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PRI reporting framework 2019

You are in Direct - Listed Equity Incorporation » ESG incorporation in actively managed listed equities » Implementation processes

Implementation processes

LEI 01. Percentage of each incorporation strategy

01.1. Indicate (1) which ESG incorporation strategy and/or combination of strategies you apply to your actively managed listed equities and (2) the breakdown of your actively managed listed equities by strategy or combination of strategies (+/- 5%)

ESG incorporation strategy (select all that apply)

Percentage of active listed equity to which the strategy is applied
100 %
Total actively managed listed equities 100%

01.2. Describe your organisation’s approach to incorporation and the reasons for choosing the particular ESG incorporation strategy/strategies.

As first approach to SRI, we have chosen screening, since it enable us relatively simply and quickly to select the assets we are more interested in according to ESG terms.

We use different screening criteria for each sub-type of equity asset:

-Equity funds and ETF: (This is 60% of the data reported in this module) the management entity is evaluated by analyzing the ESG policies they use in their funds and analyzing their subscriptions in different initiatives such as UNPRI, UN Global Compact... 

-Listed Equity (This is 40% of the data reported in this module): We exclude by country and we do norm-based exclusion. Additionally, we use the ESG rankings published by Sustainalytics and RobecoSAM to analyze companies and position them in regards to their comparable companies.


01.3. If assets are managed using a combination of ESG incorporation strategies, briefly describe how these combinations are used. [Optional]

LEI 02. Type of ESG information used in investment decision (Private)

LEI 03. Information from engagement and/or voting used in investment decision-making (Private)

(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


Positive/best-in-class screening

1) Positive screening: Equity (excluding Funds and ETF):

ESG rankings published by Sustainalytics and RobecoSAM are used to analyze the company and position with respect to their comparable although the company's position is not an exclusionary criterion.

Geroa Pentsioak guarantees that at least 50% of the investment in Corporate Fixed Income and in Equity is located within companies that have a higher score than 70 on the mentioned rankings (being 100 the top score).

2) Positive screening: ETF and Equity Funds:

Analysis of SRI policies used by management entities and subscriptions to different initiatives (UNPRI, Un Global Compact, GRI...).

A minimum of 75% of the investments shall be made through entities who have implemented ESG policies in their investment processes, or who are UNPRI signatories.

Screened by

          Sustainalytics' controversy research


1) Norm-based screening: Equity (excluding Funds and ETF):

Norm-based exclusion: An analysis of controversies is performed and it is ensured that none of the companies breaches any of the UN Global Compact principles. If an entity is involved in a serious controversy level (4 or 5 according to Sustainalytics) or if a company breaches any of the of the UN Global Compact principles, automatically that security will be in an observation period. In general basis, the positions in these securities will not be increased. The investment team along with management will decide if the security should be considered not suitable to keep it in the portfolio. If the security is declared unfit, the positions will be disposed as soon as possible.

In 2018: all the positions in securities with 5 level of controversy or non-compliance of UN Global Compact were disposed of.

Norm-Based exclusion: Should any relevant occurrence or inappropriate behaviour by the management company come to the notice of the investment committee, it will automatically enter into a period of observation. Should it be declared "unsuitable" the positions will be disposed of as soon as possible.

In 2018: No Fund/ETF has been declared unsuitable.

04.2. Describe how you notify clients and/or beneficiaries when changes are made to your screening criteria.

The periodical control is conducted on quarterly basis and the SRI policies are reviewed annually. The SRI policies are disclosed in the website.

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.

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

05.5. Additional information. [Optional]

LEI 06. Processes to ensure fund criteria are not breached (Private)