ISR as an investment discipline
In a regulated European context, ISR credibility depends on repeatable decisions, clear criteria, and the ability to evidence how ESG considerations are used.
Definition & scope
We use “ISR” to describe a structured approach to integrating environmental, social, and governance considerations into an investment process, in a way that is definable and auditable. The focus is on how decisions are made and monitored, not on broad moral positioning.
Regulatory mindset: where SFDR classifications or French market practices affect terminology and disclosures, communication must remain consistent with the product documentation and applicable reporting.
ISR Methodology Framework
The framework below is intentionally “document-like”: four blocks, each with inputs, decision logic, and outputs. It is meant to match the way a due diligence team reads an investment process.
| Inputs | Issuer documentation, third‑party data where relevant, governance signals, controversy screening, sector and norms references. |
|---|---|
| Output | Structured criteria set and a documented interpretation for the investment universe. |
| Decision logic | Explicit checks, recorded rationale, and clear thresholds for inclusion / watchlist / exclusion outcomes. |
|---|---|
| Output | Documented assessment suitable for partner review and internal follow‑up. |
| Cadence | Periodic review plus event‑driven review when a controversy or material change emerges. |
|---|---|
| Output | Updated status (maintain / engage / restrict / exit) with traceable rationale. |
| Scope | Sectoral constraints, norms‑based exclusions, and escalation outcomes for severe controversies. |
|---|---|
| Output | A clear “do not own” list and supporting rationale that can be audited against holdings and reporting. |
Selection discipline
Selection is not a one‑time classification. It is a controlled decision that should be reproducible across time and reviewers. The goal is to avoid “label drift” (changing the meaning of ISR through implicit assumptions).
| Eligibility | Defined investment universe and minimum governance expectations (“sound governance” as a baseline, not a marketing claim). |
|---|---|
| Assessment | Issuer‑level ESG considerations integrated into the review with documented rationale and sources. |
| Decision record | Outcome recorded with date, reviewer, and conditions (e.g., watchlist triggers, engagement topics). |
Monitoring & controversies
Monitoring is where ISR becomes credible. A process that cannot respond to controversies, data revisions, or governance deterioration becomes performative.
Controversy escalation
A controversy is treated as an operational signal: review, document, decide, and communicate impacts to stakeholders where relevant.
Cadence & stability
Regular review reduces discretionary drift and improves comparability across reporting periods.
Exclusions vs engagement
Exclusions and engagement serve different functions. Exclusions define non‑negotiable boundaries; engagement is a structured way to address specific governance or sustainability topics. Both require traceability to avoid “story‑based” ISR.
| Exclusions | Controls. Clear boundaries. Applied consistently. Auditable against holdings. |
|---|---|
| Engagement | Process. Defined objectives, time horizon, and escalation (including exit) if progress is not satisfactory. |
Transparency & reporting
Transparency means that a third party can understand the decision logic without relying on tone. Where relevant, disclosures must remain aligned with the product’s regulatory documentation and the applicable reporting framework.
What signals seriousness: accessible policies, stable vocabulary, and a clear distinction between definitions (what we mean) and reporting (what we can evidence).