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Alliance Bernstein

PRI reporting framework 2018

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You are in Direct - Listed Equity Incorporation » ESG incorporation in actively managed listed equities » Implementation processes » (A) Implementation: Screening

(A) Implementation: Screening

LEI 04. Types of screening applied

04.1. Indicate and describe the type of screening you apply to your internally managed active listed equities.

Type of screening

Screened by

Description

We employ screening in a variety of ways as noted above.   

  1. In our equity services that have explicit responsible investment mandates beyond ESG integration -- including the Global Sustainable Thematic, Global Core, Concentrated US Equities, N50 Frontier Markets strategy -- screening is employed through exclusions in different ways.   
  2. In our other equity services, we apply client-directed negative or positive screening to separately managed accounts if noted in investment guidelines.
  3. In our publicly available Luxembourg-Fund platform, we proactively restrict controversial weapons. 

 

 

Screened by

Description

We manage the following:

  1. A portfolio for a client that is managed against the FTSE4GOOD index which includes companies that meet certain thresholds for ESG, in addition to screening out companies that are in certain industries.
  2. Portfolios for clients that meet the screening criteria of a third-party ESG research provider.
  3. In September 2016, we introduced a Global Responsible Factor Fund that invests in global equity securities of  companies that meet certain ESG criteria.  It combines positive and negative screening based on MSCI SRI Benchmark.

 

 

Screened by

Description

Our Global Sustainable Thematic and Global Core strategies include norm based screening. We are working to provide tools to our analysts more broadly to assess UNGC compliance, and other norms.

04.2. Describe how the screening criteria are established, how often the criteria are reviewed and how you notify clients and/or beneficiaries when changes are made.

Screens are generally developed in conjunction with our clients and discussed at regular client review meetings. Some clients provide us with a list of companies to be restricted from their portfolio. Other clients prefer that we screen using a third party research provider - these screens can take several forms, including industry screens as well as screening by ESG factors. Once the companies to be screened are identified, they are captured electronically in our compliance systems and monitored daily. Updates to these screens are made regularly - as our clients or our research providers provide updated data. 

In the course of implementing such screens with our client, we do engage in an active dialogue with them regarding the implementation of specific screens, and any liquidity or tracking error considerations that might result from such screens. Our objective, of course, is to satisfy our client on two dimensions: satisfy their specific ESG requests, and also generate an attractive investment return in their Portfolio.

To the extent a change is made to a screen, the documentation is reviewed by Legal and portfolio management, and subsequently sent to our Client Guidelines group for coding where the necessary testing would be applied.  These changes will be client driven, and no changes will be made without their formal sign-off.

Within our Luxemburg Fund platform, we screen for controversial weapons based on research from a third-party service provider. Our Global Sustainable Thematic, Global Core, Concentrated US Equities, N50 Frontier Markets strategies apply negative screens.

 

 


LEI 05. Processes to ensure screening is based on robust analysis

05.1. Indicate which processes your organisation uses to ensure screening is based on robust analysis.

05.2. Indicate the proportion of your actively managed listed equity portfolio that is subject to comprehensive ESG research as part your ESG screening strategy.

05.3. Indicate how frequently third party ESG ratings are updated for screening purposes.

05.5. Additional information. [Optional]

The primary way we ensure that the screening we do is based on robust analysis is that we use screens provided, maintained, and updated by the leading ESG research providers in the industry. (The listing of the ESG Providers we use is shown in Question LEI 2.2 above.)  These providers regularly update their screens and listings of issuers, and these updates are automatically provided to our analysts through direct feeds, keeping everyone updated on a real-time basis.   

The Client Guidelines Management (CGM) team has oversight responsibilities which entail coding, review, and monitoring of the compliance systems.  Issuers are restricted in automated testing on a pre-trade basis to prevent initial purchases.  If an issuer was purchased it would be captured by post trade monitoring controls and escalated through Portfolio Management Group/Legal.  A CGM coder and reviewer checks every routing.  Routings are submitted through our workflow tool and require assistant portfolio manager review after CGM completes our coding process.  CGM is a separate entity from the portfolio management groups.


LEI 06. Processes to ensure fund criteria are not breached

06.1. Indicate which processes your organisation uses to ensure fund criteria are not breached

          Internal audit reviews compliance with investment guidelines and restrictions on a risk based approach
        

06.2. If breaches of fund screening criteria are identified - describe the process followed to correct those breaches.

Despite our best efforts, from time to time inadvertent breaches of guidelines do occur. When guideline deviations arise, we seek to bring the client's account back into compliance as promptly as possible. If the deviation incident is deemed to be an error, we will follow the escalation and correction procedures set forth in our Error Resolution and Reporting Policy. Whenever we become aware of a potential error (whether we or our client are the first to notice it) we will conduct a thorough investigation. Where a guideline error on our part has generated a loss for our client, we shall make our client's account whole, and inform our client in a timely manner.  We note that some of our clients have expressly incorporated into their IMA protocols for the timeliness with which they should be notified of any such breach as well as guidance for handling the breach.

It is AB's policy to record all incidents involving the accounts of asset management clients, and to correct any and all errors affecting those accounts in a fair, timely and reasonable manner. When correcting an error, our objective is always to take appropriate actions consistent with our fiduciary duty of care, to put our client in the same or substantially the same position as if we had not made the error. In some cases, that is not possible or practical. Even then, however, if our client has incurred a loss attributable to the actions of AB, that loss is fully reimbursable.

06.3. Additional information.[Optional]

Our Operations Group uses a third-party application, Fidessa's Sentinel System, to assist portfolio managers in remaining in compliance with client-specific investment guidelines as well as internal guidelines and risk limits. These client-specific guidelines include ESG-related guidelines and restrictions.

Our Client Guideline Management team independent from our Portfolio Management Group, encodes all client guidelines into Sentinel and monitors them on a daily, post-trade, end of day basis. From an ESG standpoint, examples of client-specific guidelines that can be programmed into Sentinel include restricting a particular issuer, sector or industry from being held.

The encoded guidelines are then reviewed and approved by either portfolio managers or associate portfolio managers to ensure correct interpretation.

In performing the pre-trade function, Sentinel reviews each proposed trade and flags trades within those client accounts where they are prohibited by a client guideline. Post-trade, the Sentinel system generates daily reports that include all applicable restrictions and limitations, based on compliance parameters coded when the account was set up, and includes approved guideline updates provided by the client.  The portfolio managers or the associate portfolio managers review daily exception notifications for possible breaches in conjunction with the Client Guidelines Management team. Exceptions are reported to the Compliance Guideline Management Department as well as to the portfolio management team. The portfolio managers are ultimately responsible for ensuring compliance of guidelines.


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