bn fund, that has underperformed its benchmark by 2%, and whose advertised claims that it is ‘sustainable’ are later deemed to be misleading, could face a $200m class action claim from its investors.
Might a clear legal standard of ‘sustainable’ emerge? The law firm Bates Wells believes that the 2015 Paris Climate Accord will be the legal standard – and the recent court ruling against Shell in The Hague set this as a legal precedent. How many investment funds are using a tool like THIS to evidence that their investments are consistent with a global warming scenario ‘well below 2 degrees’ (which is the objective of the Paris Climate Accord)?
So, ESG regulatory risks and legal liabilities may be mounting for fund management firms. The easiest way for any fund management firm to mitigate these risks is to state clearly that environmental and social objectives are not promoted by the fund, nor is ESG analysis systematically integrated into the investment process. Then all these mis-selling risks fall away.
It just seems that, fearful of losing investors, very few fund management firms want to do this.
The alternative is for these firms to build, or subscribe to, data tools that will map their funds to the Paris Accord, assess them against the 14 SFDR Adverse Indicators, and enable them to explain the key ESG risks in every existing investment.
How can Integrum ESG help meet these challenges?
- Fund managers are often relying on ESG ratings they cannot understand. When a regulator or investor asks "why are you comfortable with the ESG performance of this company?" they will struggle to answer, because the ESG score that has reassured them is a set of black boxes. The Integrum ESG dashboard presents glass boxes, with the reason for every score, for every metric, and the underlying data that explains and supports the ESG rating.
- Applying a Cambridge University model, the Integrum ESG dashboard calculates the extent to which your fund is aligned to the Paris Climate Accord - and surfaces the data that supports this calculation, company by company.
- The latest Integrum ESG dashboard feature, soon to be deployed, will provide the evidence of why, or why not, your fund can be classified as Article 8. It will map and assess the alignment of every uploaded fund to the SFDR Principal Adverse Indicators, and the EU Taxonomy Objectives.
Do you want to learn more about how Integrum ESG can help you meet these challenges? If so, CLICK HERE.
Recently we posted a poll on LinkedIn (which you can see HERE) which discussed how the plant-based meat market will develop and the main reasons why there has been a drop in the sales of plant-based meat in 2021.
One of the main reasons for this drop in sales is that consumers have now started to realise that many plant-based meats are highly processed, additive-laden and not very healthy.
This has prompted the team here at Integrum ESG to take a look at Processed Food companies that are best at managing health risks to customers.
See below for a list of the 14 companies that rank highest out of the highest possible score of 4.
Below is a list of countries that are best at managing the risks associated with climate change. Each scores 3.75 out of a maximum score of 4
The Climate change risk metric has 2 sub-metrics. The qualitative "Vulnerability vs readiness for a changing climate", and the quantitative "Demographic pressures".
The first sub-metric in particular (vulnerability vs readiness) assesses how the country is managing the risk from climate change, so for example, seeing the small island state of Mauritius on this list might be surprising, but they are deemed to have a high readiness to adapt to risks they are facing from climate change.
Last week The World Economic Forum released 'The Global Risks Report 2022', and of their 10 most severe risks on a global scale over the next 10 years, 5 were environmental risks.
These 5 risks are climate action failure, extreme weather, biodiversity loss, human environmental damage and natural resource crises.
The list below is the top 20 companies who score highest on managing business risk from climate change.
The below tables shows which 14 automobile companies score highest on the governance metric 'Risk Management'.
The list below shows the 12 companies with the highest Governance score. Integrum ESG licences the Minerva framework to assess corporate governance. Minerva are stewardship experts and their framework assesses corporate governance using 9 metrics and 39 sub-metrics.
In the table below, we show the 5 countries which rank highest and lowest on the Freedom of the Press Index. This 2021 data is an annual ranking of countries (the greater the index score, the worse the situation is regarding press freedom) published by Reporters Without Borders and is one of the 31 datapoints we track for every Sovereign in our ESG database.
In the table below, we show the 5 countries where unemployment is lowest and highest. This 2020 data is sourced from the International Labour Organization, and is one of the 31 datapoints we track for every Sovereign in our ESG database.
Below is a list of the companies with the sharpest deterioration in ESG sentiment from the past seven days. Our A.I. powered sentiment tracker trawls through ~850,000 global news sources, in 92 languages, and assigns a neutral, negative or positive sentiment score to ESG relevant comments.
The companies below are experiencing an acute deterioration in ESG sentiment for different specific reasons, such as ransomware attacks, undisclosed CEO perks and even a US Senator calling for an investigation into price fixing in their sector.
With the recent 'rise in child obesity' article published by the BBC (data taken from the NHS), we have highlighted the UK Food & Beverage companies that are most focused on managing health risks to customers. You might be surprised by some of the names below.
The UK companies below (with a score of 3) state that their procedures related to managing customer health risks either align with a third-party standard, or are audited. The companies with a score of 4 also have a target in place, for supporting customer health.
How do companies improve their ESG rating? It might be by reducing carbon emissions, it might be by adopting new employee policies. But it is very often achieved by better disclosure on ESG issues.
Below is a list of the top improvers when it comes to (uncustomised) ESG score improvements.
We are now seeing a clear trend of improving ESG disclosure in the US – and thus it is no surprise that all but 2 of this list are US companies.
Using the SASB framework, we assess certain sectors for employee turnover - as an indicator of how good a company's labour practices are.
Rather than focus on the negative, we thought we would list below the 10 companies with the lowest staff turnover:
The list below shows the 10 companies who pay their accountants the most, relative to the cost of auditing from the accountants.
For example, Volkswagen paid EY €19m in audit fees, but it paid EY €33m in non-audit fees (€21m for tax advisory, €7m for advice on new legal standards, and €5m for 'other assurance services').
The Top 10 companies with the biggest YoY GHG Emission reductions
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