WorkflowSustainable Investing & Stewardship

ESG Exclusion Screening

ESG exclusion screening with every exclusion proven from the issuer's own filing

Every exclusion proven from the issuer's own filing, and no advertised screen breached.

See one case, screen by screen ↓
demo487,360tests12,184 issuers against 40 exclusion policies, run overnight in 7 h 42 min
demo12.4%thermal coal read from the issuer's Czech annual report, where the data feed said 8.1% — escalated, not averaged
target100%of exclusion decisions backed by the issuer's own filing, page-cited
target0holdings in breach of an advertised screen left unnoticed
In short

What is ESG Exclusion Screening?

ESG exclusion screening — also called negative screening or exclusionary screening — keeps the companies a fund has promised to exclude out of its portfolio: controversial weapons, thermal coal or tobacco above a revenue threshold, UN Global Compact violators. ESG Exclusion Screening tests every holding against each fund's ESG exclusion policy with seven AI agents that read each issuer's own annual report in its language, compare it with two ESG data feeds and test every policy at once. An analyst proposes each change to the exclusion list, compliance approves it, and only then does it reach the order system.

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Updated

The problem

Why ESG exclusion screening breaks on vendor data alone

Every exclusion is a promise: in a prospectus, a fund name, a client's investment management agreement. No controversial weapons at any level, no company over a set share of revenue from thermal coal, tobacco or oil sands, no UN Global Compact violators. Each fund range has its own policy and thresholds, so a large manager runs dozens of policies over thousands of issuers. The screen runs on licensed vendor data that arrives as estimates or revenue bands, often a year or more old, and the vendors disagree. Analysts read annual reports by hand for the names a vendor flags, mostly the English ones; approvals sit in email; the list goes into the order management system as a file upload, with no read-back.

When the data is wrong, a fund holds a name its prospectus excludes. In October 2024 the SEC fined one ETF sponsor $4 million because three ESG ETFs held coal, gas and tobacco retail companies for more than two years, relying on vendor data with no procedures over the screen. The pressure keeps rising: ESMA's fund naming guidelines tie "ESG" and "sustainable" names in the EU to the Paris-aligned benchmark (PAB) exclusions, and the SEC Names Rule asks a US fund whose name suggests a focus, ESG included, to keep 80% of its assets in line with that name. Metallurgical coal counted as thermal, a 54%-owned subsidiary that makes cluster munitions, an acquisition that pushed a utility over 10%: these are the cases a vendor band does not settle.

typical$4millionSEC penalty on an ETF sponsor whose ESG ETFs held names their prospectuses excluded (October 2024)
typical475of 924EU funds that added explicit exclusions to their investment policies after ESMA's naming guidelines
typical0.38–0.71correlation between the ESG ratings of six major providers
Where a quarterly re-test's business days goestimated
By hand19 days
With the solution3 days
  • Building the universe and mapping securities to issuers and parents2 → 0.1 d
  • Running every policy on vendor data3 → 0.2 d
  • Reading annual reports and checking exceptions7 → 1 d
  • Reconciling vendor disagreements3 → 0.5 d
  • Approvals and loading the list into the order system2 → 1 d
  • Evidence for the board, auditors and exams2 → 0.2 d

Estimated split for one quarterly re-test of every issuer against every policy at a large global manager, by hand and with the solution.

How it works

How a holding is screened

Seven agents read every filing, check the feeds and test every policy; an analyst proposes, compliance approves.

What comes in
Holdings and filings in12,184 issuers, 40 policies · positions, filings in any language, two feeds
Agents at work
Universe agent286 funds and mandates
Then
Revenue agentsegment note, cited
Weapons and Norms agentownership chains
Then
Vendor Check agentgaps over 2 points
Policy agentall 40 at once
Then
List Publisher agentpublish and read back
Pre-trade agentwarn or block
A person decides
Analyst, compliancepropose, approve
What comes out
Every exclusion proven
List in the order system
Orders blocked, on the record
One case, step by step

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.

