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PRI reporting framework 2020

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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


Robeco's Exclusion Policy is based on the following three approaches:

1. Controversial behavior

Robeco acts in accordance with the United Nations Global Compact (UNGC) and the OED guidelines. An enhanced engagement process is applied with the listed companies that have severe breaches of the UNGC principles. If this enhanced engagement is not successful Robeco will decide to exclude. In 2019 Palm Oil exclusions were added to listed companies that have less than 20% of their plantations RSPO certified. 

2. Controversial products

  • Weapons

Robeco deems anti-personnel mines, cluster munitions, chemical, biological weapons and nuclear weapons to be controversial weapons.

  • Tobacco

Robeco deems investing in tobacco companies an unsustainable investment.

3. Controversial countries

Countries that are subject to a full set of UN, EU or US sanctions are considered as being controversial. Robeco will follow any applicable sanctions to which it is subject and follow any mandatory (investment) restrictions deriving therefrom. In 2019 countries where serious violations of human rights or a collapse of the governance structure take place, were added.

In addition for Sustainability Focus products thermal coal mining and generation, weapons and military contracting and nuclear energy are excluded. For Impact strategies also alcohol and gambling are excluded.

Screened by


For engagement, Robeco uses screening to identify thematic engagement opportunities on ESG issues and companies. The identification and prioritization of themes and candidates for engagement, involves rigorous research and analysis. This helps in determining the relevance of a particular theme, the sectors and companies being mostly impacted by that theme, and the performance of companies in that respect. Our screening process is backed by proprietary research as well as external analysis provided by specialized parties.

For quant investing, Robeco uses RobecoSAM's ESG data for the screening of stocks and for constructing portfolios.

For fundamental investing, best in class screening is performed on the basis of RobecoSAM's ESG scores, materiality matrices per industry and company profiles. These serve as input for the fundamental valuation in the investment case, produced by the financial analyst.

In addition to the ESG integrated strategies, for Sustainability Focus strategies companies are also screened on environmental footprint (GHG emissions, water, waste and energy use). For Fundamental Sustainability Focus strategies the bottom 20% of companies on RobecoSAM Smart ESG score are screened out. For thematic and SDG strategies a positive screening is applied on sustainable themes and on the SDG score.

Screened by

          Universal Declaration of Human Rights, Rio Declaration on Environment and Development, GRI and ICGN.


We employ three different types of ESG screening in the context of our engagement and sustainability investing activities:

  • Screening to identify thematic engagement opportunities on ESG issues.
  • Screening for enhanced engagement and exclusion.
  • Screening in sustainability investing.

Please find additional information below. For an overview of relevant codes and principles:

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

Robeco’s distribution and marketing is organized around its three client segments (institutional, wholesale and retail) in order to maintain a clear focus on the best way to serve these distinctly different groups. Robeco ensures intensive personal interaction between institutional clients and distribution partners on the one hand, and senior management, account managers, client servicing teams and portfolio managers on the other.

To improve the servicing of wholesale and institutional clients, Robeco either performs in-house studies or buys ad-hoc surveys on specific topics. In 2018, the topics that clients showed an interest in included factor investing, ESG integration and active versus passive investing. Any expected changes or changes to our sustainability methodology are communicated to clients via personal interaction, via articles on the website, KIIDS and factsheets and via our quarterly newsletter. Changes in the exclusion policy or any of the other SI policies are published on our website. 

One of our key strategic aims for Robeco Retail is to make sustainability investing accessible for everyone by allowing low entry amounts and providing easy-to-use websites and services. This strategy will guide our efforts in the coming years.

In addition to 4.1:

We employ three different types of ESG screening in the context of our engagement and sustainability investing activities:

