๐ง๐ต๐ถ๐ ๐ฎ๐ฟ๐๐ถ๐ฐ๐น๐ฒ ๐๐ฎ๐ ๐๐ฟ๐ถ๐๐๐ฒ๐ป ๐ฏ๐ ๐๐ป๐๐ฒ๐ด๐ฟ๐๐บ ๐๐ฆ๐ ๐๐ฒ๐ฎ๐ฑ ๐ผ๐ณ ๐ฅ๐ฒ๐๐ฒ๐ฎ๐ฟ๐ฐ๐ต ๐๐ฎ๐ป๐ป๐ฎ๐ต ๐๐ฒ๐ป๐ป๐ฒ๐๐.
The SEC has charged global asset manager Invesco Advisers Inc. for misleading claims about its ESG-related investments.
Y๏ปฟou can read the SEC's official findings here.
W๏ปฟhat 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% โ 94% of its parent companyโs assets under management were โESG integratedโ.
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.โ
W๏ปฟhat 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 โ 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.
๐ง๐ต๐ถ๐ ๐ฎ๐ฟ๐๐ถ๐ฐ๐น๐ฒ ๐๐ฎ๐ ๐๐ฟ๐ถ๐๐๐ฒ๐ป ๐ฏ๐ ๐๐ป๐๐ฒ๐ด๐ฟ๐๐บ ๐๐ฆ๐ ๐ฅ๐ฒ๐๐ฒ๐ฎ๐ฟ๐ฐ๐ต ๐๐ป๐ฎ๐น๐๐๐ ๐๐น๐ถ๐ฐ๐ถ๐ฎ ๐๐ฎ๐ฝ๐น๐ฎ๐ป.
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 โImpact Metricsโ that evaluates companiesโ 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:
๐ฃ๏ธ Gorman's tenure at Morgan Stanley
๐ Disney's current ESG standing
๐ ๏ธ 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 ยฃ820 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:
โ 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.
โ 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 tCOโe) 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.
โ Reputational Risk
Bob Iger's reign as CEO has been peppered with controversies; be that Elon Musk describing the companyโs diversity programs as being โenforced by Disneyโs DEI Gestapoโ, 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, McDonaldโs 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.
๐ง๐ต๐ถ๐ ๐ฎ๐ฟ๐๐ถ๐ฐ๐น๐ฒ ๐๐ฎ๐ ๐๐ฟ๐ถ๐๐๐ฒ๐ป ๐ฏ๐ ๐๐ป๐๐ฒ๐ด๐ฟ๐๐บ ๐๐ฆ๐ ๐ฅ๐ฒ๐๐ฒ๐ฎ๐ฟ๐ฐ๐ต ๐๐ป๐ฎ๐น๐๐๐ ๐๐ถ๐ ๐ ๐ฎ๐ฟ๐ธ๐.
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 โsustainableโ choice of pint?
The judgment process
An important caveat here โ 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:
๐ฅ Heineken N.V. [HEIA.AS] โ B grade (ESG Score of 2.36)
๐ฅ Molson Coors [NYSE:TAP] โ A grade (ESG Score of 2.80)
๐ฅ 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:
๐ข 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 Molsonโs, and;
๐ 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 Diageoโs key assets, with โthe brand delivering 15% organic net sales growth, double-digit growth for seven consecutive halvesโ (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 itโs 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.
๐ง๐ต๐ถ๐ ๐ฎ๐ฟ๐๐ถ๐ฐ๐น๐ฒ ๐๐ฎ๐ ๐๐ฟ๐ถ๐๐๐ฒ๐ป ๐ฏ๐ ๐๐ป๐๐ฒ๐ด๐ฟ๐๐บ ๐๐ฆ๐ ๐ฆ๐ฒ๐ป๐ถ๐ผ๐ฟ ๐๐ป๐ฎ๐น๐๐๐ ๐ ๐ผ๐น๐น๐ ๐๐ฟ๐ฎ๐๐ฒ๐ฟ.
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 administrationโs crackdown on monopoly concerns.
The case, flagged by the Integrum ESG real-time tracker, underscores rising concerns about Visaโs 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 metricsโnotably those related to competitive behaviour โis 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 โCompetitive Behaviorโ 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 Visaโs 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."
Visaโs failure to disclose how much was spent on fines or legal defence during that fiscal year reflects a lack of transparency. As a result, theyโve 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.
๐ง๐ต๐ถ๐ ๐ฎ๐ฟ๐๐ถ๐ฐ๐น๐ฒ ๐๐ฎ๐ ๐๐ฟ๐ถ๐๐๐ฒ๐ป ๐ฏ๐ ๐๐ป๐๐ฒ๐ด๐ฟ๐๐บ ๐๐ฆ๐ ๐ฅ๐ฒ๐๐ฒ๐ฎ๐ฟ๐ฐ๐ต ๐๐ป๐ฎ๐น๐๐๐ ๐ก๐ฒ๐ต๐ฎ ๐๐ฎ๐ป๐ฑ๐๐ฎ๐น.
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 ๐
The environmental law firm that filed the lawsuit alleged that the company has made misleading claims regarding its โclimate-smart beefโ, 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 ๐
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 companyโs audit of itsโ 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 ๐
Lastly, our sentiment tracker also picked up a story about Nike, where one of its top investors (Norwayโs 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.
