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First Sentier Investors (including First State Investments)

PRI reporting framework 2020

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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


We exclude cluster munition, landmine and cigarettes/ tobacco product manufacturers. 

We also exclude sanctioned and very high risk countries, companies domiciled in those countries and individuals. We are also able to implement exclusionary screens based on specific criteria requested via individual client mandates.

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

For cluster munitions and land mines the criteria were established under our cluster munitions policy which was approved by the Global Responsible Investment Steering Group. The companies captured by the policy are reviewed annually with any changes reported in our annual responsible investment and stewardship report. 

Effective 1 May 2019, our formal group wide policy excludes investment in manufacturers of cigarettes and tobacco products

For sanctioned and high risk countries we enforce country level restrictions based on the constituents of the Australian Department of Foreign Affairs and Trade (DFAT) Sanctioned Countries List and similar lists issued by Governments in other jurisdictions where our funds are domiciled. The constituents on each system are regularly reviewed and updated.

Any potential investments in companies domiciled in these countries would be rigorously screened to ensure that there is no association with any sanctioned individual, entity or regime prior to investment. No investment is possible in companies domiciled in any country on the DFAT list without clearance from Investment Compliance personnel as the system controls do not allow it.

In addition our controls include screens for any potential investment from a country deemed to be ‘very high risk’ in relation to politically exposed persons, sanctions and ultimate beneficial ownership controls. The scope of this framework will be wider than the sanctioned countries list and the countries deemed to be ‘very high risk’ are updated on a regular basis.

Please also see the following link for more information:

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]

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.

          pre and post trade compliance reviews

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

Pre and post trade compliance systems prevent investment in excluded companies. Any breaches are managed through the investment compliance processes. Provided screening lists are coded within both Aladdin and CRIMS. Trade activity is considered against these lists and exemptions are flagged (both on a pre and post trade basis).

If an exemption is flagged Investment Compliance investigates the circumstances, contacting Portfolio Managers and other stakeholders where appropriate.

Any valid breaches of restrictions will be escalated to the Risk team who enter the details within a Risk Management System, which tracks resolutions and any required preventative measures.

06.3. Additional information. [Optional]