The tobacco screen is monitored by the custodian and is hard wired into their systems. So, if a breach occurred and a screened company was held, the custodian would be notified and they in turn would notify us.
For our Sustainable options, the list of blacklisted (or whitelisted) stocks is loaded into our trading system and will alert and prevent the trader from executing a trade on a blacklisted stock.
We would seek to identify why the the breach occurred and identify how to prevent any similar breach from occurring, and would remedy where appropriate.
We would also raise the issue with the fund manager in question as they would have committed a breach of the investment management agreement, and if relevant seek remediation should any losses to the fund have arisen
The funds Sustainable Options will be audited as part of the RIAA certification process.