  1. 012:40 p.m.

    The agents worked overnight; her next steps are waiting

    Ana Ruiz · ESG Screening Analyst

    Ana'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.”

  2. 02The sieve

    Every issuer through every rule, every catch with its page

    Ana Ruiz · ESG Screening Analyst

    She 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”

  3. 03One click

    The revenue share, from the issuer's own segment note

    Revenue agent

    The 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.

  4. 04Page 148

    Any figure opens the page it came from

    Ana Ruiz · ESG Screening Analyst

    Ana 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.”

  5. 05Three readings, 40 policies

    A 4.3-point gap escalated, every policy tested at once

    Vendor Check agent · Policy agent

    The 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.”

  6. 06Before she proposes

    She asks the agents what waiting would cost

    Ana Ruiz · ESG Screening Analyst

    Ana 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.”

  7. 072:52 p.m.

    She proposes the exclusion, with the evidence attached

    Ana Ruiz · ESG Screening Analyst

    The 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.”

  8. 08Before he approves

    Compliance asks the agents, then decides

    Tom Hale · Compliance Officer

    In 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.”

  9. 093:10 p.m. · published 3:11

    Approved, published, read back, and the buy is blocked

    Tom Hale · List Publisher agent

    Tom 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.”

  10. 10Cure by December 3

    The portfolio manager gets a cure plan, not a surprise

    Marcus Lindqvist · Portfolio Manager

    In 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.”

Who it’s for

Built for everyone who keeps an exclusion promise.

The same re-test, seen by five of the people who carry it — what the quarter looked like, and what it looks like now.

AR
Ana RuizESG Screening Analyst · New York · proposes list changes
ESG Screening Analyst
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.
TH
Tom HaleCompliance Officer · approves or returns every list change
Compliance Officer
Before
Approves list changes from email and minutes, with the evidence in shared drives; nothing proves the order system took the new list.
Now
Asks the agents about any change before deciding, approves with a reason code, and sees the order system read the list back. He can never approve his own proposal.
ML
Marcus LindqvistPortfolio Manager · Quillfield Sustainable Europe Equity Fund · London
Portfolio Manager
Before
Learns a name is excluded when his trader's order is stopped, and tracks the cure deadline in email.
Now
Sees names proposed in his funds before they are approved, and gets a cure plan with shares, days of volume and a cure date to acknowledge or extend.
LH
Leila HaddadHead of Sustainable Investing · owns the 40 policies and the board report
Head of Sustainable Investing
Before
Prospectus wording like "significant involvement" is coded into restrictions by hand, fund by fund, and drifts from what investors were promised.
Now
The Policy agent drafts each rule with the sentence it came from; she sets every threshold, back-tests it on the universe and signs with compliance.
GW
Grace WhitfieldInternal Audit · tests the control each quarter
Internal Audit
Before
Spends weeks reconstructing who decided what, on which evidence, for an exam request.
Now
Filters a hash-chained trail of every action by people and agents, verifies the chain and exports one evidence pack.
Built on the engine

7 agents. Each with one job, and hard limits.

Seven agents read every filing, check the feeds and test every policy; an analyst proposes, compliance approves.

Universe agent

Builds the issuer universe from every fund's holdings and benchmark, maps each security to its issuer and ultimate parent, and plans each re-test so issuers with new filings are read first.

  • Never changes a position or a fund's holdings list
  • Read-only access to portfolio accounting
Revenue agent

Finds the issuer's latest annual report or 10-K, reads the segment note in its original language with the English beside it, computes the revenue share of each activity in scope and reconciles the segments to consolidated revenue.

  • Never reports an estimate as reported; with no split disclosed it gives a range and will not guess
  • Below 90% confidence, the analyst decides
  • Every figure carries its page
Vendor Check agent

Compares the filing with two ESG data feeds, explains each gap — an old year, a misclassified activity, a subsidiary mapped to the wrong parent — escalates any gap over 2 points and drafts the challenge to the vendor.

