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PRI reporting framework 2020

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ESG incorporation in actively managed listed equities

Implementation processes

LEI 01. Percentage of each incorporation strategy

01.1. Indicate which ESG incorporation strategy and/or combination of strategies you apply to your actively managed listed equities; and the breakdown of your actively managed listed equities by strategy or combination of strategies.

ESG incorporation strategy (select all that apply)

Percentage of active listed equity to which the strategy is applied — you may estimate +/- 5%
100 %
Total actively managed listed equities 100%

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

ACTIAM uses a combination of strategies for its internally managed active funds. A combination of screening, integration and thematic strategies is implemented. Please see LEI 01.3 for an explanation of the incorporation approach. The reason for choosing this combination of strategies is that it allows us to exclude companies that we do not wish to be invested in because of violation of international standards or due to insufficient performance in several material drivers and risks; differentiating the remaining companies with respect to their ESG performance (although only a minority of companies is excluded, yet there can be considerable differences in ESG performance of the remaining companies); and finally to downgrade or upgrade companies based on certain material themes, such as climate change, water and land.

The approach allows us to form an opinion about the sustainability of every entity in the portfolio and to combine this analysis with the financial analysis of the entity, thereby constructing a portfolio of companies that show both a high ESG as well as a high financial performance. 

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

ACTIAM stimulates companies to prepare for the ongoing transitions, operate within the planetary boundaries, respecting the social foundations. All companies are evaluated on its steps to move towards the so-called safe and just space. Accordingly, the active funds incorporate all three strategies. First, a screening is conducted based on ACTIAM's Sustainable Investment policy. Companies in breach of the FIP or non-adaptive at any material business drivers are excluded from the investment universe (

Secondly, we add a thematic overlay based on material business drivers, such as water, land and social capital development that impact several sustainability issues. For this, we consider to what extent companies have the capabilities of adapting to the ongoing sustainability transitions. Companies that are considered positive contributors, such as responsible renewable energy producers, are positively selected by upgrading their ESG score. Engagements can be set up in case these companies deliver a sustainable core product but are lagging in their ESG score due to, for example, a relatively low level of disclosure. The ESG team and the Equity portfolio management team are jointly responsible for managing the integrated strategy. For more, please see following questions in this report.

LEI 02. Type of ESG information used in investment decision

02.1. Indicate what ESG information you use in your ESG incorporation strategies and who provides this information.

Type of ESG information

Indicate who provides this information  

Indicate who provides this information 

Indicate who provides this information 

Indicate who provides this information 

Indicate who provides this information 

Indicate who provides this information 

02.2. Indicate whether you incentivise brokers to provide ESG research.

02.3. Describe how you incentivise brokers.

ESG is a component of our broker evaluation and research buying processes (as performed by the Equity portfolio management team) which determines the allocation of commissions to brokers and where we will buy our external research. In 2014 we also determined a set of key ESG issues and shared these with the sell-side as suggestions for sell-side research topics as well as agenda topics in meetings with companies. Based on the added value of their research and the corporate meetings arranged, as well as their overall ESG score our brokers are ESG-scored at the end of each year. The overall ESG score is an integral factor in the overall broker score which determines the overall allocation of commissions to brokers.

02.4. Additional information. [Optional]

ACTIAM uses multiple specialised external data providers as a supplement to its own in-house research. For both screening and integration, we use all the above-mentioned sources.

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

03.1. Indicate whether your organisation has a process through which information derived from ESG engagement and/or (proxy) voting activities is made available for use in investment decision-making.

03.2. Additional information. [Optional]

ESG information derived from engagement and voting processes is provided to the ACTIAM ESG Committee, which meets on a quarterly basis and decides on the eligibility of investments. This decision and policy making body comprises four members: the CEO, performing the role of Chair; the CIO; the Head of Fund Management and Head of the ESG Research team; and an external expert who is a Professor of Ethics.
Additionally, both engagement and proxy voting information is shared with investment decision-makers through an internal dashboard, as well as raw data files. The dashboard is updated every quarter with the latest engagement developments and every half year to reflect outcomes of voting. 

(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


Based on data from our external data providers we perform a screening every quarter, in line with ACTIAM's Sustainable Investment Policy (including both Fundamental Investment Principles and Fundamental Material Drivers), which incorporate Environmental, Social and Governance Issues. We exclude several products and activities, for instance nuclear weapons or riverine tailings disposal. Furthermore, a sector-based score is integrated into the final ESG score, which downgrades companies that are active in certain sectors, such as the oil & gas sector. An analyst score (positive or negative) can also be given and applied by the ESG team.

Screened by


Companies that deliver sustainable goods or services, with particularly positive impacts on focus themes such as climate, land and water will receive an upgrade in their ESG score, based on the thematic overlay in the actively managed fund strategies.
Furthermore, given the varying degree of sustainability among different sectors, ACTIAM has developed sector scores into its ESG scoring methodology. Likewise to the negative/exclusionary screening approach, the ESG team can add a positive analyst score to upgrade companies.

These various (positive) screening methodologies result in higher ESG Scores for relevant individual companies.

Lastly, the mandates of our actively managed fund strategies stipulate optimising financial returns in combination with high portfolio ESG-scores relative to its benchmarks.