  • Screening to identify thematic engagement opportunities on ESG issues (picking themes and selecting companies): The identification and prioritization of themes and candidates for engagement involves rigorous research and analysis to determine the relevance of a particular theme, the sectors and companies being mostly impacted by that theme and the performance of companies in that respect. Our screening process is backed by proprietary research as well as external analyses provided by specialized parties.
  • Screening for enhanced engagement and exclusion: Our enhanced engagement program is applied to companies violating the ten principles of the United Nations Global Compact in the areas of human rights, labour rights, environmental issues and anti-corruption. The screening on such controversies is carried out through several databases as well as other research sources. Our generic exclusions policy entails the exclusion of companies that manufacture products that do not comply with broadly accepted international treaties, in particular treaties on controversial weapons. The screening of companies on controversial weapons involvement is carried out by (among others) our data provider Sustainalytics and conforms to Dutch law.
  • Screening in sustainability investing: Furthermore, Robeco systematically incorporates analysis of ESG factors into both its quant and its fundamental investment processes. We are convinced that taking ESG criteria into account results in better-informed investment decisions and is necessary to fully grasp the opportunities that are associated with the businesses. In quant investing the choice of ESG variables in the models is based on back testing. We inform clients if we make a change to the model. In fundamental equity the choice of the ESG variables is based on the ESG materiality matrix. This matrix and the company profile is reviewed every two years. Changes are incorporated into the valuation of companies.

Furthermore, Robeco is committed to measuring the carbon footprint of its investment products (for more information on the companywide approach please see the section on climate change). RobecoSAM's Environmental Impact Monitoring tool measures the impact of investors' portfolios in terms of greenhouse gas emissions, energy and water consumption and waste production. Robeco and RobecoSAM have further developed tools for actively managing the reduction of the greenhouse gas emissions footprint associated with its portfolios while also controlling for other environmental impacts. Based on these tools Robeco has adopted a comprehensive approach to reducing emissions with respect to the relevant benchmark. We are also able to respond to specific client requirements in optimizing investment portfolios to meet absolute targets. All Robeco SI Focus funds optimize their carbon footprint. These funds have at least a 20% target on carbon reduction towards the benchmark.

All Robeco SI Focus funds are divested from mining companies with more than 10 percent of thermal coal revenues, and from power producers with more than 20 percent of thermal coal related revenues.

Thermal coal is a product that is predominantly used in power generation and is a more carbon intensive source of energy than any of the alternatives such as oil and natural gas. We focus on thermal coal because we consider that power generators have a choice of technologies and we expect them to move towards the lower carbon alternatives. We expect to see companies reducing their dependence on thermal coal in the future and aim to adjust our threshold lower in the coming years.

Robeco's climate change policy can be found here:

Please find additional information below. For an overview of relevant codes and principles:

In 2019 Robeco subscribed to the Eurosif Transparency Guidelines for its Sustainability Focus range, increasing transparency:

 Also a document was published on ESG integration per strategy:

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

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

          Industry ESG materiality framework, that helps identify most material risks and opportunities across various sectors

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.

05.4. Indicate how frequently you review internal research that builds your ESG screens.

05.5. Additional information. [Optional]

For our exclusion policy all assets are screened based on our policy. To ensure robustness we use multiple sources of information for the controversy screening (Sustainalytics, RobecoSAM Media and Stakeholder analysis, RepRisk). The information is updated at least once a quarter, but also on an ad hoc basis when controversies or changes in for example sanctions occur. The exclusion list is integrated into our trading systems and compliance pre-trade monitoring is in place.

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.

The rules for Sustainability funds are determined and validated by the Sustainability and Impact Strategy committee (SISC). This committee guides sustainability developments. The committee consists of members of the Executive Committees of Robeco and RobecoSAM and internal specialists. 

The portfolio management team bears the responsibility to implement the rules in the portfolio. Outcomes are measured and monitored via an automated system. The eligible universe is coded by the compliance team as such that any ticker not being eligible will be flagged and results into a pre-trade compliance alert that needs to be addressed by the pre-trade restriction team and the portfolio manager responsible for the respective fund. In addition, the eligible tickers enables the daily Compliance post-trade check, ensuring the portfolios being monitored are compliant on an ongoing basis. The internal audit department periodically evaluates the effectiveness of this process.

Furthermore results are reported to clients on a monthly basis. Please see the monthly portfolio managers update on our website for an example of this reporting.

External due diligence of our processes take place by our clients and are part of our application for external labels. In 2018 we applied for and were awarded the French SRI Label for our Sustainability Focus range. To be able to be awarded this label an external party audited our processes. In 2019 we applied for the Febelfin label for over 16 strategies. The external verification was done by Ethibel. All 16 strategies were awarded the label. Furthermore, we are continually subject to client due diligence processes.

06.3. Additional information. [Optional]