  • Never picks between sources
  • Never sends a challenge without an analyst
Weapons and Norms agent

Checks cluster munitions, anti-personnel mines and chemical and biological weapons through ownership chains in the issuer's own filings, and UN Global Compact status from the norms feed.

  • Never excludes on news alone; a filing or the norms feed must confirm it
  • Subsidiaries owned 50% or more count
Policy agent

Tests every issuer against all 40 policies with their versions, thresholds and ownership rules, shows the funds that hold it, the orders in flight and each cure date, and drafts rules from prospectus text.

  • Never changes a policy
  • Never proposes or approves a list change
List Publisher agent

After a compliance approval, builds the new list version, publishes it to the order management system, portfolio accounting and client reporting, and reads the entry count back from each.

  • Publishes only after approval by someone other than the proposer
  • Stops and alerts if the read-back differs
Pre-trade agent

Warns the trader on orders in names proposed for exclusion, blocks new buys in approved names and allows sells that reduce a breach.

  • Never cancels or amends an order
  • Never blocks a sell that reduces a breach
Analyst, compliance, portfolio manager

Propose, approve, cure. The agents propose; a named person decides.

Ask in plain words

Ask the agents about any issuer, fund, policy or order

Every screen keeps the agents at hand. Ask in plain words or tell them what to do; every answer cites the page, and anything that changes a list goes to an analyst and compliance.

Why is Vltavin Energie over the coal limit?

Its 2025 annual report (Czech), note 5, shows coal-fired generation CZK 16,437m and lignite mining CZK 6,210m out of CZK 182,640m: 12.40%, over the 10% limit of P-07. It rose from 9.94% after the July 2024 purchase of the Kladruby lignite plant. The primary feed's 8.1% is a FY2023 estimate.

Which funds hold names proposed for exclusion today?

Vltavin Energie: $51.9M in Sustainable Europe Equity, the Global ESG Leaders ETF and the Responsible Growth model. Bergström Försvar: $3.1M in the Global ESG Leaders ETF. Already excluded today: Castellan Retail, $18.7M, and Daesan Precision, $9.4M, with cure plans to December 3.

Prepare the evidence pack for exam request item 14

Scope: exclusion decisions since July 1, 2026 — 82 decisions, each with the maker, the checker, the reason code and the source pages in the original language and English, plus list read-back receipts and the hash chain. Opening the export for you to build and download.

Make tobacco retail 0% for the Hollins Medical Foundation

Already drafted: PC-2026-018 changes P-27 tobacco distribution and retail from 5% to 0%, from the client's letter of October 14. Back-test: 2 more issuers, neither held by the mandate. Leila Haddad signed; it waits for compliance. I cannot sign it.

Every screen

The working solution, as it ships.

13 screens from the working solution, on its sample data. Pick one to see it large.

TodayThe ESG screening analyst's home for ESG exclusion screening: what needs her, list changes awaiting compliance, the overnight re-test and every agent step since Monday, cited.
The exclusion sieveA fund's exclusion policy as stacked rules; the universe pours through and each caught issuer hangs under its rule with its revenue share and page.
Revenue from the issuer's own reportThe segment note in Czech beside the English, the thermal coal share against the 10% revenue threshold, and how the agent reconciled it.
The cited pageAny figure opens its page: the original-language passage beside the English, with the values the agents used highlighted.
Three readings, 40 policies, holdingsThe filing and two ESG data feeds with the gap escalated, every exclusion policy tested at once, and the funds and open orders affected.
Ask the agentsThe analyst asks what waiting for the next filing would cost; the Policy agent answers with the fund, the amount and the page.
Propose an exclusionThe proposal carries the segment note, the reconciliation, three readings and holdings; it goes to compliance, never to its proposer.
Compliance asks before approvingBefore deciding, the compliance officer asks the agents about the change: the reading, the feeds, the policies and what approval will do.
Publish and read backThe approved exclusion list goes to the order management system and is read back, entry count and version hash matching; the pre-trade check blocks the open buy.
Positions to exitA cure plan for every fund holding a newly excluded name: shares, value, days of volume, the cure date and the portfolio manager's acknowledgment.
When the filing has no splitThermal and metallurgical coal reported together: the agent gives a 6.9%–10.5% range at 61% confidence and the analyst decides, with a reason.
A policy from the prospectusThe Policy agent drafts each exclusion rule with the prospectus sentence it came from, and asks for a threshold where the wording is not a number.
Audit trailEvery question, proposal, approval, publish and pre-trade block, by person or agent, with its evidence, hash-chained.
Governance

