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Santander Empleados Pensiones, F.P.

PRI reporting framework 2019

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


We exclude companies when they are related to or engage in the following activities:

  • Inappropriate use of nuclear energy
  • Toxic waste related activities
  • Environmental Pollution
  • Child Labour
  • Universal Declaration of Human Rights breachment
  • Child Pornography
  • Manufacturing or sale of a finished product/strategic parts of cluster ammunition, anti-personnel landmines or nuclear weapons
  • Irresponsible advertisement of alcohol, tobacco, pornography or gambling related products

Screened by


As it was earlier stated, we obtain an overall ESG rating via a 2-step process. We use the data provided by Vigeo-Eiris and give a greater weight towards the overall score to the indicators that concentrate on the main ESG issues. This same process is repeated but taking into account the impact each indicator has on each of the 11 GICS Sectors in order to obtain a final ESG rating for companies that takes into account both, their overall ESG performance and their sector-specific impact. 

Screened by


Some of the indicators that we use to determine the ESG Rating of our companies directly derive from the principles in these conventions.

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

Screening criteria is established by the ESG/SRI team based on the ESG approach depicted by the Control Commission in the investment policy. The review of the criteria in our investment process is performed on an ad-hoc basis. The Control Comission, governing organ of the pension fund, is notified about the status of the investment policy twice a year and clients and beneficiaries recieve information about the pension fund/any changes to policies every 4 months. 

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]

We update our records from third party ESG information every 4 months. 

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.

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

In the case that during our trimestral screening update a company has breached one or more of our exclusion policies, the Control Commision decides whether to start an engagement process with the company or divest from it directly. In case of engagement, a formal letter is sent by the pension fund to the corporation involved asking them for information regarding the incident, giving them the right to defend their position and enquiring about the incident that has led them to this situation. If the result from this process is negative, the pension fund divests from the company. The list of excluded companies is sent to the fund managers who have 6 months to divest in such a way that does not affect the value of the portfolio. 

06.3. Additional information.[Optional]