๐ง๐ต๐ถ๐ ๐ฎ๐ฟ๐๐ถ๐ฐ๐น๐ฒ ๐๐ฎ๐ ๐๐ฟ๐ถ๐๐๐ฒ๐ป ๐ฏ๐ ๐๐ป๐๐ฒ๐ด๐ฟ๐๐บ ๐๐ฆ๐ ๐๐ฒ๐ฎ๐ฑ ๐ผ๐ณ ๐ฅ๐ฒ๐๐ฒ๐ฎ๐ฟ๐ฐ๐ต ๐๐ฎ๐ป๐ป๐ฎ๐ต ๐๐ฒ๐ป๐ป๐ฒ๐๐.
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;
๐๏ธ 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.
๐๏ธ Similarly, The Lottery Corporation [TLC:ASX] ย 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.
T๏ปฟo read all of Integrum ESG's latest insights, please follow the link below:
๐ง๐ต๐ฒ ๐ณ๐ผ๐น๐น๐ผ๐๐ถ๐ป๐ด ๐ถ๐ ๐ฎ ๐๐ฟ๐ถ๐๐ฒ-๐๐ฝ ๐ฏ๐ ๐๐ป๐๐ฒ๐ด๐ฟ๐๐บ ๐๐ฆ๐ ๐ฎ๐ป๐ฎ๐น๐๐๐ ๐ ๐ผ๐น๐น๐ ๐๐ฟ๐ฎ๐๐ฒ๐ฟ ๐ฎ๐ณ๐๐ฒ๐ฟ ๐ต๐ฎ๐๐ถ๐ป๐ด ๐ฎ๐๐๐ฒ๐ป๐ฑ๐ฒ๐ฑ ๐ฃ๐ผ๐ฟ๐๐ณ๐ผ๐น๐ถ๐ผ ๐๐ป๐๐๐ถ๐๐๐๐ถ๐ผ๐ป๐ฎ๐นโ๐ ๐๐ฆ๐ ๐๐น๐๐ฏ ๐๐ผ๐ป๐ณ๐ฒ๐ฟ๐ฒ๐ป๐ฐ๐ฒ ๐ผ๐ป ๐ญ๐ฏ ๐ฆ๐ฒ๐ฝ๐๐ฒ๐บ๐ฏ๐ฒ๐ฟ ๐ฎ๐ฌ๐ฎ๐ฏ. ๐ง๐ต๐ถ๐ ๐๐ฎ๐ ๐ฎ๐ป ๐ฒ๐๐ฒ๐ป๐ ๐ฎ๐๐๐ฒ๐ป๐ฑ๐ฒ๐ฑ ๐ฏ๐ ๐บ๐ฎ๐ป๐ ๐น๐ฒ๐ฎ๐ฑ๐ถ๐ป๐ด ๐ณ๐ถ๐ด๐๐ฟ๐ฒ๐ ๐ถ๐ป ๐๐ต๐ฒ ๐จ๐ & ๐๐จ ๐๐๐๐ฒ๐ ๐ข๐๐ป๐ฒ๐ฟ ๐ฐ๐ผ๐บ๐บ๐๐ป๐ถ๐๐, ๐๐ต๐ฒ๐ฟ๐ฒ ๐ถ๐ป๐๐๐ถ๐๐๐๐ถ๐ผ๐ป๐ฎ๐น ๐ถ๐ป๐๐ฒ๐๐๐ผ๐ฟ๐ ๐ฒ๐ป๐ด๐ฎ๐ด๐ฒ๐ฑ ๐ผ๐ป ๐ต๐ผ๐ ๐๐ผ ๐ฟ๐ฒ๐ฑ๐๐ฐ๐ฒ ๐๐ต๐ฒ ๐๐ผ๐ฟ๐น๐ฑโ๐ ๐ฟ๐ฒ๐น๐ถ๐ฎ๐ป๐ฐ๐ฒ ๐ผ๐ป ๐ณ๐ผ๐๐๐ถ๐น ๐ณ๐๐ฒ๐น๐, ๐ฝ๐ฟ๐ผ๐๐ฒ๐ฐ๐ ๐๐ต๐ฒ ๐ฒ๐ฐ๐ผ๐๐๐๐๐ฒ๐บ, ๐ฎ๐ป๐ฑ ๐ฝ๐ฟ๐ผ๐บ๐ผ๐๐ฒ ๐ด๐ฟ๐ฒ๐ฎ๐๐ฒ๐ฟ ๐ฒ๐พ๐๐ฎ๐น๐ถ๐๐.
โ๐๐ค๐ฌ ๐๐๐ฃ ๐ฅ๐๐ค๐ฅ๐ก๐ ๐ฉ๐ง๐ช๐จ๐ฉ ๐๐๐ ๐ง๐๐ฉ๐๐ฃ๐๐จ ๐ฉ๐๐๐ฎ ๐๐ค๐ฃโ๐ฉ ๐ช๐ฃ๐๐๐ง๐จ๐ฉ๐๐ฃ๐?โ
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.ย
One of the many questions he raised was why are people taking ESG ratingsย which they donโt 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. ย
๐๐๐ฉ ๐ฏ๐๐ง๐ค, ๐ฝ๐๐ค๐๐๐ซ๐๐ง๐จ๐๐ฉ๐ฎ & ๐ฉ๐๐ โ๐โ ๐๐ฃ ๐๐๐
The other three panel discussions also provided many invaluable insights, including but not limited to:
โณ 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.
โด 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.
โต While in environmental issues we can think about โoffsetsโ 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 companyโs tier 2 supplier workforce. ย
๐ผ๐๐ฉ๐๐ค๐ฃ ๐ฅ๐ค๐๐ฃ๐ฉ๐จ ๐๐ค๐ง ๐ฉ๐๐ ๐๐ช๐ฉ๐ช๐ง๐
The conference revealed a path forward in ESG investing; transparency, collaboration, and holistic approaches. Imperfect data shouldnโt 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 โ act now!
