| Guidance |
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DEI due diligence reporting lines | Disclosure of who is ultimately responsible for enforcing DEI policy, DEI reviews, DEI oversight, or other DEI procedures in the investment process. This includes designated groups, parties, or people inside the company responsible for overseeing DEI. This will also be considered disclosed if an executive team is also a DEI team. Otherwise, the reporting lines and ultimate DEI authority must be disclosed. |
DEI policy or initiative | This is marked as disclosed if the firm specifically mentions the existence of a diversity policy or discloses the policy itself. This can include a formal policy, an actual initiative or target for inclusion in hiring, a process to hire more diverse candidates, or adoption of a third-party policy on diversity. |
DEI policy or initiative for portfolio companies/assets | This is marked as disclosed if the firm specifically mentions the existence of a diversity policy or discloses the policy itself for their portfolio companies or assets. This can include a formal policy, an actual initiative or target for inclusion in hiring, a process to hire more diverse candidates, or adoption of a third-party policy on diversity. |
Family Leave policy | This is marked as disclosed if the firm specifically mentions the existence of a family leave policy or discloses the policy itself. |
Tracks employee diversity | This is marked as disclosed if the firm tracks any form of diversity metric (i.e., gender, ethnicity, demographic, etc.). Although we are at a base level assessing proof of concept, actual metrics may also be disclosed. |
Breakdown of pay details | This is marked as disclosed if the firm discloses the breakdown of pay details numerically |
Breakdown of pay details at the portfolio company/asset-level | This is marked as disclosed if the firm discloses the breakdown of pay details numerically in their portfolio companies or assets |
Gender breakdown of the board of directors | Disclosure of the gender of members of a firm’s board of directors or the breakdown of gender on the board by percentage which indicates the inclusion of at least one female board member. The amount of female representation on the board is otherwise immaterial in this instance, as we are assessing transparency and not firm performance. We do not accept nor assume gender through photos. |
Gender breakdown of the executive committee | Disclosure of the gender of members of a firm’s executive committee or the breakdown of gender on the executive committee by percentage which indicates the inclusion of at least one female executive committee member. The amount of female representation on the executive committee is otherwise immaterial in this instance, as we are assessing transparency and not firm performance. We do not accept nor assume gender through photos. |
Gender breakdown of the executive committee or senior management at the portfolio company/asset-level | Disclosure of the gender of members of a firm’s executive committee/senior management or the breakdown of gender on the executive committee/senior management by percentage which indicates the inclusion of at least one female executive committee/senior management member for their portfolio company or assets. The amount of female representation on the executive committee/senior management is otherwise immaterial in this instance, as we are assessing transparency and not firm performance. We do not accept nor assume gender through photos. |
Gender breakdown of the senior management team | Disclosure of the gender of members of a firm’s senior management or the breakdown of gender on the senior management team by percentage which indicates the inclusion of at least one female senior management member. The amount of female representation on the senior management team is otherwise immaterial in this instance, as we are assessing transparency and not firm performance. We do not accept nor assume gender through photos. |
Gender breakdown of the wider company | Disclosure of the gender of members of a firm’s wider company or the breakdown of gender in the wider company by percentage which indicates the inclusion of at least one female employee. The amount of female representation in the company is otherwise immaterial in this instance, as we are assessing transparency and not firm performance. We do not accept nor assume gender through photos |
Gender breakdown of the wider company at the portfolio company/asset-level | Disclosure of the gender of members of a firm’s wider company or the breakdown of gender in the wider company by percentage which indicate the inclusion of at least one female employee for their portfolio company or assets. The amount of female representation in the company is immaterial in this instance, as we are assessing transparency and not firm performance. We do not accept nor assume gender through photos. |
Emissions targets | Disclosure of numerical or measurable emissions reductions targets. |
Emissions targets for portfolio companies/assets | Disclosure of numerical or measurable emissions reductions targets for the portfolio company or assets. Targets can be specific to an asset or apply to the general portfolio. |
