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Gresham House plc

PRI reporting framework 2020

Export Public Responses

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


For our positive screening, we have undertaken ESG training for our investment managers such that they understand what constitutes best in class ESG performance in each of the key ESG themes. We recognise, though, that as an active investor we are not always looking for best in class performance at the outset but instead for the potential to drive quality performance which will be critical to value creation.

This year we have taken steps to formalise our approach such that it is rigorous and documented by developing our bespoke asset class tools. These contain questions on the various ESG themes within our SI Framework, and the sub-topics which hang off these themes. The questions are backed up by a series of guidance notes which provide detailed context on what would be considered as best in class for various sectors and activities, including how these can vary on a geographical basis.

This will allow our team to screen for risks and opportunities around best in class performance quickly and systematically. We note, though, that as a generalist investor, we have to rely on a wide-range of information and therefore our internal capabilities are critical to the application of these principles.

Screened by


Please see above.

Screened by

          Sustainability Framework of the Sustainability Accounting Standards Board


Where utilised, the screen examines topics within the following framework, which maps closely onto the Global Compact and the ILO Conventions: Environment: Exposure to and management of Carbon, Emissions & Climate Change; Pollution & Waste; Natural Resources and input materials; Social: H&S risks and management; Employment risks and practices; Marketplace responsibility, inc product risks; Supply Chain Sustainability, inc possible child and forced labour and environmental degradation; Community, inc impacts and indigenous rights violation; Governance:  Board structure and processes for probity; Business ethics, inc anti-corruption; Risk and Compliance; Commitment to Sustainable Business.

Use of the tool creates a graded pre-investment risk-opportunity profile that is used;

  • To decide whether to invest or not on the basis of what is known
  • To guide our influence on the asset management team over the lifetime of the investment with regard to material ESG matters
  • To guide monitoring and reporting of material ESG matters.

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

Clients and key counterparties would be informed of any substantial changes to our screening protocols, as soon as the change is implemented. Any more minor changes are brought to the attention of our clients/beneficiaries by:

  • Quarterly Board Meetings
  • Regular face to face interactions within periodic client meetings
  • Updates during the AGM

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.

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

05.5. Additional information. [Optional]

Our investments have always been subject to a pre-investment due diligence review which incorporates ESG issues, but this activity has been strengthened during 2019, as described below. Where ESG issues or potential issues are identified, and considered likely to be material in the context of our proposed investment, we undertake comprehensive due diligence to understand both the risk and, wherever possible, how to manage or mitigate it during the lifetime of our investment.

We believe that the work we have undertaken this year has helped mature our processes in line with the progressive Responsible Investment agenda and to a standard which will give us a future-proof, comprehensive and robust approach. This predominantly takes the form of a structured asset management deal tool, designed to support implementation of our asset class specific Public Equity Sustainable Investing Policy, and our company-wide thematic Sustainable Investment framework.

The tool has been developed in close cooperation with our external ESG advisers, and incorporates as series of prompts and checks as well as a set of focused questions designed to proactively identify areas of potential concern. It contains links to content-rich guidance which is based on both global and local ESG risks, trends, guidance and considerations. This will be updated on a periodic basis as and when required.

Our team is encouraged to undertake asset-specific research as needed on potentially material ESG risks (and opportunities where relevant) as part of the intelligence gathering aspect of the tool. This could include industry papers, guidance, guidelines, etc and/or discussions with management as needed. Where necessary, we would rely on the support and guidance of external experts to aid our research.

We keep a continuous watching brief on a number of key information sources to scan for new and emerging ESG issues:

  • The mainstream media including consumer trends, public interest and campaigns 
  • The industry press, regulation, guidance and guidelines specifically associated with sustainable investing
  • UN PRI Industry events and webinars
  • Periodic topic-specific updates from our external ESG advisors, backed up by refresher training.

Our team has been trained in the use of our internal tool by external ESG experts.     

We are also in the process of undertaking a retrospective documented review of our existing portfolio to identify any material ESG risks which pre-date the adoption of our Sustainable Investing Policy and principles. 


LEI 06. Processes to ensure fund criteria are not breached (Private)