๐ง๐ต๐ถ๐ ๐ฎ๐ฟ๐๐ถ๐ฐ๐น๐ฒ ๐๐ฎ๐ ๐๐ฟ๐ถ๐๐๐ฒ๐ป ๐ฏ๐ ๐๐ป๐๐ฒ๐ด๐ฟ๐๐บ ๐๐ฆ๐ ๐ฎ๐ป๐ฎ๐น๐๐๐ ๐๐ถ๐ ๐ ๐ฎ๐ฟ๐ธ๐.
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: Bidenโs 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 โliberalโ 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 โradical-left garbage.โ
In March, DeSantis formed an alliance with 18 US states to pushback against the DoLโs new rule allowing ESG-aligned funds in 401(k) plans. Floridaโs 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, itโs likely that greeniums could diminish on US ESG debt, as demand for ESG bonds may decrease significantly.
๐ช๐ต๐ฎ๐ ๐ฑ๐ผ๐ฒ๐ ๐๐ต๐ถ๐ ๐บ๐ฒ๐ฎ๐ป ๐ณ๐ผ๐ฟ ๐๐ฆ๐ ๐ถ๐ป ๐ฎ๐ฌ๐ฎ๐ฐ?ย
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 newย 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.ย
Recently, a lot of these investors seem to say the same thing:
"We do not have the budget for better ESG data right now."ย
The majority of these investment firmsย seem toย accept the idea that implementing good ESG data is costlyย - 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 oftenย opaqueย and their scores are builtย uponย unclear methodologiesย - 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 orย leave themselves vulnerable to 'greenwashing' claims.ย
"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.
๐ญย "Are you really able to offer all of this for so little?"
๐ญย "Is the quality of your data really as good as you say?"
๐ญย "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 anย AI-powered ESG data provider.ย
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 ourย innovative data-centric AI methodologies - this is what makes us stand out from the rest:
โก๏ธย Quality and Accuracy.
Our systems' focus on transparency and 'explainability' means theย ESG scores you see are always up to date and trustworthy - you can export all data we pick upย and verify its quality for yourself.
โก๏ธย 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.ย
โก๏ธย Ability to scale up at a low cost.
Our unique 'Human-in-the-loop' approach effectively blendsย Artificial and Human Intelligence - meaningย that we only need a small team of ESG experts overseeing the rating process of every company.ย
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 - andย we can thenย share these savings with you.
๐ ๐ด๐น๐ผ๐ฏ๐ฎ๐น ๐๐ฒ๐ ๐ผ๐ณ ๐๐ฆ๐ ๐ฑ๐ถ๐๐ฐ๐น๐ผ๐๐๐ฟ๐ฒ ๐๐๐ฎ๐ป๐ฑ๐ฎ๐ฟ๐ฑ๐ ๐ต๐ฎ๐ ๐ฒ๐บ๐ฒ๐ฟ๐ด๐ฒ๐ฑ.ย
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.ย
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.
๐ช๐ต๐ฎ๐ ๐ฑ๐ผ ๐๐ต๐ฒ๐๐ฒ ๐ป๐ฒ๐ ๐๐๐ฅ๐ฆ ๐ฆ๐๐ฎ๐ป๐ฑ๐ฎ๐ฟ๐ฑ๐ ๐น๐ผ๐ผ๐ธ ๐น๐ถ๐ธ๐ฒ?
Well, they are not really new;ย
โก๏ธ 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.ย
โก๏ธ 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 ๐๐ผ๐๐ฎ๐น๐ฒ๐ป๐ฐ๐ฒ (๐๐), ๐๐๐ต๐ถ๐๐ถ๐ป๐ฎ๐ป๐ฐ๐ฒ (๐๐ฅ, ๐๐, ๐ฆ๐ฃ), ๐๐ป๐ฟ๐ฎ๐๐ฒ (๐๐) and ๐๐ป๐๐ฒ๐ด๐ฟ๐๐บ ๐๐ฆ๐ (๐จ๐) 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 ownerย survey, focusing on their attitudes, priorities and decisions being made onย 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:
๐ญ. ๐๐๐ค๐ง๐ฉ-๐ฉ๐๐ง๐ข๐๐จ๐ข ๐๐จ ๐ ๐๐ง๐๐๐๐ ๐ค๐ ๐๐๐๐ช๐๐๐๐ง๐ฎ ๐๐ช๐ฉ๐ฎ.
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.
๐ฎ. ๐๐๐ ๐ฌ๐ค๐ง๐ '๐๐จ๐ฉ๐๐ข๐๐ฉ๐๐' ๐จ๐ช๐๐๐๐จ๐ฉ๐จ ๐๐ฃ ๐๐ฃ๐๐ก๐ฎ๐จ๐ฉ ๐ข๐๐๐๐ฉ ๐๐๐ซ๐ ๐จ๐ฉ๐ช๐๐๐๐ ๐ฉ๐๐๐ฉ ๐๐ค๐ข๐ฅ๐๐ฃ๐ฎ ๐๐ฃ๐ ๐๐ฉ๐จ ๐๐ฃ๐๐ช๐จ๐ฉ๐ง๐ฎ ๐๐ฃ๐ ๐ข๐๐๐ ๐๐ฃ ๐๐ฃ๐๐ค๐ง๐ข๐๐ ๐๐ค๐ข๐ฅ๐๐ฃ๐ฎ-๐จ๐ฅ๐๐๐๐๐๐ ๐๐จ๐ฉ๐๐ข๐๐ฉ๐.