Built for ESG exclusion screening that stands up to an exam: cited, signed, read back.

Every figure cites its pageEach revenue share and every agent statement links to the page in the issuer's own filing, in the original language beside the English. The page image and its fingerprint stay with the decision.
The analyst proposes, compliance approvesAn ESG screening analyst proposes each addition or removal with a reason code; a compliance officer approves, returns or rejects it, and never their own. Policy changes need the head of sustainable investing and compliance; settings changes wait for compliance's co-signature.
Disagreement is escalated, never averagedWhen a data feed differs from the filing by more than 2 points, the agents show all three readings and the reason for each, and a person decides. Bulk approval is allowed only where the filing and both feeds agree within 0.5 points.
Published only after approval, and read backThe ESG exclusion list reaches the order management system only after a compliance approval, and the order system's entry count is read back before the version is in force. If it differs, publishing stops and compliance is alerted.
Agents with hard limits and measured versionsNo agent changes a policy, proposes or approves a list change, cancels an order or presents an estimate as reported. Each agent is versioned and scored on a golden set — the Revenue agent at 98.6% exact on 400 segment notes in 18 languages — and a new version runs beside the old one until compliance approves it.
Hash-chained, kept seven yearsEvery action by a person or an agent — every question, proposal, approval, publish and block — is on an append-only, hash-chained audit trail with its evidence, kept seven years and exported as one evidence pack for auditors and regulators.
Configuration

Your exclusion policies and thresholds, not ours

The rules every screen runs on are settings. Each change is versioned and needs compliance's co-signature before it applies.

SettingDefaultChoose from
Feed disagreement escalated above2.0 pointsAny gap in points between the filing and a feed
Near-limit band1.0 pointIssuers this close to a limit go on watch; a change to 1.5 waits for compliance
Revenue agent confidence floor90%Below it, the analyst decides
Ownership counted from50% (consolidated subsidiaries)Any ownership share
Oldest filing accepted18 monthsAny age in months
Cure window30 business days, US holidays excludedAny number of business days, set per policy
Approval window2 business days, then the head of sustainable investing is notifiedAny number of business days
Bulk approval allowed when filing and both feeds agree within0.5 pointsAny gap in points
Connections

Works with the systems your exclusion list already lives in

Order management systempre-trade checks, restriction list import and read-back
Portfolio accountingpositions for every fund, ETF, model and mandate
Security mastersecurities mapped to issuers and ultimate parents
ESG data and norms feedstwo product involvement feeds and a UN Global Compact norms feed
Document managementannual reports, 10-Ks and business reports in any language, prospectuses and client agreements
Client reportingthe published list and the fund websites' exclusion pages
What it changes

The difference, in numbers.

Every figure is labelled: a target the solution is built to, an estimate, a typical published result, or a proven one.

target
0
holdings in breach of an advertised screen left unnoticed
Todayvendor estimate trusted
With agentsevery filing read
target
100%
of exclusion decisions backed by the issuer's own filing, page-cited
every decision
not a vendor band
target
Overnight
quarterly re-test of every issuer against every policy, not three weeks

“demo” = seen in the working solution, on its sample data · “target” = the design goal, measured in the live solution · “estimated” = our estimate · “typical” = published figures (SEC order against an ETF sponsor, October 2024, $4 million, via WealthManagement and ThinkAdvisor; ESMA review of its fund-naming guidelines, December 2025: 475 of 924 funds added exclusions; Berg, Koelbel and Rigobon, 2022, on ESG rating divergence). Regulatory context: Delegated Regulation (EU) 2020/1818, Art. 12 (Paris-aligned benchmark exclusions); ESMA guidelines on funds' names; SEC Names Rule. People, firms, funds and issuers named on this page are fictional — characters and sample data in the working solution.

