SystemSustainable Investing & Stewardship

ESG Risk Monitoring

ESG risk monitoring that finds a controversy at its first source, in any language, and shows what each fund's screen requires

Controversies in holdings scored within hours, and no fund's screen breached unseen.

See one case, screen by screen ↓
demo52,318documentsread in 24 hours in 31 languages, narrowed to 214 incidents in holdings and 6 that need a person
demo49minutesfrom the court ruling's publication at 4:52 p.m. to a severity score of 4 of 5, each factor cited to the ruling's pages
demo37reportsin 4 languages merged into one incident and mapped to 3 funds holding $86.0M, each with its policy clause and deadline
target0fundsscreened funds holding a flagged issuer past its policy window without a signed decision
In short

What is ESG Risk Monitoring?

ESG risk monitoring is the daily watch an asset manager keeps on its holdings for ESG controversies — environmental harm, labor and human rights abuses, corruption — and the action each fund's policy requires. ESG Risk Monitoring puts seven agents on every holding: they read news, NGO, court and regulator sources in 31 languages, merge each event into one incident, score it twice, map it to the UN Global Compact principles and each fund's own screen, and propose the step for an analyst to decide and the ESG Committee to approve.

AI in asset management: a buyer's guide to agentic AI for investment managers →

Updated

The problem

Why ESG risk monitoring by hand misses the first source

ESG risk monitoring is how an asset manager keeps the promises in its prospectuses, SFDR annexes and client agreements: no holdings with UNGC violations or breaches of the OECD Guidelines, and engagement, then divestment, when a company is in a severe controversy. Under the ESMA fund names guidelines, an EU fund with an ESG or sustainability term in its name must exclude those companies too. Today the Sustainable Investing team leans on vendor controversy ratings that disagree with each other and alert on a cycle, sets English-language news alerts by hand, and rarely sees the local court ruling, regulator order or NGO lab report that comes first, in the issuer's own language.

Then the slow part starts. Someone works out which funds hold the issuer from a portfolio accounting extract, reads each fund's wording to see what it requires and by when, and drafts a letter, all in spreadsheets and email. That is where screens fail: a holding stays in a screened fund because the vendor data lagged, duplicate reports hide how severe an event is, and the decision is never recorded with a reason. In 2024 the SEC settled with an adviser for $4 million because its ESG funds held companies their stated screens excluded, with no policies and procedures over the screening process, as SEC Rule 206(4)-7 requires.

typical$4MpenaltySEC settlement, October 2024, for ESG funds holding companies their stated screens excluded
typical0.38–0.71correlationbetween the ESG ratings of six major providers, so vendor scores cannot be applied unread
typical2weeksbetween client controversy alerts at one large data vendor, published in its own research FAQ
Where one severe incident's business days goestimated
By hand13 days
With the solution1.6 days
  • Learning of it from a vendor alert or English press5 → 0.1 d
  • Reading and translating the primary source1 → 0.1 d
  • Scoring severity and checking the score0.5 → 0.1 d
  • Finding the funds that hold it and what each policy requires1.5 → 0.1 d
  • Drafting the engagement letter and getting it approved3 → 1 d
  • Assembling the evidence for the committee or an auditor2 → 0.3 d

Estimated split for one severity 4 incident held in three screened funds, from first publication to an approved engagement letter, by hand and with the solution.

How it works

How an incident moves

Seven agents read, merge, score twice and map every incident; an analyst decides, the committee approves.

What comes in
Sources inabout 50,000 a day · news, NGO, court, regulator; 31 languages
Agents at work
Watcher agentany language, matched
Then
Merge agentone incident
Then
Severity agent1 to 5, cited
Second Opinion agentblind re-score
Then
Mapping agentprinciple and fund policy
Action agentwatchlist, engage, divest
A person decides
ESG analyst, committeedecide and approve
What comes out
Watchlist and letter
Divestment, two votes
Restriction coded
One case, step by step

One ESG controversy, from a court ruling in Indonesian to an approved letter

On Monday, October 19, 2026 at 4:52 p.m., the Kolaka District Court publishes its judgment against PT Seruni Nikel Tbk, a nickel miner held in three Quillfield Capital funds. Here is how the ESG risk monitoring agents and the people at Quillfield handle it, screen by screen, in the working solution.

