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Blue Harbour Group, L.P. (Delisted)

PRI reporting framework 2020

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%
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.

Blue Harbour owns a concentrated portfolio of small and mid-cap companies, often owning between 5% and 10% of the companies in which we invest. All investments are reviewed in the context of our proprietary Blue Harbour ESG Framework, where we consider ESG risks and opportunities specific to each investment prospect. As part of our diligence process, the investment team directly engages with company operating and Board leadership on the key ESG issues relevant to their company. Going beyond only negative screening, we analyze both the scope of ESG issues and the company’s relative mitigation capacity to reduce meaningful risk. And, as lead shareholder, Blue Harbour regularly monitors our companies’ ESG profile and expects to play a role in effecting change when appropriate.  

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

We use screening on a limited basis to remove certian investments that we do not have an attractive risk profile given our view of ESG risks.  In the remaining universe of companies, we then use integration to both conduct our diligence and pursue our ongoing engagement with the company on ESG and other issues.

LEI 02. Type of ESG information used in investment decision (Private)

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

(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


Although Blue Harbour goes beyond just negative screening to analyze both the scope of ESG issues and the company’s relative mitigation capacity to reduce meaningful risk, we will avoid investments in certain stocks and industries according to defined guidelines. The following is the current restricted list of industries and areas which Blue Harbour will not invest: civilian munitions, coal mining, predatory lending, private prisons and tobacco.

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

Blue Harbour evaluates the industries in which it will not invest on a continuous basis and discusses such issues with clients regularly.

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.

          Screening is a small part of the ESG process and identifying the businesses in which a company participates is relatively straightforward.

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.

05.5. Additional information. [Optional]

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

(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]

We keep track of the most material factors impacting each of our portfolio companies.  We believe aspects of governance are critical to any investment, for example, compensation and the structure of decision making at the board level.  We have asked all of our companies about human capital management and other factors typically classifiied as social.  We have standard metrics that we look at like turnover, but also ask about company specific factors as appropriate, for example, looking at how companies recruit and retain certian types of vital personnel.  We do analyze our companies for enviromental factors, but many of them have relatively low tangible asset bases which makes their environmental risk factors relatively smaller versus the total universe of public companies.

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.

          Full integration into the investment process. We do not utilize a separate staff for RI.

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

09.4. 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 10. Aspects of analysis ESG information is integrated into (Private)