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:
๐ฏ. ๐๐ฉ ๐๐จ ๐ฃ๐ค๐ฉ ๐๐ก๐๐๐ง ๐ฌ๐๐๐ฉ ๐๐ค๐ข๐ฅ๐๐ฃ๐ฎ ๐๐๐ฉ๐ ๐๐จ ๐๐๐๐ฉ๐ช๐๐ก ๐๐ฃ๐ ๐ฌ๐๐๐ฉ ๐๐จ ๐๐จ๐ฉ๐๐ข๐๐ฉ๐๐.
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.
N๏ปฟo 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.
๐ง๐ต๐ถ๐ ๐ฎ๐ฟ๐๐ถ๐ฐ๐น๐ฒ ๐๐ฎ๐ ๐๐ฟ๐ถ๐๐๐ฒ๐ป ๐ฏ๐ ๐๐ป๐๐ฒ๐ด๐ฟ๐๐บ ๐๐ฆ๐ ๐ฎ๐ป๐ฎ๐น๐๐๐ ๐ ๐ผ๐น๐น๐ ๐๐ฟ๐ฎ๐๐ฒ๐ฟ.
Last month, my colleagueย Hazel Cranmerย wrote a post on the issues of companies relying solely on carbon โoffsettingโ to reach decarbonisation goals.ย ย
She argued carbon offsets fail to make genuine carbon reductions, and that we should instead invest in โcarbon insettingโ; avoiding emissions at the source โrather than being forced to clean them upโ.โฏย
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.ย
It has become apparent that this sentiment is widely shared, with both the EU parliament and UKโs advertising watchdog proposing bans last week on adverts making โcarbon neutralโ product claims using offsets. (https://www.theguardian.com/environment/2023/may/15/uk-advertising-watchdog-to-crack-down-on-carbon-offsetting-claims-aoe &โฏโฏhttps://us10.campaign-archive.com/?e=6cd1763d23&u=f89d68518db6e2585b0808206&id=35b50e16fc)โฏ.ย ย
The crackdown comes as no surprise, given the seemingly endless cases of companies being exposed for greenwashing.ย
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 Lufthansaโs recent campaign declaring their green efforts (carbon offsets) were โprotecting the worldโs futureโ.ย
๐๐ผ๐ ๐บ๐ถ๐ด๐ต๐ ๐๐ต๐ฒ๐๐ฒ ๐ฝ๐ฟ๐ผ๐ฝ๐ผ๐๐ฎ๐น๐ ๐ฎ๐ณ๐ณ๐ฒ๐ฐ๐ ๐๐ต๐ฒ ๐๐๐๐๐ฎ๐ถ๐ป๐ฎ๐ฏ๐ถ๐น๐ถ๐๐ ๐น๐ฎ๐ป๐ฑ๐๐ฐ๐ฎ๐ฝ๐ฒ?
I believe we will see two changes:ย
1. More accurate sustainable purchasing decisionsย
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.ย
2. A shift towards carbon โinsettingโย
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.ย
๐๐ ๐๐ต๐ฒ๐ฟ๐ฒ ๐ฎ๐ป๐ ๐๐๐ฒ ๐ณ๐ผ๐ฟ ๐ฐ๐ฎ๐ฟ๐ฏ๐ผ๐ป ๐ผ๐ณ๐ณ๐๐ฒ๐ ๐๐ฐ๐ต๐ฒ๐บ๐ฒ๐ ๐ถ๐ป ๐๐๐๐๐ฎ๐ถ๐ป๐ฎ๐ฏ๐ถ๐น๐ถ๐๐ ๐๐๐ฟ๐ฎ๐๐ฒ๐ด๐ถ๐ฒ๐?
We at Integrum ESG do not include carbon offsets in calculating the carbon footprint of companies (as per GHG Protocol guidelines).ย ย
However, investments in offsetting schemes should not be discouraged entirely. Not only do they contribute to the pool of climate financeย needed to reach international climate goals, but they also demonstrate a companyโs dedication to global climate mitigation beyond their value chain; a policy valued by ESG ratings providers and investors.ย
But what do you think?
๐๐ฆ๐ ๐ฅ๐ฒ๐ฑ ๐ฆ๐ฝ๐ถ๐ธ๐ฒ๐ ๐
๐จ๐ป๐ถ๐ผ๐ป ๐ฑ๐ถ๐๐ฝ๐๐๐ฒ๐, '๐ฃ๐ผ๐๐๐ฎ๐น ๐ฑ๐ฒ๐๐ฒ๐ฟ๐๐' & ๐ฅ๐ฒ๐ด๐๐น๐ฎ๐๐ผ๐ฟ๐ ๐ฎ๐ฐ๐๐ถ๐ผ๐ป
๐ช๐ต๐ฎ๐ ๐ฑ๐ถ๐ฑ ๐๐ฒ ๐๐ฒ๐ฒ?
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.
๐ช๐ต๐ฎ๐ ๐ฑ๐ถ๐ฑ ๐๐ฒ ๐น๐ฒ๐ฎ๐ฟ๐ป?
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.