Screened by

          Please check the list of other international mechanisms we consult as an appendix to our Fundamental Investment Principles on our website:


ACTIAM applies a norms-based screening to all its investments, including passive funds, in which a series of relevant regulation and international norms apply to several topics. For more information, please see our Fundamental Investment Principles for both companies and sovereigns (, as well as the current exclusion lists (;

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

Screening criteria, which form important part of ACTIAM's Sustainable Investment Policy, are researched and proposed by the in-house ESG team. Changes to our screening criteria first have to be approved by the ESG-Committee, which consists of the CEO, CIO, the Sustainability Director and an independent ethics professor. In addition, these changes are discussed with our clients and beneficiaries. The ACTIAM ESG Committee meets on a quarterly basis and decides on the eligibility of investments and any revisions of the sustainability Policy.

Any changes and newly excluded companies are communicated on our website and in our quarterly ESG report which is published on our website and is sent to our clients. Furthermore, changes made in the past year are described in the annual report and an overview of policy updates is given. 

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.

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]

The internal research that builds our ESG screens is reviewed as an ongoing process.

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.

          Our external accountant also verifies our processes.

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

ACTIAM's governance is organised according to the 'three lines of defence'- model. The first line (portfolio management and the ESG research team) is the risk owner and responsible for first line risk controls. ESG criteria is integrated into mandates and underlying agreements with the clients. Mandate restrictions are monitored automatically by the mandate compliance department (the 'second line') on a continuous basis. In the event of a breach, the second line manager will investigate the cause of the breach as soon as the breach is discovered. In case of a passive breach (caused by external factors as f.i. market moves), portfolio management will realign the portfolio to the permitted bandwidth. In case of an active breach (internal factors, like f.i. an excluded security is accidentally purchased), portfolio management must sell the security immediately. The client will be informed about the event and will be compensated according to ACTIAM's compensation policy to the extent any losses have arisen. Any profits remain with the client. 

06.3. Additional information. [Optional]

In case a breach of screening criteria occurs due to a corporate action (e.g. merger, acquisition), the security will be sold when the corporate action is physically settled.

(B) Implementation: Thematic

LEI 07. Types of sustainability thematic funds/mandates

07.1. Indicate the type of sustainability thematic funds or mandates your organisation manages.

07.2. Describe your organisation’s processes relating to sustainability themed funds. [Optional]

In our sustainably themed funds (our actively managed fund strategies), a combination of environmental and social themes is applied. The focus is on selecting companies that respect the planetary boundaries and that positively contribute to any of the Sustainable Development Goals without compromising on any of the other SDGs. This not only includes environmental sustainability themes such as climate change, water, and land, but also looks at social and human capital development and business ethics. ACTIAM identifies companies that contribute negatively and positively to these themes. Only those that contribute positively are allowed in the sustainably themed actively managed fund strategies. In addition, the positive contributors receive an upgrade in their ESG score, thereby increasing the likelihood of being selected for investment.

(C) Implementation: Integration of ESG factors

LEI 08. Review ESG issues while researching companies/sectors

08.1. Indicate the proportion of actively managed listed equity portfolios where E, S and G factors are systematically researched as part of your investment analysis.

ESG issues

Proportion impacted by analysis




Corporate Governance

Corporate Governance

08.2. Additional information. [Optional]

LEI 09. Processes to ensure integration is based on robust analysis

09.1. Indicate which processes your organisation uses to ensure ESG integration is based on robust analysis.

09.2. Indicate the proportion of your actively managed listed equity portfolio that is subject to comprehensive ESG research as part your integration strategy.

09.3. Indicate how frequently third party ESG ratings that inform your ESG integration strategy are updated.

09.4. Indicate how frequently you review internal research that builds your ESG integration strategy.

09.5. Describe how ESG information is held and used by your portfolio managers.

09.6. Additional information. [Optional]

LEI 09.4 - The review of our internal research supporting our ESG integration strategy is an ongoing process.

LEI 10. Aspects of analysis ESG information is integrated into

New selection options have been added to this indicator. Please review your prefilled responses carefully.

10.1. Indicate which aspects of investment analysis you integrate material ESG information into.

Proportion of actively managed listed equity exposed to investment analysis

Proportion of actively managed listed equity exposed to investment analysis

Proportion of actively managed listed equity exposed to investment analysis

Proportion of actively managed listed equity exposed to investment analysis

Proportion of actively managed listed equity exposed to investment analysis

Proportion of actively managed listed equity exposed to investment analysis

10.2. Indicate which methods are part of your process to integrate ESG information into fair value/fundamental analysis.

          We apply our ESG score in the portfolio construction setting as one input in our overall company scores.

10.3. Describe how you integrate ESG information into portfolio weighting.

We apply our ESG score in the portfolio construction setting as one input in our overall company scores.

10.4. Describe the methods you have used to adjust the income forecast/valuation tool.

We apply our ESG score in the portfolio construction setting as one input in our overall company scores, in which the ESG score has a fixed weight. 

10.5. Describe how you apply sensitivity and /or scenario analysis to security valuations.

We integrate sensitivity and scenario analysis into our ESG scoring model. This ESG score is part of the portfolio construction and is one input in our overall company scores. 

10.6. Additional information. [OPTIONAL]