GHG emissions | This is marked as disclosed if the firm discloses their Scope 1, Scope 2 and/or Scope 3 GHG emissions. This must include numerical figures, generally recorded in tCO2e. Additionally, this indicator will also be considered disclosed if a firm adheres to ISO14064, as this is the international standard for disclosure. |
GHG emissions of portfolio companies/assets | This is marked as disclosed if the firm discloses Scope 1, Scope 2 and/or Scope 3 GHG emissions for their portfolio companies. This must include numerical figures, generally recorded in tCO2e. |
GHG emissions: Scope 1 | This is marked as disclosed if the firm discloses Scope 1 GHG emissions. This must include numerical figures, generally recorded in tCO2e. |
GHG emissions: Scope 1 of portfolio companies/assets | This is marked as disclosed if the firm discloses Scope 1 GHG emissions for their portfolio companies. This must include numerical figures, generally recorded in tCO2e. |
GHG emissions: Scope 2 | This is marked as disclosed if the firm discloses Scope 2 GHG emissions. This must include numerical figures, generally recorded in tCO2e. |
GHG emissions: Scope 2 of portfolio companies/assets | This is marked as disclosed if the firm discloses Scope 2 GHG emissions for their portfolio companies. This must include numerical figures, generally recorded in tCO2e. |
GHG emissions: Scope 3 | This is marked as disclosed if the firm discloses Scope 3 GHG emissions. This must include numerical figures, generally recorded in tCO2e. |
GHG emissions: Scope 3 of portfolio companies/assets | This is marked as disclosed if the firm discloses Scope 3 GHG emissions for their portfolio companies. This must include numerical figures, generally recorded in tCO2e. |
GHG intensity of portfolio companies/assets | This is marked as disclosed if the firm discloses carbon intensity for their portfolio companies. This must include numerical figures. |
Adherence to any ISO standards | ISO standards are specific standards set by the International Organization for Standardization. The firm may adhere to any ISO standard for this indicator to be considered disclosed. |
Adopts a green building or energy management standard | This is marked as disclosed if the firm discloses a third-party standard for green building or energy management. |
Any mention of sustainability consideration in operations | Mention of sustainability on a firm’s website, policies, reports, or other collateral. This indicator is considered disclosed if any material suggests that the company is using sustainability in some way, either in their portfolio management or in their own business operations, such as management of diversity or carbon emissions. This does not include philanthropy or CSR initiatives, but must specifically mention information about environmental risk management, labor risk management, or governance issues. |
Board of directors | This is meant to simply capture the disclosure of any board of directors at the firm level. |
Dedicated sustainability report | This is marked as disclosed if the firm has released a sustainability, corporate responsibility, CSR, ESG, socially responsible, impact, or other sustainability/impact-related report within the past two years. This may include UNPRI Public Signatory Reports. |
Employee engagement surveys | This is marked as disclosed if the firm mentions or publishes the results of an employee engagement survey. |
Sustainability integration within performance reviews and/or compensation mechanisms | This is marked as disclosed if the firm mentions sustainability practices or initiatives being a component of the compensation structure or performance reviews of their employees, and determines the pay they are getting. |
Governing, leadership, or executive bodies, including the board of directors | This is meant to simply capture the disclosure of any executives or governing bodies at the firm level. This may include disclosure of the board of directors, Chief Executive Officer or executive team, or any other firm leadership. |
List of investors by type | Disclosure of a basic list of client types, often included in UNPRI Public Signatory Reports. |
Ownership structure of the firm | Ownership structures specifically refer to whether the General Partner is publicly listed (if they have an investor relations section on their website or if they are listed on any global exchange and have a stock ticker, for instance) or if they list the owner(s) of the company. |
Registered investment advisor or registered broker dealer status | This specifically refers to whether the firm is regulated by a securities regulator, either as a registered investment advisor, broker, or other regulated entity that can legally give investment advice. |
Spending on political donations and/or lobbying expenditures | This refers to evidence of political donations and/or lobbying expenditure. We also accept mentions of no political donations or lobbying expenditure being made. |
Statements, policies, or initiatives related to climate change | This is marked as disclosed if the firm discloses any statements, policies, or initiatives related to climate change, carbon, or emissions. This is related to the company itself, which may include statements regarding the risks of climate change, announced initiatives to measure or manage climate risk as part of a firm’s business model or investment strategy, or disclosure of a carbon or climate change-related policy |