๐ช๐ต๐ฎ๐ ๐ผ๐๐ฟ ๐ฅ๐ฒ๐ฎ๐น-๐ง๐ถ๐บ๐ฒ ๐๐ฆ๐ ๐ง๐ฟ๐ฎ๐ฐ๐ธ๐ฒ๐ฟ ๐๐ฎ๐
We have summarised the main stories which we captured across wider media and Twitter for you below:
๐๏ธ ๐ง๐๐ฒ๐๐ฑ๐ฎ๐ ๐ต๐๐ต ๐ ๐ฎ๐
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 ๐ป to a low of 244.47. ๐
๐๏ธ ๐ช๐ฒ๐ฑ๐ป๐ฒ๐๐ฑ๐ฎ๐ ๐ญ๐ฌ๐๐ต ๐ ๐ฎ๐
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 ยฃ20m 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 ๐ป to a low of 232.8. ๐
๐๏ธ ๐๐ฟ๐ถ๐ฑ๐ฎ๐ ๐ญ๐ญ๐๐ต ๐ ๐ฎ๐
Reports that Royal Mail reportedly failing to frequently deliver post were causing dozens of areas to become โpostal desertsโ - with some areas receiving letters as little as once a fortnight.
Share price for IDS.L had a high of 236 ๐ป to a low of 229.2. ๐
๐๏ธ ๐ ๐ผ๐ป๐ฑ๐ฎ๐ ๐ญ๐ฑ๐๐ต ๐ ๐ฎ๐
It is widely reported that the UK regulator Ofcom has launched an investigation into Royal Mailโs 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 ๐ป to a low of 224.9. ๐
๐ง๐ต๐ถ๐ ๐ฎ๐ฟ๐๐ถ๐ฐ๐น๐ฒ ๐๐ฎ๐ ๐๐ฟ๐ถ๐๐๐ฒ๐ป ๐ฏ๐ ๐๐ป๐๐ฒ๐ด๐ฟ๐๐บ ๐๐ฆ๐ ๐ฎ๐ป๐ฎ๐น๐๐๐ ๐๐ฎ๐ฐ๐ธ ๐ ๐ผ๐ฟ๐ฝ๐ต๐ฒ๐.
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 whenย 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 โbetter-than-baseline company performanceโ 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 ย
One of the most important governance metrics (with the highest number of sub-metrics captured under this metric byย Integrum ESG) is Remuneration Alignment, which evaluates executive pay alignment with company shareholdersโ interests.ย
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 ownersโ interests, often now called โthe agency problemโ.
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.ย
Will things change?
Ultimately, the responsibility of executive pay and alignment is down to the Remuneration Committee on the board.
Theย U.S. Securities and Exchange Commissionย 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.ย
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.
๐๐ฆ๐ ๐ฅ๐ฒ๐ฑ ๐ฆ๐ฝ๐ถ๐ธ๐ฒ๐ ๐
๐๐๐ข๐, ๐๐ผ๐ป๐๐๐ฒ๐ & "๐ฃ๐ถ๐๐ ๐๐ถ๐๐"
๐ช๐ต๐ฎ๐ ๐ฑ๐ถ๐ฑ ๐๐ฒ ๐๐ฒ๐ฒ?
Our Real-time ESG Tracker picked up a significant negative red spike forย MillerKnollย (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.
๐ช๐ต๐ฎ๐ ๐ฑ๐ถ๐ฑ ๐๐ฒ ๐น๐ฒ๐ฎ๐ฟ๐ป?
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 almostย $1.2 million in bonuses in the previous year,ย as part of a pay package worth nearly $5 million.
These comments had ramifications on public sentiment and their share price.
๐ช๐ต๐ฎ๐ ๐ผ๐๐ฟ ๐ฅ๐ฒ๐ฎ๐น-๐ง๐ถ๐บ๐ฒ ๐๐ฆ๐ ๐ง๐ฟ๐ฎ๐ฐ๐ธ๐ฒ๐ฟ ๐๐ฎ๐ ๐ฉ
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.
๐ง๐ต๐ถ๐ ๐ฎ๐ฟ๐๐ถ๐ฐ๐น๐ฒ ๐๐ฎ๐ ๐๐ฟ๐ถ๐๐๐ฒ๐ป ๐ฏ๐ ๐๐ป๐๐ฒ๐ด๐ฟ๐๐บ ๐๐ฆ๐ ๐๐๐ข ๐ฆ๐ต๐ฎ๐ถ ๐๐ถ๐น๐น.
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.
๐๐ฒ๐ฟ๐ฒ'๐ ๐ฎ ๐๐๐บ๐บ๐ฎ๐ฟ๐ ๐ผ๐ณ ๐๐ต๐ฒ ๐ฑ ๐ธ๐ฒ๐ ๐ฝ๐ผ๐ถ๐ป๐๐ ๐ณ๐ฟ๐ผ๐บ ๐๐ต๐ฒ ๐ญ๐ฑ๐ด-๐ฝ๐ฎ๐ด๐ฒ ๐ฐ๐ผ๐ป๐๐๐น๐๐ฎ๐๐ถ๐ผ๐ป ๐ฝ๐ฎ๐ฝ๐ฒ๐ฟ:
1๏ธโฃ The number of mandatory PAIs (indicators that funds making sustainable investments will have to report to) will be increased from 14 to 18.ย ย
The new 4 are 'Social' indicators, relating to the companies the fund invests in:
๐ฉ Revenue earned in countries which don't co-operate with the EU on tax
๐ฉ Involvement in production of tobacco
๐ฉ Whether the company tries to block trade unions
๐ฉ % of staff earning less than an adequate wage
2๏ธโฃ If the fund has an emissions reduction objective, it must publish quantified details.
3๏ธโฃ More disclosure will be required on a fund's EU Taxonomy alignment (bringing SFDR and the Taxonomy closer together).
