- Before
- Works the re-test from vendor scores and revenue bands, and reads annual reports by hand — mostly the English ones — for the names a vendor flags.
- Now
- Opens each item with the issuer's segment note beside the English, three readings and all 40 policy results, asks the agents, and proposes with the evidence attached.
One ESG exclusion screening re-test, from the overnight run to a blocked order
Quillfield Capital runs 286 funds, ETFs, model portfolios and client mandates on 40 exclusion policies. Its Q4 2026 re-test ran overnight on Monday. It is Wednesday, October 21, 2026, 2:40 p.m. in New York. Here is what happens next, screen by screen, in the working solution.
- 012:40 p.m.
The agents worked overnight; her next steps are waiting
Ana Ruiz · ESG Screening AnalystAna's home screen shows 69 items with her, 10 list changes awaiting compliance, and 12,184 issuers tested against 40 policies overnight. The agents' thread says what each did since Monday: the Universe agent mapped 41,902 securities from 286 funds and mandates, the Revenue agent read the 3,912 filings published since last quarter, and the Policy agent finished 487,360 tests — 11,402 issuers clear, 640 unchanged on the list, 142 for a person. First on her list: Vltavin Energie, where the feed says 8.1% coal and the annual report says 12.4%.
Vendor Check agent: “61 gaps over 2 points between filings and the two feeds; 9 change an outcome. … I escalated them; I did not pick a side.”
- 02The sieve
Every issuer through every rule, every catch with its page
Ana Ruiz · ESG Screening AnalystShe picks P-07 Sustainable funds (US) v4.2 and runs the sieve: 12,184 issuers pour through seven layers and each hangs at the first rule it fails. Under the thermal coal exclusion sit Vltavin Energie at 12.4% ("feed said 8.1% · gap 4.3 pts"), Kestrel Mining at 6.9–10.5% with no thermal split disclosed, Rheinwerk Chemie leaving the list at 0.8%, and Société Minière du Rhône at 0.0%, where the feed misread steelmaking coal. Under controversial weapons hangs Daesan Precision, through a 54.0% subsidiary.
“11,453 issuers pass all 7 rules” · “487,360 tests across all 40 policies”
- 03One click
The revenue share, from the issuer's own segment note
Revenue agentThe evidence opens on the Výroční zpráva 2025, Vltavin's annual report, note 5 on page 148 — the Czech table beside the English. Coal-fired generation CZK 16,437m plus lignite mining CZK 6,210m, of CZK 182,640m: 12.40%, over the 10% limit by 2.40 points. The segments add up to the income statement on page 96, the report was filed April 28, 2026, inside the 18-month limit, and FY2024 was 9.94% — it rose when Vltavin bought the Kladruby lignite plant in July 2024.
The Revenue agent never reports an estimate as reported, and below 90% confidence it asks the analyst.
- 04Page 148
Any figure opens the page it came from
Ana Ruiz · ESG Screening AnalystAna clicks the citation. The page opens with the original Czech on the left and the English, read by the Revenue agent, on the right, with the values the agents used highlighted. She checks the figures in seconds instead of searching a 212-page report.
“The page image and its fingerprint are kept with the decision for seven years.”
- 05Three readings, 40 policies
A 4.3-point gap escalated, every policy tested at once
Vendor Check agent · Policy agentThe filing says 12.4%. The primary feed's 8.1% is an estimate dated March 2025 from FY2023 reporting, before the plant purchase; the second feed's 11.9% nets out internal lignite sales. The Policy agent tests all 40 policies: 4 newly breached (P-07, P-12, P-22, P-31), 6 already exclude it, 30 pass. Three funds hold $51.9M, and an index buy, OMS-7731842 for 85,000 shares, is working in the Global ESG Leaders ETF.
“The Vendor Check agent escalated this instead of picking a source. The decision rests on the issuer's own filing.”
- 06Before she proposes
She asks the agents what waiting would cost
Ana Ruiz · ESG Screening AnalystAna asks why the feed is lower, and the Vendor Check agent explains the old estimate and drafts a challenge to the vendor for her to send. Then she asks what happens if they wait for the next filing. The Policy agent answers that P-07 tests the latest annual report, the half-year report is due September 2027 and is not audited, and waiting would leave $41.8M in a fund that promises investors it excludes this, for up to a year.
Policy agent: “The strategy to leave coal by 2033 is a matter for engagement, not for the screen.”
- 072:52 p.m.
She proposes the exclusion, with the evidence attached
Ana Ruiz · ESG Screening AnalystThe proposal carries the segment note, the reconciliation to the income statement, the three readings and the holdings: 3 funds, $51.9M, a 30-business-day cure window from approval. She picks the reason code "Breach confirmed from issuer filing". It goes to Tom Hale or Naomi Brooks in compliance, due Friday, October 23. The moment it is proposed, the Pre-trade agent warns Sofia Brandt on the working buy.
“Goes to compliance: Tom Hale or Naomi Brooks · due Fri Oct 23 · you cannot approve your own proposal.”
- 08Before he approves
Compliance asks the agents, then decides
Tom Hale · Compliance OfficerIn Approvals, Tom opens LC-2026-1054 and asks the agents. The Revenue agent restates the reading with its page, the Vendor Check agent says the feeds differ by more than 2 points and the change should be decided on its own, and the Policy agent lists the policies and holdings affected. He asks what happens if he approves; the List Publisher agent explains the publish and read-back, and that sells reducing the position are always allowed.
List Publisher agent: “If a compliance officer other than Ana Ruiz approves, I build the next list version, publish it … and read the entry count back from each.”
- 093:10 p.m. · published 3:11
Approved, published, read back, and the buy is blocked
Tom Hale · List Publisher agentTom approves with his reason code. The List Publisher agent builds exclusion list v2026.10.3 with 4 new entries, publishes it to the order management system, reads back 7,422 entries — the same count as sent, version hash matching — and checks the portfolio accounting restriction feed, client reporting and the fund websites' exclusion pages. The Pre-trade agent blocks OMS-7731842.
“v2026.10.3 is in force. 7,422 entries on 1,906 issuers. OMS-7731842 blocked.”
- 10Cure by December 3
The portfolio manager gets a cure plan, not a surprise
Marcus Lindqvist · Portfolio ManagerIn London, Marcus sees Vltavin excluded, with a cure date of Thursday, December 3. His Sustainable Europe Equity fund holds 1,126,400 shares, $41.8M or 0.97% of the fund, 9.4 days of volume; the plan is to sell over 9 days at the volume-weighted price. He acknowledges it or asks compliance for more time. New buys are blocked; sells that reduce a breach are always allowed.
“The Policy agent drafts a cure plan for every holding in a newly excluded name.”