Waste generation metrics | Disclosure of numerical metric on waste generation, such as recycling waste disposal |
Anti-money laundering and/or “know your client” (AML KYC) policy | Any disclosed policy that refers to anti-money laundering or “know your client” (KYC). This specifically refers to an anti-money laundering/KYC policy that extends beyond a privacy policy. |
Code of conduct | Any disclosure of a code of conduct (COC) that applies to all employees at the firm. This may take the form of an ethics code, bribery code, or other code of conduct that employees must abide by. |
Insider trading policy | Any disclosure specifically mentioning insider trading that refers to the disclosure of a policy related to the buying/selling/trading of a stock or other securities using material, nonpublic information. This may be related to the code of conduct. |
Modern slavery human rights policy | Disclosure of any policy relating to modern slavery, human trafficking, or human rights. |
Political donations and/or lobbying expenditure policy | Any mention of a policy relating to political donations, contributions or expenditures, or lobbying-related activities. |
Privacy policy | This is marked as disclosed if the firm discloses the existence of its own privacy policy. This includes the mention of adherence to ISO standards or JIS Q standards related to privacy or data protection and data management. |
Sustainable supply chain framework | Any disclosure by the firm that is related to their supply chain framework or how they are adding sustainable practices to their supply chain network. This includes sustainability materiality risks or business ethics integration in the firm’s supply chain operations. |
Whistleblower or anonymous incident reporting process | This is marked as disclosed is the firm mentions any evidence of a whistleblower policy, whistleblower or anonymous hotline for reporting breaches in conduct, or other systems for reporting internal issues anonymously. |
Employee training on data security or privacy | Any mention of training on data security or privacy. In order to be marked as disclosed, the training must have happened; the intent to conduct this training is not sufficient. |
Management training | Any mention of training exclusively for employees in management positions. This excludes manager onboarding training and management-related training sessions for non-managers. In order to be marked as disclosed, the training must have happened; the intent to conduct this training is not sufficient. |
Training for investment professionals on sustainability risks and opportunities in investment activities | Any mention of training specifically for investment professionals on investment sustainability risks and opportunities. In order to be marked as disclosed, the training must have happened; the intent to conduct this training is not sufficient. |
Any mention of ESG consideration in investing | Mention of ESG consideration in a firm’s investment process. This may include the disclosure of an ESG policy or any mention of ESG as a factor, consideration, or potential risk or opportunity in investing |
Breakdown of energy efficiency for real estate assets | This is marked as disclosed if the firm discloses a third-part standard for energy efficiency (i.e., EPC ratings, LEED, BREEAM, etc.). This applies to the asset-level only. |
Dedicated ESG investment policy | Any disclosed investment policy that mentions the consideration of ESG in investing. This specifically refers to an investment policy that extends beyond ESG or sustainability in firm operations. |
Dedicated sustainability investment staff | Disclosure of any staff members specifically dedicated to implementing sustainability policies, strategies, and procedures in the investment process. This may be a dedicated business unit, team, or individual. |
Sustainability commitments included in fund documents | This is marked as disclosed if a firm's fund documents (i.e., LPAs, Side-Letters, etc.) include sustainability commitments. |
Sustainability considerations included in deal documentation | This is marked as disclosed if a firm's deal documentation (i.e., Shareholder's Agreements) includes sustainability considerations. |
Sustainability due diligence reporting lines | Disclosure of who is ultimately responsible for enforcing sustainability policy, sustainability reviews, sustainability oversight, or other sustainability-related procedures in the investment process. This includes designated groups, parties, or people inside the company responsible for overseeing sustainability. This will also be considered disclosed if an executive team is also a sustainability team. Otherwise, the reporting lines and ultimate sustainability authority must be disclosed. |
Sustainability risks and opportunities included on Limited Partners Advisory Committee and Annual Investor Meeting Agenda | This is marked disclosed if a firm includes sustainability as a topic during investor meetings or LP Advisory Committees. |
Investments in portfolio companies/assets explicitly aligned with the UN Sustainable Development Goals | Disclosure of individual investments in portfolio companies tied to the Sustainable Development Goals, clearly stated as such. |