  1. 01Tuesday, 9:10 a.m. Singapore

    What the agents did overnight, and what needs her

    Mei Lin · ESG analyst, Asia Pacific

    Mei covers 140 Asian issuers. Her home screen says the agents read 52,318 articles, filings, court and NGO documents in 31 languages in the last 24 hours; 1,206 mentioned a holding, 214 incidents were opened or updated, and 6 need a person. The watchlist holds 41 issuers worth $1.92B, and 0 of 64 screened funds are breached. First on her list: “PT Seruni Nikel: court finds it liable for poisoning a river.”

    “Severity 4 · UNGC principle 7 · 3 funds hold $86.0M · the policy needs a watchlist decision by Mon Oct 26.”

  2. 02The seismograph

    Every holding as a 90-day trace, every spike one incident

    Mei Lin · ESG analyst

    Each holding with an incident in the last 90 days has a trace; each spike is one incident, merged from every report in every language, and its height is the severity. Seruni's trace shows two earlier spikes of severity 2, the NGO water tests on Aug 28 and a village protest on Sep 30, then Monday's 4. The selected spike shows both scores, the principles and the three funds that hold it.

    Filters for severity, Global Compact principle, fund, region, language and status, across 1,186 issuers with an incident.

  3. 03Monday, 5:03 p.m.

    The ruling read at the court registry, 11 minutes after it was published

    Watcher agent and Merge agent

    The Watcher agent read judgment 41/Pdt.G/LH/2026/PN Kka on the Kolaka District Court registry, in Indonesian, and matched the defendant to SRNI IJ and to its bond issuer, Seruni Nikel Finance B.V., through the security master. By 6:40 p.m. the Merge agent had folded 37 reports into one incident: 22 Indonesian, 9 English, 4 Chinese, 2 Japanese. The reader shows the original beside the English, with every figure the agents used highlighted and cited to its page: nickel at 3.8 mg/L against a standard of 0.5 on page 9.

    “Translation checked against the original by the Watcher agent (97%).”

  4. 045:41 p.m.

    Severity 4 of 5, scored twice, the second time blind

    Severity agent and Second Opinion agent

    The Severity agent scored 4 of 5 at 91% confidence on Quillfield's scale, citing each factor: toxic metals in the drinking water of 1,240 households, the company's own settling ponds, a weak response and three incidents in 90 days. The Second Opinion agent, on a different model and without seeing the first score, also scored 4 (88%). Within one level, so no escalation. Data vendor A still shows “Category 2”, last updated Oct 7.

    “Not 5: a first-instance judgment that can still be appealed by Nov 2.”

  5. 056:05 p.m.

    Principle 7, and what each of the three funds must do

    Mapping agent

    The Mapping agent tied the ruling to UN Global Compact principle 7, the precautionary approach, with principle 8 secondary and OECD Guidelines Chapter VI. Under Quillfield's rules Seruni is a potential violator, not a violator, because the judgment is not final. Asia Pacific Sustainable Equity holds $38.4M (0.92% of the fund): watchlist within 5 business days, committee decision within 90 days. Energy Transition Materials holds $31.2M and EM Corporate Bond $16.4M of the 7.25% senior notes due 2029, each with its own clause.

    “No restriction is coded without a committee decision.”

  6. 069:14 a.m.

    She moves Seruni to the watchlist and submits the letter

    Mei Lin · ESG analyst

    The Action agent proposed the watchlist in all three funds and an engagement letter to the Board of Commissioners, with no divestment while the judgment can be appealed. Mei moves Seruni to the watchlist with reason code WL-02, potential violator, and the portfolio managers are told no trade is required. The letter is drafted in English and Bahasa Indonesia with four asks, each cited to the ruling: a remediation plan within 60 days, independent quarterly water tests, the grounds of any appeal, and a meeting with representatives of the 1,240 affected households. She submits it for approval.