Questions

What asset managers ask about ESG exclusion screening.

What is ESG exclusion screening?

ESG exclusion screening — also called negative screening or exclusionary screening — keeps the companies a fund has promised to exclude out of its portfolio: controversial weapons, thermal coal or tobacco above a revenue threshold, UN Global Compact violators. ESG Exclusion Screening tests every holding against each fund's ESG exclusion policy with seven AI agents that read each issuer's own annual report in its language, compare it with two ESG data feeds and test every policy at once. An analyst proposes each change to the exclusion list, compliance approves it, and only then does it reach the order system.

How is it different from negative screening on vendor ESG data?

ESG screening tools that rely on vendor data alone see estimates or revenue bands, often a year or more old, and the vendors disagree. Here the revenue share comes from the issuer's own segment note, reconciled to the income statement and cited to the page, and both feeds are kept beside it. Any gap over 2 points is escalated to a person with the three readings and the reason for each, never averaged.

Can it apply Paris-aligned benchmark (PAB) exclusions and ESMA's fund naming guidelines?

Yes. Each policy is a set of versioned rules with thresholds, so one manager can run firmwide baselines, the EU Paris-aligned benchmark exclusions and Climate Transition exclusions that ESMA's fund naming guidelines tie to fund names, US sustainable funds, index funds, faith-based screens and clients' own mandate lists side by side. In the working solution, the PAB exclusions include hard coal and lignite at 1% of revenue, oil fuels at 10%, gaseous fuels at 50% and high-carbon power at 50%.

How does it screen controversial weapons held through subsidiaries?

For controversial weapons screening, the Weapons and Norms agent follows ownership chains in the issuer's own filings. In the working solution it found cluster munitions at a subsidiary 54.0% owned by a Korean parent, cited in the parent's Korean business report; the ownership rule counts subsidiaries 50% or more owned. It never excludes on news alone. The quarterly board report then shows controversial weapons exposure as the SFDR PAI 14 indicator: 0.001% of AUM in the working solution, nil once that position's cure ends on December 3.

What happens when ESG data vendors disagree with the filing?

The Vendor Check agent shows the filing and both feeds with the reason for each gap — an old year, a misclassified activity such as metallurgical coal counted as thermal, a subsidiary mapped to the wrong parent. It drafts a challenge to the vendor with the page attached, and an analyst decides whether to send it. Disagreements that change no outcome can be noted in bulk after checking a sample.

How is the approved exclusion list enforced pre-trade?

After a compliance approval, the List Publisher agent publishes the new list version to the order management system as its pre-trade restricted list and reads the entry count back. The Pre-trade agent warns traders on orders in names proposed for exclusion, blocks new buys once approved, and always allows sells that reduce a breach. It never cancels or amends an order.

Do people stay in control of the exclusion list?

Yes. The agents read, compare, test and draft; they never change a policy, propose or approve a list change, or cancel or amend an order. An analyst proposes, a compliance officer who did not propose it approves, policy changes need two signatures, and every action is on a hash-chained audit trail.

How long does it take to go live?

The Agentic Solution Engine builds and deploys it from your requirements and documents — your prospectuses, client agreements and exclusion policies, your data feeds and a sample of past decisions — and it goes live once every quality gate has passed. A guided setup connects the order system, portfolio accounting, security master, feeds and document management, loads the universe and codes each policy from its document with two signatures; the agents are tested on a golden set and one quarterly re-test runs beside the old process before go-live.

See it on
your exclusion policies.

We'll run ESG Exclusion Screening on your own policies, a sample of your holdings and the filings behind them.