A portfolio manager may need to adopt a more appropriate ESG benchmark rather than a broad

market benchmark if the degree of exclusions results in high active share and high tracking error.

High active share indicates that the portfolio significantly deviates from the benchmark, while high

tracking error measures the volatility of these deviations.

High Active Share: Excluding a significant number of securities from the investment universe to align

with ESG criteria can lead to a portfolio that is very different from the broad market benchmark. This

high active share reflects the extent to which the portfolio composition differs from the benchmark.

High Tracking Error: The deviations from the benchmark can lead to high tracking error, indicating the

portfolio's performance can vary significantly from the benchmark. This variability can be a result of

the different risk and return characteristics of the excluded securities.

Appropriate ESG Benchmark: To accurately measure performance and risk, it is essential to use a

benchmark that reflects the ESG criteria applied in the portfolio. An ESG-specific benchmark would

provide a more relevant comparison and better align with the investment strategy.

Reference:

MSCI ESG Ratings Methodology (2022) - Explains the importance of selecting appropriate

benchmarks for ESG-focused portfolios to ensure alignment with investment objectives​​.

ESG-Ratings-Methodology-Exec-Summary (2022) - Discusses the impact of exclusions on portfolio

metrics such as active share and tracking error, and the need for suitable ESG benchmarks​​.

Carbon footprinting allows emissions data to be aggregated across geographies, supply chains, and

business units,providing a holistic view of carbon impact.

It is typically backward-looking rather than forward-looking (A).

There are multiple carbon accounting methodologies (B), but they are not always standardized.

Reference:

Greenhouse Gas (GHG) Protocol Carbon Accounting Framework

CFA Institute ESG Carbon Footprint Measurement Guide

UNFCCC Carbon Accounting & Disclosure Standards

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Germany is most likely to use a two-tier board structure. Here’s a detailed explanation:

Two-Tier Board Structure: A two-tier board structure consists of a management board and a

supervisory board. The management board is responsible for day-to-day operations, while the

supervisory board oversees the management board and represents the interests of shareholders.

Germany’s Corporate Governance: Germany is well-known for its two-tier board system, which is a

legal requirement for many large companies, especially those listed on the stock exchange. The

supervisory board includes employee representatives, which is a unique feature of the German

system.

Comparison with Other Countries:

USA: The USA typically uses a single-tier board structure where a single board of directors oversees

the company’s management. This board often includes a mix of executive and non-executive

directors.

Japan: Japan has traditionally used a single-tier board structure but has been increasingly

incorporating elements of a two-tier system, such as appointing outside directors. However, it does

not predominantly use a two-tier structure like Germany.

CFA ESG Investing Reference:

The CFA Institute highlights that Germany’s corporate governance is characterized by the two-tier

board system, which separates management and supervisory functions (CFA Institute, 2020).

This structure aims to improve oversight and accountability, aligning with Germany’s emphasis on

stakeholder engagement and corporate responsibility​​​​.

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Pension trustees mustassess ESG risks in credit ratingswhen selectingfixed-income managers, asESG

factors affect bond pricing, default risk, and credit spreads.

Reference:

UK Pensions & Lifetime Savings Association Stewardship Checklist

Principles for Responsible Investment (PRI) ESG in Fixed Income Guide

CFA Institute Fixed Income ESG Risk Report

Investors constructingnet zero portfoliosoftenoverweight technology stocksbecause:

Tech companies tend to have lower direct carbon emissions (Scope 1 & 2).

Excluding Scope 3 emissions (indirect supply chain emissions) makes tech firms appear even

"greener."

There is no universally accepted (A) carbon netting standard.

Derivatives and short positions (B) remain controversial in ESG investing, with no consensus on

accounting.

Reference:

Net Zero Asset Owners Alliance Portfolio Alignment Report

MSCI ESG Portfolio Construction Guidelines

Principles for Responsible Investment (PRI) Net Zero Investment Framework

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Policy risks are most likely associated with increased environmental standards. Here’s a detailed

explanation:

Definition of Transition Risks: Transition risks refer to the financial risks that result from the transition

to a lower-carbon economy. These can arise from policy changes, legal actions, technology

developments, and market shifts.

Policy Risks and Environmental Standards: Policy risks specifically relate to changes in regulations and

policies aimed at addressing climate change and environmental issues. Increased environmental

standards often involve stricter regulations on emissions, waste management, resource use, and

other environmental impacts.

Impact of Policy Risks: Companies may face increased costs of compliance, the need for new

investments to meet regulatory requirements, and potential fines or sanctions for non-compliance.

These policy changes can significantly affect business operations and financial performance.

Comparison with Other Risks:

Legal Risks: Legal risks involve litigation and legal actions related to environmental damages or

failure to comply with environmental laws. While related, they are distinct from policy risks, which

are driven by regulatory changes.

Technology Risks: Technology risks involve the adoption of new technologies and the potential for

current technologies to become obsolete. While technology plays a role in meeting increased

environmental standards, policy risks are more directly linked to regulatory changes.

CFA ESG Investing Reference:

The CFA Institute explains that policy risks are a significant component of transition risks, particularly

when governments implement stricter environmental standards to combat climate change (CFA

Institute, 2020).

Increased environmental standards often lead to policy risks as companies must adapt to new

regulatory landscapes, making it the most relevant type of transition risk in this context​​​​.

By understanding these risks and their implications, investors can better manage their portfolios in

the face of evolving environmental standards and regulatory changes.

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ESG integration is most developed in corporate bonds, where ESG factorsdirectly affect credit ratings,

risk assessment, and investment decisions.

Sovereign debt (A) ESG integration is growing but less standardized.

Securitized bonds (C) have lower ESG data transparency.

Reference:

MSCI ESG Ratings for Corporate Bonds

Principles for Responsible Investment (PRI) ESG Fixed Income Guide

CFA Institute ESG Integration in Fixed Income

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The European Union's Sustainable Finance Disclosure Regulation (SFDR) requires that the carbon

intensity of a portfolio is measured by accounting for Scope 1, Scope 2, and Scope 3 emissions. This

comprehensive approach ensures that both direct and indirect emissions across the entire value

chain of the companies are considered, providing a more complete picture of the carbon footprint

associated with investments​​​​.

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TheEU Carbon Border Adjustment Mechanism (CBAM)is acarbon pricing tool that ensures imports of

carbon-intensive goods face similar emissions costs as EU-produced goods.

This prevents carbon leakage, where companies move production to countries with weaker climate

regulations.

It is not a revision of energy taxation (A).

While CBAM supports sustainability goals (C), its main purpose is to adjust carbon pricing on imports.

Reference:

European Commission Carbon Border Adjustment Mechanism (CBAM) Overview

CFA Institute ESG & Carbon Pricing Analysis

UNFCCC Climate Policy & Trade Regulations

Governments and corporations can take steps to internalize externalities,such ascarbon pricing,

emissions regulations, or corporate sustainability initiatives.

Externalities (A) are not always reflected in market prices.

Negative externalities mean societal costs exceed private costs, not the other way around (B).

Reference:

OECD Report on Environmental Externalities & Market Failures

CFA Institute ESG Impact Measurement Guide

UNFCCC Climate Policy & Externalities Report

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