4๏ธโฃ 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).ย ย
5๏ธโฃ 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.
๐๐ผ๐ฟ ๐ฎ๐ป ๐๐ฟ๐๐ถ๐ฐ๐น๐ฒ ๐ด ๐ณ๐๐ป๐ฑ, ๐ถ๐ ๐๐ถ๐น๐น ๐ฐ๐ผ๐ป๐๐ฎ๐ถ๐ป ๐ฑ ๐ธ๐ฒ๐ ๐ฏ๐ผ๐
๐ฒ๐:
๐ฉ What 'environmental and social characteristics' are promoted by the fund (max 250 characters)
๐ฉ What % of the fund's investments are sustainable
๐ฉ What % of the fund's investments are Taxonomy-aligned
๐ฉ Does the fund consider the PAIs
๐ฉ If the fund supports an emissions reduction target, what is the total % reduction targeted, and by what year
๐ช๐ต๐ฎ๐ ๐ฐ๐ผ๐ป๐ฐ๐น๐๐๐ถ๐ผ๐ป๐ ๐๐ต๐ผ๐๐น๐ฑ ๐๐ฒ ๐ฑ๐ฟ๐ฎ๐ ๐ณ๐ฟ๐ผ๐บ ๐๐ต๐ฒ๐๐ฒ ๐ป๐ฒ๐ ๐ฝ๐ฟ๐ผ๐ฝ๐ผ๐๐ฎ๐น๐?
๐ญ The SFDR compliance headache is not going away:ย
The EU seems determined to keep 'raising the bar' for any fund marketing itself as 'sustainable'.
๐ญ Investors' need for agile software that can keep up with increasing disclosure requirements is going to increase.
๐ญ Our argument about ๐๐ซ๐ญ๐ข๐๐ฅ๐ ๐ด+ (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 "๐ต๐ฉ๐ช๐ด ๐ง๐ถ๐ฏ๐ฅ ๐ฎ๐ช๐จ๐ฉ๐ต ๐ฉ๐ข๐ท๐ฆ ๐ข๐ฏ ๐๐ณ๐ต๐ช๐ค๐ญ๐ฆ 8 ๐ญ๐ข๐ฃ๐ฆ๐ญ, ๐ฃ๐ถ๐ต ๐ช๐ต ๐ช๐ด ๐ฏ๐ฐ๐ต ๐ช๐ฏ ๐ข๐ฏ๐บ ๐ฎ๐ฆ๐ข๐ฏ๐ช๐ฏ๐จ๐ง๐ถ๐ญ ๐ธ๐ข๐บ ๐ข ๐ด๐ถ๐ด๐ต๐ข๐ช๐ฏ๐ข๐ฃ๐ญ๐ฆ ๐ง๐ถ๐ฏ๐ฅ".
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 ESGโs 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 โEDCIโ 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.
๐ง๐ต๐ถ๐ ๐ฎ๐ฟ๐๐ถ๐ฐ๐น๐ฒ ๐๐ฎ๐ ๐๐ฟ๐ถ๐๐๐ฒ๐ป ๐ฏ๐ ๐๐ป๐๐ฒ๐ด๐ฟ๐๐บ ๐๐ฆ๐ ๐ฎ๐ป๐ฎ๐น๐๐๐ ๐๐ฎ๐๐ฒ๐น ๐๐ฟ๐ฎ๐ป๐บ๐ฒ๐ฟ.
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.ย 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 companyโs 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 โphantom creditsโ failing to make โgenuineโ 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 companyโs 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 โinsettingโ challenges a reliance on offsetting. It advocates a proactive approach to tackling carbon emissions within a companyโs 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, itโs not a new concept and many companies have already embraced โinsettingโ initiatives. Examples weโve found at Integrum ESG include Nestleโs commitment to sustainable farming practises resulting in improvements in biodiversity while reducing water consumption and GHG emissions.
Decarbonisation of a companyโs supply chain is clearly the more demanding path to net-zero but it is overwhelmingly the preferred course of action.
Ultimately,ย 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.
๐๐ฆ๐ ๐ฅ๐ฒ๐ฑ ๐ฆ๐ฝ๐ถ๐ธ๐ฒ๐ ๐
๐๐ผ๐ผ๐ด๐น๐ฒ ๐๐๐๐ฝ๐ฒ๐ป๐ฑ๐ ๐ฃ๐ถ๐ป๐ฑ๐๐ผ๐ฑ๐๐ผ ๐๐ต๐ผ๐ฝ๐ฝ๐ถ๐ป๐ด ๐ฎ๐ฝ๐ฝ
๐ช๐ต๐ฎ๐ ๐ฑ๐ถ๐ฑ ๐๐ฒ ๐๐ฒ๐ฒ?
Our proprietary Real-Time ESG tracker picked up a significant negative red spike forย Pinduoduo(PDD), which has continued to rise throughout the day.ย ย
Our systems immediately sent out an alert to our clients with Pinduoduo in their portfolio.
๐ช๐ต๐ฎ๐ ๐ฑ๐ถ๐ฑ ๐๐ฒ ๐น๐ฒ๐ฎ๐ฟ๐ป?
Google has suspended Pinduoduo, one of Chinaโs 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.
๐ง๏ปฟ๐ต๐ถ๐ ๐ฎ๐ฟ๐๐ถ๐ฐ๐น๐ฒ ๐๐ฎ๐ ๐๐ฟ๐ถ๐๐๐ฒ๐ป ๐ฏ๐ ๐๐ป๐๐ฒ๐ด๐ฟ๐๐บ ๐๐ฆ๐ ๐ฎ๐ป๐ฎ๐น๐๐๐ ๐๐ถ๐ ๐ ๐ฎ๐ฟ๐ธ๐.
