Internal Controls The internal control plan includes ESG & labels related verifications processes.
The second level of control, permanent and a posteriori of operations, is carried out by the Internal Control team. The main task of this team is to monitor compliance with procedures and the quality of the tools put in place. The controls assess the effectiveness of the first-level controls.. Internal Auditing Periodic control is carried out by the internal audit department as part of an audit plan defined by the Audit Committee at Group level. This plan includes ESG controls. Portfolio management & ESG controls With ESG data fully integrated in our operating systems, ESG is monitored on a continuous basis. Our entire value chain (teams in charge of compliance, risk management, portfolio management and reporting) is covered by the same ESG data flow (updated quarterly), which allows us to monitor daily and in real time ESG constraints and requirements coded into systems by the Compliance team (with a common exclusion framework) and the Risk Management team (product-specific ESG requirements). The investment management teams have access to ESG data and can follow their sustainability constraints on a daily basis via their Bloomberg portal. Allocations within portfolios and their impacts on sustainability requirements are thus monitored in real time by fund managers. These mechanisms complement the investment committees, which meet regularly to discuss in greater depth the ESG risks and challenges of a specific issuer and/or portfolio. In order to monitor changes in ESG ratings and controversies, we have set up automatic daily and weekly notifications from the MSCI ESG Research platform. The investment teams monitor newsflow daily and disseminate relevant information each day during the morning meeting. In case of a major event, our controversy committee meets in the days following its occurrence. Our process for managing controversies is detailed in the engagement and principal adverse impact policies. ESG reports are produced monthly with the same ESG data flow. They are reviewed and validated on by the investment teams
Rothschild & Co Asset Management Europe | ESG policy
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