Governance & compliance
For an ISR-oriented asset management activity, governance is a control system: it defines accountability, reduces discretion, and supports consistent disclosure.
Governance Snapshot
A compact view of decision flow and control layers. It is intentionally framed as a “map” rather than a narrative.
Product documentation, issuer information, ESG data where relevant, controversy signals, and partner requirements.
Documented judgement, explicit thresholds, and recorded outcomes (maintain / engage / restrict / exit).
Oversight routines, conflict management, and record keeping that allow auditability and consistent reporting.
| Responsibility layers | Operational ownership, second‑level controls, and escalation paths for incidents and controversies. |
|---|---|
| Control mechanisms | Defined review cadence, documented exceptions, and a preference for stable vocabulary aligned with disclosure expectations. |
Decision structure
Institutional stakeholders typically evaluate governance through clarity: who decides, who reviews, and how disagreements are handled. The objective is not speed; it is consistency and traceability.
| Decision ownership | Decisions are recorded with responsibility attribution (who decided, when, based on which evidence). |
|---|---|
| Escalation | Defined escalation steps when a controversy or material change occurs. |
| Conflicts | Conflicts of interest are treated as governance events requiring documentation and mitigation. |
Oversight & controls
Oversight reduces discretionary drift over time. Controls are only useful if they are applied consistently and leave a record that can be reviewed by a third party.
Control considerations
Governance supports consistency across financial, operational, and communication dimensions. For responsible investment, clarity of claims and the ability to evidence methodology are central.
| Operational consistency | Clear routines, consistent documentation, and sufficient escalation paths. |
|---|---|
| Communication discipline | Precise ESG language, evidence-based statements, and alignment between communication and disclosures. |
| Regulatory alignment | Stable vocabulary and documented processes consistent with regulatory documentation and reporting expectations. |
Regulatory mindset
European sustainable finance frameworks have increased expectations around disclosure and precision. A regulatory mindset favors conservative language and traceable decisions over promotional statements.
Communication principle: if a statement cannot be evidenced through documentation or reporting, it should not be presented as fact.
Record keeping
Record keeping is the bridge between “we have a process” and “our process can be reviewed”. It enables stable partner relationships and supports consistent reporting.
| What is recorded | Decision outcomes, evidence sources, review dates, changes to criteria, and controversy escalations. |
|---|---|
| Why it matters | Auditability, consistency across time, and reliable responses to due diligence requests. |