    The ESG watchlist goes from 41 issuers and $1.92B to 42 and $2.01B.

  7. 079:18 a.m. Singapore

    The chair approves the letter; the analyst cannot

    Rafael Ortiz · Head of Sustainable Investing, ESG Committee chair

    Rafael reads the letter in both languages and approves it with reason code AP-02, approve with edits, and the stewardship team sends it through the engagement log. Mei cannot approve her own letter. The agents keep four watch conditions running: whether an appeal is filed by Nov 2, a remediation plan by Jan 18, 2027, severity rising to 5, and an appeal court upholding the ruling.

    “With ‘approve with edits’, your edits are kept beside the analyst’s version.”

  8. 08The same morning

    When the two agents disagree, a person decides

    Mei Lin · ESG analyst

    A former Nordhavn Shipping vessel was beached for scrapping at Chattogram and two workers were injured. The Severity agent scored 3, treating the sale to a cash buyer as indirect involvement; the Second Opinion agent scored 5, citing Nordhavn's own policy covering sales through cash buyers and the Hong Kong Convention, in force since June 26, 2025. A gap of two levels stops the flow and goes to Mei with both rationales; the Mapping agent waits for her score before applying each fund's policy.

    “Agents never settle a gap over one level: read both rationales and set it.”

  9. 09Divestment

    Two committee votes, never the proposer's

    Sofia Lindqvist · Head of Stewardship

    Taraval Agro Plantations has been severity 5 since March 2025, with forced-labor indicators at its Sabah estates and 3 of 4 engagement milestones missed in 18 months. Mei proposed divestment on Oct 12 and, as the proposer, cannot vote; Rafael voted on Oct 16. Sofia's vote, due Mon Oct 26, is the second. After it, compliance codes restriction R-ESG-0412 in the order management system and the portfolio managers sell $54.7M in 4 funds to zero by Dec 1; the Action agent estimates 4.2 trading days at 20% of volume.

    “Rafael Ortiz approved on Oct 16. A second vote approves the divestment. You may vote against with a reason.”

  10. 10Every step

    Every action on a hash-chained audit trail

    Evidence agent · Graham Pike, Internal Audit

    Every action by a person or an agent is recorded with who, what, when, the reason code, the evidence and the agent's version: the Watcher agent's read at 5:03 p.m., both scores, the mapping, Mei's WL-02 decision and Rafael's approval. Entries are read-only and the chain is verified. Internal audit asks the Evidence agent to prove every severity 4 had a decision in its window, and exports an evidence pack for an issuer, a fund or a period.

    “In Q3, 9 of 9 severity 4–5 incidents in screened funds had a signed decision inside the policy window.”

Who it’s for

Built for everyone who answers for a fund's ESG promise.

The same controversy, seen by the people who carry it from the first source to a decision — what their week looked like, and what it looks like now.

ML
Mei LinESG Analyst, Asia Pacific · Singapore · 140 issuers
ESG analyst
Before
Reads English news alerts and vendor spreadsheets, and finds the local court ruling or NGO report late or not at all.
Now
Starts the day with the one incident that changes what a fund must do, the page that proves it, and a decision with a reason code.
RO
Rafael OrtizHead of Sustainable Investing and ESG Committee Chair · London
ESG Committee chair
Before
Approves letters and chairs the committee from email threads and minutes, with no single file to defend a decision.
Now
Reads each letter in both languages with every ask cited, approves or returns it, and votes on divestments from one file.
SL
Sofia LindqvistHead of Stewardship, ESG Committee member · London · 17 active engagements
Head of Stewardship
Before
Tracks engagements without firm dates, so a company can drift for months before anyone escalates.
Now
Sees every engagement's milestones, missed and met, and casts the second vote on a divestment with the evidence in front of her.
AM
Arjun MehtaPortfolio Manager, Asia Pacific Sustainable Equity · $4.18B SFDR Article 8 fund
Portfolio manager
Before
Hears about a controversy in his fund late, without knowing what the fund's rules require of him.
Now
Is told when a holding goes on the ESG watchlist, what the clause requires and by when, and whether he must trade: here, no.
CW
Claire WhitfieldInvestment Compliance Officer · New York · screens, restrictions, PAI
Investment compliance officer
Before
Has to prove every screened fund kept its prospectus promise, from spreadsheets and the vendor's data.
Now
Sees 64 screened funds with their coded rules, flagged holdings and 0 breaches, codes restrictions and signs the PAI data.
Built on the engine

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

Seven agents read, merge, score twice and map every incident; an analyst decides, the committee approves.