Signed into law in August 2022, the Inflation Reduction Act (IRA) has been hailed as โthe most significant climate legislation in U.S. historyโ 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.ย ย
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).ย
W๏ปฟe looked into 4 companies that are starting to benefit from the IRA:
๐ง๐ฒ๐๐น๐ฎ - On 22nd February, Tesla announced a shift inย 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]
๐ ๐ฒ๐ฟ๐ฐ๐ฒ๐ฑ๐ฒ๐-๐๐ฒ๐ป๐ ๐๐ฟ๐ผ๐๐ฝ - 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]
๐๐ถ๐ป๐ฑ๐ฒ - 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]
๐๐ถ๐ฟ๐๐ ๐ฆ๐ผ๐น๐ฎ๐ฟ - 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 companyโs ability to produce American-made solar modules for the US solar market to over 10 gigawatts (GW) by 2025. [4]
๐ง๐ต๐ฒ ๐ฟ๐ฒ๐ฎ๐ฐ๐๐ถ๐ผ๐ป ๐ณ๐ฟ๐ผ๐บ ๐๐ต๐ฒ ๐๐จ ๐ฎ๐ฐ๐ฟ๐ผ๐๐ ๐๐ต๐ฒ ๐ฝ๐ผ๐ป๐ฑ ๐ต๐ฎ๐ ๐ฏ๐ฒ๐ฒ๐ป ๐น๐ฒ๐๐ ๐ฒ๐ป๐๐ต๐๐๐ถ๐ฎ๐๐๐ถ๐ฐ.
European officials have complained that the IRA; which โ 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.ย ย
There are genuine fears that it could lure businesses away from the bloc with generous tax breaks - and there is no smoke without fire.ย ย
The CEO of Enel in December publicly claimed the IRA is more efficient than EU aid to support domestic production of energy sector components.ย ย
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.ย The EU has warned against a subsidy race but has welcomed the commissionโs response to the IRA.
T๏ปฟhis 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:
- ๐ง๐ต๐ฒ๐ ๐ฑ๐ผ๐ป'๐ ๐บ๐ฎ๐ธ๐ฒ ๐ฐ๐น๐ฒ๐ฎ๐ฟ ๐๐ต๐ฎ๐ ๐ฐ๐ผ๐บ๐ฝ๐ฎ๐ป๐ ๐ฑ๐ฎ๐๐ฎ ๐ถ๐ ๐ฎ๐ฐ๐๐๐ฎ๐น ๐ฎ๐ป๐ฑ ๐๐ต๐ฎ๐ ๐ถ๐ ๐ฒ๐๐๐ถ๐บ๐ฎ๐๐ฒ๐ฑ.
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.
- ๐ง๐ต๐ฒ ๐๐ผ๐ฟ๐ฑ '๐ฒ๐๐๐ถ๐บ๐ฎ๐๐ฒ๐ฑ' ๐๐๐ด๐ด๐ฒ๐๐๐ ๐ฎ๐ป ๐ฎ๐ป๐ฎ๐น๐๐๐ ๐บ๐ถ๐ด๐ต๐ ๐ต๐ฎ๐๐ฒ ๐๐๐๐ฑ๐ถ๐ฒ๐ฑ ๐๐ต๐ฎ๐ ๐ฐ๐ผ๐บ๐ฝ๐ฎ๐ป๐ ๐ฎ๐ป๐ฑ ๐ถ๐๐ ๐ถ๐ป๐ฑ๐๐๐๐ฟ๐ ๐ฎ๐ป๐ฑ ๐บ๐ฎ๐ฑ๐ฒ ๐ฎ๐ป ๐ถ๐ป๐ณ๐ผ๐ฟ๐บ๐ฒ๐ฑ ๐ฐ๐ผ๐บ๐ฝ๐ฎ๐ป๐-๐๐ฝ๐ฒ๐ฐ๐ถ๐ณ๐ถ๐ฐ ๐ฒ๐๐๐ถ๐บ๐ฎ๐๐ฒ.
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๏ปฟ. ๐ ๐๐ฒ๐ฟ๐ถ๐ผ๐๐ ๐ฝ๐๐๐ต๐ฏ๐ฎ๐ฐ๐ธ ๐บ๐ถ๐ด๐ต๐ ๐ฏ๐ฒ ๐ฏ๐ฒ๐ด๐ถ๐ป๐ป๐ถ๐ป๐ด ๐ณ๐ฟ๐ผ๐บ ๐ฎ๐๐๐ฒ๐ ๐ผ๐๐ป๐ฒ๐ฟ๐.
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.
W๏ปฟhat 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.
๐๐๐ ๐๐ต๐ฎ๐ ๐ฑ๐ผ ๐๐ผ๐ ๐๐ต๐ถ๐ป๐ธ? 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. ย
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.ย
Many LPs and investors doubt the value of scope 3, and the two main criticisms arose during the โ27 years to Net Zero, are we on track?โ panel at the PEI Responsible Investment Forum last week:ย
(1) Scope 3 calculations are crude estimates at best โ there is no such thing as measured scope 3.
(2) The double, triple, quadruple accounting problem at the fund level.ย The example given at the conference was a good one; jet fuel emissions. ย
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.ย ย
The SEC recently signalled they were scaling back their ambitious disclosure requirements on scope 3 [1], however some disclosure will be required under the newย IFRSย S2 standards [2]. So, there is mixed opinion from standard setters/regulators.ย
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 โunattractiveโ industries like Steel, or Cement.โฏ
Calculating their Scope 4 will reveal their positive impact - but again, estimations will play a large role in their quantification.
