The exclusion policy is monitored and coded by Investment Restrictions.
Monthly (on the first business day of every month), the Fixed Income Portfolio Information (hereafter FI PIM) team extracts the most recent SDG scores as input for the FI PIM screening tool from the RobecoSAM database where the SDG scores are being stored. Secondly, the FI PIM team extracts from the most recent coverage list of the Robeco Credit Analyst team the tickers of all issuers currently under coverage, the Bloomberg (BB) Global ID and their respective score from the Robeco Credit Analyst team. This is to ensure control over the ultimate eligible universe only consisting of names that are under actual coverage of the Robeco Credit Analyst team in Rotterdam (as the Investment Team from Rotterdam is ultimately responsible for the investment decisions of the above mentioned funds). The coverage list is of key importance and contains separately monitored key controls.
The screening tool is fed with the following data:
- Most recent SDG scores
- Most recent coverage list from the Robeco Credit Analyst team composed of covered tickers and individual identifiers labelled as “green bonds” (with their own scores)
- Most recent Enhanced Exclusion list constituents
The ultimate eligible ticker list is sent to the COO Data Management team and the Compliance Restrictions monitoring team. The COO Data Management team safeguards that no ineligible ticker can be invested without a pre-trade alert. The compliance team permanently coded the restrictions 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 ticker and green bond ISIN enables the daily Compliance post-trade check, ensuring the portfolios being monitored are compliant on an ongoing basis.
To safeguard a sound backup, continuous operation and present detailed operational knowledge in case of ad-hoc client/prospect and portfolio manager questions, FI PIM safeguards sound knowledge sharing within their team and that at least two people evaluate the changes and investable universe list together.