Watcher agent

Reads news, NGO, court and regulator sources and company filings in 31 languages, about 50,000 documents a day, and matches each one to the issuer, its subsidiaries and its local names through ISIN, CUSIP and LEI in the security master.

  • A match on a name alone below 0.90 similarity goes to a person
  • Keeps licensed news as an excerpt and link only
Merge agent

Folds duplicate and related reports of one event into a single incident across languages, by place, parties and period, and explains every merge.

  • Never merges different sites or dates without saying why
  • A person can split any report out
Severity agent

Scores each incident 1 to 5 on the firm's severity scale from impact, involvement, response and recurrence, each factor cited.

  • Never scores 5 on allegations alone
  • Below 75% confidence, hands the incident to a person
Second Opinion agent

Re-scores every incident of severity 3 or more on a different model, without seeing the first score, and escalates a gap of more than one level.

  • Never sees the first score
  • Never settles a disagreement: the analyst does
Mapping agent

Maps each incident to the UN Global Compact principles and OECD Guidelines chapters, then to every fund that holds the issuer and that fund's coded policy, with the clause and the deadline in business days.

  • Never changes a policy
  • A fund without a coded policy goes to a person
Action agent

Proposes watchlist, engagement, no action or divestment as each policy requires, drafts engagement letters in English and the issuer's language and divestment files, and sets watch conditions.

  • Proposals only
  • Never sends a letter, votes, codes a restriction or trades
Evidence agent

Keeps the evidence file for every incident, builds committee packs, PAI data and reports with every number cited, and verifies the audit chain.

  • Drafts only: every report is signed by a person
  • Verifies the hash chain daily
Analyst, chair, committee, compliance

Decide, approve, vote, restrict. The agents propose; a named person decides.

Ask in plain words

Ask about any incident, fund or decision

On every screen, ask the agents in plain words or tell them what to do. They answer with sources and act only with your approval.

Why principle 7?

Principle 7 asks companies to take a precautionary approach to environmental challenges. The court found the company let tailings run off into a river for two years, with nickel and chromium far above the standard: a failure to prevent harm it could foresee. Principle 8 is secondary because the remedy is about environmental responsibility.

Which funds must act, and by when?

Three funds, $86.0M: Asia Pacific Sustainable Equity $38.4M, watchlist by Mon Oct 26 and a committee decision by Jan 18, 2027; Energy Transition Materials $31.2M, watchlist and engagement; EM Corporate Bond $16.4M, watchlist and bondholder engagement. No fund has to sell today.

What changed since last week?

The water tests (Aug 28) and the protest (Sep 30) were already on the trace; on Monday the court ruled, 37 reports followed in 4 languages, and this morning the company said it “will consider legal remedies”. Our data vendor has not updated since Oct 7.

Where were we ahead of our data vendor this month?

This month we flagged 9 severity 3+ incidents before our data vendors, on average 11.4 days earlier, and missed none they flagged. PT Seruni Nikel is the latest: the vendor still shows “category 2”, last updated Oct 7, while the court ruled on Oct 19.

Every screen

The working solution, as it ships.