R๏ปฟead our Head of Research Hannah Bennett's thoughts here.
Effective today, Integrum ESGโs 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.
โWe 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,โ said Shai Hill, CEO and Founder of Integrum ESG. โBy combining Malkโs 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.โ
โOur clients have been very clear. They want the best ESG data available โ 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 clientsโ needs,โ said Max Hong, CEO of Malk Partners.
Above all else, client satisfaction is our highest priority, and we are excited about the ways Malkโs field-leading advisory services will complement Integrum ESGโs unmatched data capabilities.
We now look forward to serving top-tier private market investors together.
P๏ปฟlease 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 โobjectiveโ -- showed that only 286 were new.ย ย The rest were reclassifications of existing funds.
A probe of Article 9 products by Swedish authorities last month found โmany casesโ 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 ourย 'Screener Tool'ย to create an Article 9 fund whereย everyย 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" byย Corporate Vision Magazineย 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.
N๏ปฟOTE: 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 countriesย which are worst at managing risks from climate change.
T๏ปฟhe Climate Change Risk metric includes two sub-metrics:
1๏ปฟ. 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๏ปฟ. Demographic Pressures which considers pressures upon the state deriving from the population itself or the environment around (including pressures stemming from extreme weather events).
T๏ปฟhis 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 โcomply or explain mechanismโ
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 โcomply or explain mechanismโ under Article 4(1) of Regulation 2019/2088 distinguishes between โprincipal adverse impactsโ and โadverse impactsโ.
Whilst the โcomply mechanismโ 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 โcomply mechanismโ, must under point (b) of that paragraph that establishes โexplain mechanismโ, provide clear reasons for why they do not consider โadverse impactsโ 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 โdisclosure mechanismโ and reduce a hypothetical incidence of application of โexplain mechanismโ.
New regulation comes into force in January 2023, called โSFDRโ (Sustainable Finance Disclosure Regulation) - settingย out rules for asset managers to classifyย and reportย 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.ย
Moreover, the FCA regulator in the UK opened a consultation on its own version, called โSDRโ, 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 largestย 'limit on long-term bonuses as a percentage of base salary (%) 'ย -ย i.e. the potential size of a CEO bonusย ~~can be~~ย 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 inย absoluteย values, this table focuses on potential bonus as % of salary
Of the 314 companies weย 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 withย 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 theย Integrum ESG Sovereign Dashboard, compared toย its Latin America & Caribbean peers, Chile ranks no1 on overall ESGย 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 beย Article 8ย (an SFDR categorisation that means ESG has been integrated into the investment process). Morningstar however has criticised theseย funds that โplace themselves into Article 8โฆsay they consider ESG factors in the investment processโฆbut donโt integrate them in a determinative way for their investment selectionโ.ย
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 toย 14 โPrincipal Adverse Indicatorsโ. It's a detailed process, and the vast majority of self-declared Article 8 funds areย 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 โgreenwashingโ 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 โoften contain claims that do not bear scrutinyโ. 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, โyouโll see plaintiffs step in. Youโre hearing the rumblings. Itโs not happened that much yet. But it will.โ
- Simmons & Simmons in London cites cases brought by shareholders against operating companies, on ESG grounds, and the FT quotes its partner Robert Allenโs warning โyou can definitely see how (a case against fund managers) can follow onโ.
- North Wall Capital, which funds legal class actions, offers the alarming quote โit is certainly comingโ.
What might this mean? It means that a $10bn fund, that has underperformed its benchmark by 2%, and whose advertised claims that it is โsustainableโ are later deemed to be misleading, could face a $200m class action claim from its investors.
Might a clear legal standard of โsustainableโ emerge? The law firm Bates Wells believes that the 2015 Paris Climate Accord will be the legal standard โ 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 โwell below 2 degreesโ (which is the objective of the Paris Climate Accord)?
So, ESG regulatory risks and legal liabilities may be mounting for fund management firms. Theย easiest wayย 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.
Theย alternativeย 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 theseย 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 presentsย glass boxes, with the reason for every score, for every metric, and the underlying data thatย explains and supports the ESG rating.
- Applying a Cambridge University model, the Integrum ESG dashboard calculates the extent to which your fund isย aligned to the Paris Climate Accordย - 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 theย SFDRย Principal Adverse Indicators, and theย EU Taxonomyย 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.ย
These 5 risks are climate action failure, extreme weather, biodiversity loss, human environmental damage and natural resource crises.ย
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 theย sharpest deterioration inย ESG sentiment from the past seven days. Our A.I. powered sentiment tracker trawls through ~850,000 global news sources, inย 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 asย ransomware attacks,ย undisclosed CEO perks and even a US Senator calling for an investigation into price fixing in theirย 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 eitherย align with a third-party standard, or are audited. The companies with a score of 4ย alsoย 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 betterย disclosureย on ESG issues.ย
Below is a list of the top improvers when it comes to (uncustomised) ESG score improvements.ย
We are now seeing a clear trend of improving ESG disclosure in the US โ 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 theย lowestย 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 โฌ19m in audit fees, but it paid EY โฌ33m in non-audit fees (โฌ21m for tax advisory, โฌ7m for advice on new legal standards, and โฌ5m for 'other assurance services').
The Top 10 companies with the biggest YoY GHG Emission reductions
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