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Nuveen, a TIAA Company

PRI reporting framework 2020

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You are in Direct - Listed Equity Incorporation » ESG incorporation in actively managed listed equities » Implementation processes

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%
5.302 %
Percentage of active listed equity to which the strategy is applied — you may estimate +/- 5%
20.54 %
Percentage of active listed equity to which the strategy is applied — you may estimate +/- 5%
74.062 %
Percentage of active listed equity to which the strategy is applied — you may estimate +/- 5%
0.095 %
Percentage of active listed equity to which the strategy is applied — you may estimate +/- 5%
0.001 %
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.

We believe that incorporating ESG factors into investment research, due diligence, portfolio construction and ongoing monitoring allows us to improve financial performance, mitigate risk, and create new investment opportunities.At Nuveen, responsible investing is an integral part of our history and our future as we believe that it can help provide enduring benefits for our clients and our communities.The ability to accurately forecast long-term industry and entity-specific trends increasingly requires an understanding of relevant ESG factors and their potential financial impacts. Through ESG integration, we seek to expand our investment research and portfolio construction lens to incorporate ESG risks and opportunities that can inform investment decision-making beyond traditional financial analysis.

ESG integration within listed equities is implemented using centralized frameworks, insights and processes developed at the enterprise level by Nuveen's Responsible Investing (RI) Team which are then tailored to meet the specific investment approaches and needs of our investment specialists. RI team support activities include training investment management teams on material ESG issues by sector, facilitating access to and uptake of quality ESG data housed in Nuveen's RI Data Platform (RIDP) and developing proprietary frameworks and insights specific to asset class and investment process. Public equity investment specialists supported by the RI team include: TIAA Investments, Nuveen Asset Management, Winslow Capital Management, NWQ, and Santa Barbara Asset Management.

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

Each Nuveen investment specialist undertakes an approach to responsible investing that best aligns with their investment process, underlying assets and their unique strategy(ies) for pursuing competitive risk-adjusted returns.

Across all equity specialists, our ESG integration activities generally focus on building out the financial relevance of material ESG themes and factors, and facilitating systematic access to and uptake of quality ESG information in the investment process. This involves engaging directly with our analysts and portfolio managers on ESG issues, facilitating our investment teams' access to relevant data and tools, and providing guidance on emerging ESG themes across industries. Continuing improvements in the quality, disclosure and accessibility of ESG information have enabled greater applications for incorporation into investment portfolios. In a mutually reinforcing manner, market related insights gained through engagement provide additional information for decision-making at the security, sector and portfolio management levels. Further details are elaborated within specific questions.

Throughout this module, our responses reflect the practices implemented within the majority of our equity assets under management. Activities specific to an investment specialist may be additionally described in the descriptive sections and noted as such.

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 

          Engagement and Proxy Voting insights

Indicate who provides this information 

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

02.4. Additional information. [Optional]

Our overall goal is to integrate ESG information systematically so that it can be leveraged across a range of investment strategies. Nuveen's primary source of ESG information is our proprietary Responsible Investing Data Platform (RIDP), which provides all investment teams access to high quality ESG data and ratings and facilitates deeper, more actionable ESG analysis. This information is used to enhance investment processes. In addition, equity research analysts may also directly source ESG information from company reports, sell-side research, NGO reports, and direct discussions with a company's senior management as part due diligence for potential and existing investments. Other inputs include materials from, or discussions with, regulatory agencies and independent research providers with sector expertise. The RI team may also conduct additional research (including company, sector, thematic and issue research) as part of on-going due diligence to substantiate the research we receive.

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]

The RI and Global Equity teams collaborate on ESG integration, engagement and proxy voting issues concerning significant current (or potential) public equity investments. This joint collaboration is an important input into the investment process as a means to raise awareness of potential ESG issues associated with a particular investment. Broader engagement themes (for example, board effectiveness, shareholder rights, climate change, human capital management and human rights) are also shared and discussed with the Equities team which may highlight potential areas of concern during the investment process. By employing an end to end system of integration, engagement and voting, we will strengthen the mutually reinforcing links between these topics in a more connected and synergistic manner.

(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


The negative exclusionary screens selected apply in the following specific instances:

Country/geographic region:

All public market securities within the TIAA-CREF Funds Complex (CREF, TIAA-CREF Funds, TIAA Separate Account VA-1 and TIAA-CREF Life Funds) and the General Account avoid investment in the following four oil and gas companies that continue to have ties to Sudan:

  • China Petroleum& Chemical Corporation (Sinopec)
  • Kunlun Energy (formerly CNPC Hong Kong Oil)
  • Natural Gas Corporation
  • PetroChina


In addition, ESG products at Nuveen are subject to environmental, social and governance ("ESG") criteria. Certain of these funds will not invest in companies significantly involved in business activities such as the production of alcohol, tobacco, military weapons, firearms, nuclear power and gambling products and services.

Screened by


Positive/best-in-class screening apply to Nuveen's ESG products, which are subject to certain environmental, social and governance ("ESG") criteria. The ESG evaluation process is conducted on an industry-specific basis and involves the identification of key performance indicators, which are given more relative weight. The evaluation process favors companies with leadership in ESG performance relative to their peers. Typically, environmental assessment categories include climate change, natural resource use, waste management and environmental opportunities. Social evaluation categories include human capital, product safety and social opportunities. Governance assessment categories include corporate governance, business ethics. Concerns in one area do not automatically eliminate an issuer from being an eligible investment. When ESG concerns exist, the evaluation process gives careful consideration to how companies address the risks and opportunities they face in the context of their industry and relative to their peers.