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

TodayESG risk monitoring at a glance: documents read in 31 languages, incidents in holdings, what needs the analyst, the watchlist and screened-fund breaches, and what each agent did overnight.
The controversy seismographESG controversy screening across every holding: each holding with an incident in the last 90 days as a trace, each spike one incident, its height the severity, with both scores, the principle and the funds that hold it.
The incident and the agentsThe ESG controversy file for one incident: what happened, cited to the ruling’s pages; two severity scores, the second blind; the agents’ conversation; and the analyst’s decision.
The source, original beside EnglishThe court judgment in Indonesian beside the English, every figure the agents used highlighted and cited to its page, and the 37 reports merged into one incident.
Funds and policiesEvery fund that holds the issuer, its exposure and share of the fund, the policy clause, what the policy requires and by when.
The engagement letterAn engagement letter drafted in English and Bahasa Indonesia, each ask cited to the ruling, for the analyst to edit and submit for approval.
The chair approvesThe committee chair approves the letter with a reason code, signed and recorded on the audit trail; the analyst who submitted it cannot approve it.
When the scores differA severity agent score of 3 and a blind second opinion of 5: a gap of two levels goes to the analyst with both rationales to set the severity.
The divestment fileThe divestment file as the second committee member sees it: proposal, first vote, the missed engagement milestones, the exit plan and her vote to cast, never the proposer's.
Funds and their screens412 funds and mandates, 64 with a written norms-based screen or controversy policy coded from the prospectus, SFDR annex or client agreement, with flagged holdings, decisions due and breaches.
SourcesHow 52,318 documents in 31 languages became 6 decisions: what the Watcher agent read in the issuer’s own language, the languages, and news, NGO, court and regulator sources with their health.
The audit trailEvery action by a person or an agent, with the reason code, the evidence and the agent version, hash-chained and read-only, with evidence pack export.
Rules and thresholdsEscalation windows, the second-opinion and confidence thresholds and the name-match rule, with core rules locked and changes approved by compliance.
Governance

Built for ESG controversy screening that must hold: cited, scored twice, signed.

Every value cites its sourceEvery figure and every agent statement links to the page it came from — the ruling in its original language, the NGO report, the fund's prospectus clause — and answers to questions cite too.
Two scores, the second blindEvery incident of severity 3 or more is scored again on a different model without the first score. A gap of more than one level stops the flow and goes to the analyst with both rationales.
Maker and checker, with reason codesThe analyst decides watchlist and engagement, the chair approves letters, and any divestment needs two committee votes, never the proposer's. Every decision carries a reason code and a signature.
Agents never act on their ownThe agents propose and draft. They never send a letter, vote, code a restriction or trade, and an issuer goes on the watchlist only on an analyst’s decision; compliance codes restrictions in the order management system and portfolio managers trade.
Hash-chained audit trail and evidence packsWho, what, when, why, which evidence and which agent version, read-only and chained, with evidence packs for an issuer, a fund or a period. Decisions are kept 7 years, longer than the five years SEC Rule 204-2 requires, and evidence files 10.
Versioned agents, tested before releaseAgents and prompts are versioned and evaluated against 1,860 past incidents labeled by the committee; every human override is recorded with its code and feeds the next evaluation. Data stays in its region.
Configuration

Your escalation policy, not ours

The thresholds every incident is checked against are settings. Core rules are locked, and any change is saved as a new version that compliance approves.

SettingDefaultChoose from
Severity 4–5 in a screened fund reaches an analyst within4 business hoursLocked core rule
Divestment needs committee votes from different members, never the proposer2 votesLocked core rule
Restriction coded by compliance after approval within1 business dayLocked core rule
Second opinion runs on incidents of severity3 or moreEditable, as a new version for compliance approval
Escalate when the two scores differ by more than1 levelEditable, as a new version for compliance approval
Log severity 1–2 automatically at confidence of at least85%Editable, as a new version for compliance approval
Hand to a person below confidence of75%Editable, as a new version for compliance approval
Entity match by name alone needs similarity of at least0.90Editable, as a new version for compliance approval
Connections

Works with the systems your ESG team already runs on

News, NGO, court and regulator sourceslicensed news and wires, 1,480 NGO sites, 212 court registries in 46 jurisdictions, 138 regulators, 61 exchanges
Portfolio accounting and the fund administratorpositions for every fund three times a day, holdings and NAV reconciled daily, custodian positions and securities on loan
Security masterissuers, subsidiaries and local names by ISIN, CUSIP and LEI
Order management systemrestrictions and pre-trade rules, two-way
Fund documentsprospectus wording, SFDR annexes and client agreements, coded as rules that compliance approves
ESG data vendors and the engagement logeach vendor’s ESG controversy score category, flags and norms status, compared and never copied; letters, meetings and milestones from the CRM
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
screened funds holding a flagged issuer past its policy window without a signed decision
Todayscreens rely on vendor data
With agentsevery spike decided in its window
target
100%
of holdings watched daily in the issuer's own language, courts and NGOs included
9,412 issuers
31 languages
target
4hours
or less from publication to a scored, fund-mapped alert, not the next vendor cycle
Vendor alertevery 2 weeks
With agentsunder 4 hours