Total AUM as subject to sustainability criteria or policies | Disclosure of a currency amount of assets under management that are subject to sustainability policies or assessment. If a disclosed sustainability policy explicitly states its applicability to total AUM, this will also be considered disclosed. Otherwise, this must be numerical. |
Environmental impact studies conducted on portfolio companies/assets | This is marked as disclosed if the firm mentions that they conduct environmental impact studies before investing in portfolio companies, while holding and engaging with portfolio companies, or as part of typical portfolio company exits. Environmental impact studies may include pollution studies, emissions studies, or any other study that is related to the environment as part of investing. This must specifically be a study conducted on one or more of the companies in which they invest, going beyond the mere consideration of environmental impacts of their portfolio companies. |
List of exclusionary screening factors | This is marked as disclosed if the firm mentions the specific screening factors they used. Examples of screening factors include Controversial Weapons, Tobacco and Fossil Fuels. |
Policy specifying how sustainability factors are used after investing in portfolio companies/assets, or in company exits | Disclosure of a policy specific to post-investment processes that includes sustainability engagements, tracking sustainability factors, and/or how sustainability is considered when exiting an investment. |
Policy specifying how sustainability factors are used before investing in portfolio companies/assets | Disclosure of a policy specific to pre-investment due diligence that includes the consideration of sustainability factors before making an investment, the application of an exclusionary policy, or the consideration of environmental or social impacts of portfolio companies before investing. |
Social impact studies conducted on portfolio companies/assets | This is marked as disclosed if the firm mentions that they conduct social impact studies before investing in portfolio companies, while holding and engaging with portfolio companies, or as part of typical portfolio company exits. Social impact studies may include diversity impact, employment of underrepresented groups, or any other study that is related to the society as part of investing. This must specifically be a study conducted on one or more of the companies in which they invest, going beyond the mere consideration of social impacts of their portfolio companies. |
Code of conduct for portfolio companies/assets | Disclosure of a code of conduct explicitly stated as applicable to portfolio companies. This may take the form of an ethics code, bribery code, or other code of conduct that employees must abide by. |
Employee engagement surveys for portfolio companies/assets | Disclosure of employee engagement surveys conducted on any topic for at least one portfolio company or asset. Evidence of employee engagement surveys conducted is sufficient, and results are not necessary. |
Engagement process or considerations specifically focused on sustainability issues with portfolio companies/assets | Disclosure of an engagement policy that details an engagement process with portfolio companies on sustainability specific issues. This must include evidence of a process or issue that exemplifies how engagement happens. Sustainability issues may include any environmental issues (waste, water, energy, pollution, carbon, regulatory fines for environmental damage, etc.), social issues (employees and employee management, social protests, religious issues, etc.), or governance issues (management team composition, leadership structure, business ethics or codes of conduct, bribery, corruption, etc.). |
Sustainability educational programs designed and run for portfolio companies/assets | The existence of any formal educational programs designed for portfolio companies that address sustainability-related issues. This may include portfolio company trainings offered by the GP on topics such as workforce management, environmental law, corporate structures, stakeholders, diversity and inclusion, or anything else related to sustainability. |
Policy detailing engagement processes with portfolio companies/assets | Disclosure of an engagement policy that details a general engagement process with portfolio companies on any topic or issue. This must include evidence of a process or issue that exemplifies how engagement happens. |
Reporting or monitoring portfolio companies/assets using ESG KPIs | This is marked as disclosed if the firm mentions that they monitor ESG performance, or any specific ESG issues (i.e. carbon emissions, workforce performance, board diversity and makeup, environmental law compliance, etc), in their portfolio companies. Although we are at a base level assessing proof of concept, actual metrics may also be disclosed. |
Share of portfolio companies/ assets where engagements were conducted on sustainability policies or issues | Disclosure of the number of companies that were reviewed for sustainability issues or against a sustainability policy either before or after investment. This does not necessarily need to include what they were reviewed for as long as it specifies, even generically, "sustainability issues" or "sustainability" as the basis for review. |
