Financial analysts are responsible for negative-screening and ensuring companies do not have activities part of the exclusion list, prior to start any fundamental analysis. The CIO, as directly involved in investment decisions, also have a role in the implementation. A double verification from a compliance officer is realized before any investment decision. The portfolio compliance is reviewed on a regular basis.
Engagement approaches are collectively decided upstream by the Head of sustainability, investment analysts and salesforce, as an integral part of the investment strategy. Actions are implemented afterwards by the portfolio managers and ultimately incorporated into investment decisions.