“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 settled order, October 2024, $4 million, ESG screens not applied; Berg, Kölbel and Rigobon, Aggregate Confusion, ESG rating correlations of 0.38–0.71; a controversy data vendor's published research FAQ, 2020, on bi-weekly client alerts). Regulations named as context: UN Global Compact principles, OECD Guidelines for Multinational Enterprises (2023), SFDR principal adverse impact indicators 10 and 11, ESMA guidelines on fund names (2024), SEC Rules 206(4)-7 and 204-2. People, funds, companies, courts and amounts named on this page are fictional — characters and sample data in the working solution.

Questions

What asset managers ask about ESG risk monitoring.

What is ESG risk monitoring?

ESG risk monitoring is the daily watch an asset manager keeps on its holdings for ESG controversies — environmental harm, labor and human rights abuses, corruption — and the action each fund's policy requires. ESG Risk Monitoring puts seven agents on every holding: they read news, NGO, court and regulator sources in 31 languages, merge each event into one incident, score it twice, map it to the UN Global Compact principles and each fund's own screen, and propose the step for an analyst to decide and the ESG Committee to approve.

What is norms-based screening?

Norms-based screening, often called UN Global Compact screening, checks companies against international standards such as the ten UN Global Compact principles and the OECD Guidelines for Multinational Enterprises, and excludes, watches or engages with those that breach them. In this solution each fund's screen is coded from its prospectus, SFDR annex or client agreement and approved by compliance, so an incident is tested against what that fund actually promised.

How do you monitor ESG controversies in local-language sources?

The Watcher agent reads sources in the issuer's own language, including 212 court registries in 46 jurisdictions, 138 regulators and 1,480 NGO sites, and matches them to the issuer, its subsidiaries and local names. The original is shown beside the English with every figure cited to its page; in the demo, an Indonesian court ruling was read 11 minutes after it was published.

What is the difference between a potential violator and a UNGC violator?

It depends on how the fund's policy treats UNGC violations, and the Mapping agent cites the clause it applies. In the demo, a first-instance judgment that can still be appealed makes the issuer a potential violator — watchlist within 5 business days, engagement and a committee decision within 90 days — while a final judgment, or severity 5 without credible remediation, makes it a violator to be sold within 30 business days.

Does it replace our ESG data vendor's controversy scores?

No. It works beside the ESG risk monitoring tools you already license: vendor categories and norms status come in as a feed and are shown beside the agents' own score — compared, never copied. In the demo month the agents flagged 9 severity 3+ incidents before the data vendors, on average 11.4 days earlier, and the vendor still showed the Seruni case at “category 2”.

Does it help with SFDR PAI indicators 10 and 11?

Yes. The Evidence agent drafts the principal adverse impact data for indicators 10 and 11 with every number cited to holdings and policies; an ESG analyst reviews and submits it, and investment compliance signs it. The ESG Committee report, the stewardship report, US fund board updates and client report extracts work the same way: drafted by the agent, reviewed by one person, signed by another.

Do people stay in control of watchlist, engagement and divestment decisions?

Yes. The agents propose and draft; they never send a letter, vote, code a restriction or trade. The analyst decides with a reason code, the chair approves letters, two committee members approve any divestment and never the proposer, compliance codes the restriction, and every step 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 fund prospectuses and SFDR annexes, your escalation policy and severity scale — and it goes live once every quality gate has passed. A guided first-time setup codes each fund's screen for compliance to approve.

See it on
your holdings.

We'll run ESG Risk Monitoring on your own holdings and fund policies, against a recent month of controversies.