Screened by

          In addition to the above, a number of other norms and conventions are addressed related to ESG practices (e.g. EITI, Global Sullivan, etc ).


Norms-based screening applies to Nuveen's ESG products, which are subject to certain environmental, social and governance ("ESG") criteria.The ESG evaluation process utilized within those strategies considers a company's involvement in ESG-related controversies, including violations of international norms and conventions such as those stated above, and how well companies adhere to international norms and principles.

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

Changes are communicated to clients and beneficiaries via the ESG-product prospectus and in other company communications.

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]

We source screening criteria from credible third party ESG research providers, as well as conduct our own internal research. The RI team conducts thorough due diligence on an at least an annual basis on any ESG research or providers used at the organization. Our process for evaluating potential ESG research partners is robust, and includes considerations of analytical capabilities, sources of data, track record and history in ESG research, company coverage, and approach to ESG performance evaluation, among other factors.

In addition, for the Social Choice ESG products, the firm's recommended approach to implementing the Fund's ESG criteria and ESG research partner are annually reviewed and approved by the Fund's Independent Board of Trustees.

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.

Explicit restrictions in the trading system prevent the execution of Sudan names on the restricted list for applicable strategies.

Multiple checks also prevent the trading of names that do not meet minimum ESG criteria for inclusion in our ESG-focused funds. However, an ineligible name could be held in the case where (1) a name previously held in the funds no longer met the minimum ESG criteria necessary for these portfolios or (2) a corporate action. In both cases, the portfolio manager will put the name up for sale. The trading desk will sell this name in an orderly fashion, to minimize market impact.

06.3. Additional information. [Optional]

(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]

Nuveen offers low carbon ESG products that combine thematic criteria related to current and future carbon emissions alongside comprehensive ESG leadership.

These products give special consideration to environmental, social, and governance factors by favoring companies with leadership in ESG performance relative to their peers. In addition, they favor companies that demonstrate leadership in managing and mitigating current carbon emissions and potential future emissions resulting from fossil fuel reserves. Nuveen's low carbon ESG products include the Social Choice Low Carbon Equity Fund, an actively managed Low Carbon Value SMA, and a suite of domestic and international ESG ETFs.

(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]

In 2018 we launched the Nuveen RI Data Platform to capture, curate and govern ESG information and provide greater access to ESG data, research, and tools for our investment teams to incorporate into investment decision-making. We also collaborated to strengthen our investment colleagues' convictions on material ESG themes and factors through development of proprietary ESG materiality frameworks.

The RI Data Platform provides all teams access to a standardized set of ESG data and information for use in investment decision-making. In addition, certain affiliates have developed explicit processes for capturing and documenting internal ESG analysis and conviction to better integrate ESG information into investment decision-making:

TIAA Investments and Nuveen Asset Management: Analysts assign internal ESG ratings to each name in active coverage universe based on material ESG analysis. Analysis is based on data in the RI Data Platform alongside analyst own proprietary views and research. These internal ESG ratings are stored in central repositories and made available to all portfolio managers within that investment team. Additional processes will be developed in 2020 to integrate ESG information further into existing portfolio and risk reporting tools for portfolio managers.

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.

          See Additional Information

09.6. Additional information. [Optional]

When material to an investment thesis, key issues are thoroughly investigated and reviewed across the analyst and portfolio management teams. In addition, proprietary portfolio ESG reporting capabilities are being developed to provide our portfolio managers with greater insights into the ESG attributes of their holdings. Companies with potential issues can be vetted with the analyst team along with the RI team to better understand the concerns and develop a response if appropriate. The combination of bottom up and top down incorporation of ESG factors is an important and growing part of our investment 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.

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

Much of the integration of ESG information occurs at the company and sector level where analysts attempt to capture their impact to financial models and valuations over the long term. Based on value drivers related to material ESG concerns or ability to capitalize on ESG opportunities, holdings may be bought, avoided, overweighted or underweighted in the portfolio. Illustrative examples provided in response to LEI 13.

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

Broad concerns relating to ESG factors can be expressed as risk factors which may reduce an investments fair value and increase the potential downside risk associated with an investment. This would occur via a higher discount rate used to value future projected cash flows given the uncertainty and potential for future liabilities. Known factors such as increased expense associated with regulatory requirements or changing consumer preferences are explicitly captured when modelling the estimated future cash flows of a company. ESG considerations can also represent opportunities. Companies positively aligned with secular ESG trends (for example, clean energy, data security, human capital management and health/ wellness) may experience above industry average growth and profitability, which we endeavour to explicitly capture in the relevant sector analyst's company model and valuation.

10.6. Additional information. [OPTIONAL]

The percentages selected above represent aggregated responses across Nuveen's public equity AUM. Not all responses selected apply to every specialist. Each specialist takes a unique investment approach to pursuing competitive risk-adjusted returns on behalf of its clients and may differ depending on company type, underlying asset or applicable regulation, including fiduciary duties and obligations.