SystemSustainable Investing & Stewardship

Stewardship Engagement Tracking

Stewardship engagement tracking that checks every meeting for 13G risk and proves every outcome from the company's own words

Every meeting checked against 13G limits, and every outcome proven by a cited source.

See one case, screen by screen ↓
demo297objectivesmoved up at least one rung in 2026 on the sample book, of 1,094 tracked; 162 implemented, each with a cited source
demo1board-seat requestcaught on a six-item agenda at a 6.10% holding before the meeting, rewritten and cleared by Legal
target0high-risk itemsreaching a company without Legal's clearance
target100%of rung changes backed by a cited source and a second person
In short

What is Stewardship Engagement Tracking?

Stewardship Engagement Tracking is engagement tracking software for investment stewardship teams: it logs every company engagement against its objectives, follows each objective up a ladder from Raised to Implemented, and drafts the annual stewardship report. Six AI agents turn notes into milestones, check every agenda for Schedule 13G risk before the meeting, draft letters in the company's language, prove progress from the company's own filings and watch the escalation clock. Analysts submit, engagement leads approve, Legal clears and the Head of Stewardship signs.

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

Updated

The problem

Why engagement tracking still can't prove an outcome

Engagement tracking at a large asset manager covers hundreds of companies and many hundreds of shareholder engagements a year, each meant to move a specific objective — a methane target, a more independent board, pay tied to the right goals — for years until the company does what it said. Today the analyst types the meeting summary into the tracker days or weeks later, progress sits in a free-text field with a pasted link, and every spring the team re-reads years of notes and company reports to support the UK Stewardship Code Activities and Outcomes Report, the SRD II engagement report, PRI reporting and client reports, while Compliance checks every claim.

Since the SEC staff's guidance of February 11, 2025 (C&DI 103.12), every meeting at a company where the firm holds more than 5% carries a second risk: a holder that seeks a board seat, pressures management on a specific measure or ties its vote for directors to a change can lose the right to file the short Schedule 13G as a passive investor. Agendas go to Legal by email, often the day before, with no record of what Legal changed or why — and a follow-up letter or a collaborative letter can say the wrong thing just as easily.

typical5%holding above which engagement must stay within passive-holder limits to keep filing Schedule 13G
typical45daysafter each quarter end to amend Schedule 13G for a material change
typical3of 50large asset managers referred to time-bound milestones for companies
Where the working days go for one engagement at a 13G issuerestimated
By hand1.8 days
With the solution0.4 days
  • Agenda and briefing from three or four systems0.4 → 0.1 d
  • Getting the agenda through Legal0.3 → 0.1 d
  • Logging the note, objectives and milestones0.3 → 0.1 d
  • Drafting and translating the follow-up letter0.3 → 0.1 d
  • Finding proof of progress in company filings0.4 → 0.1 d
  • Writing it up for the stewardship report0.3 → 0.1 d

Estimated working days of eight hours for one meeting at a company where the firm holds more than 5%, from the agenda to the report: about 14 hours by hand, 3.5 with the solution.

How it works

How an engagement moves

Six agents log notes, check every agenda for 13G risk, prove progress and draft the report; analysts submit, leads approve, Legal clears.

What comes in
Engagement in412 companies, hundreds a year · notes, agendas, filings; any language
Agents at work
Notes agentmilestones, same day
Then
Filing Status agent13G check before meetings
Follow-up agentletters, any language
Then
Evidence agentnext rung, cited
Escalation agentpolicy clock
Then
Report agentapproved records only
A person decides
Analyst, lead, Legalsubmit, approve, clear
What comes out
Rungs proven
Meetings cleared
Report drafted
One case, step by step

Stewardship engagement tracking, the day before a meeting with the chair

Quillfield Capital, a global asset manager, holds 6.10% of Hollis Marrow Energy Corp. — 8,742,000 shares, about $612.1M across 14 funds — and files Schedule 13G as a passive investor. It is Wednesday, October 21, 2026, and tomorrow at 10:00 a.m. the team meets the independent chair. Here is what happens next, screen by screen, in the working solution.

  1. 018:50 a.m.

    One next step each, and what the agents did overnight

    Claire Whitford · Head of Investment Stewardship

    Claire's home shows 684 engagements in 2026 of about 800 planned, with 412 companies in 31 markets; 23 meetings in the next seven days, 3 with Legal before they happen; 14 rung changes waiting, 7 for her; and 297 of 1,094 objectives moved up this year. Under “Needs you”, the first two lines are Hollis Marrow: approve the methane rung, and an agenda with Legal that asks for a board seat at a 6.10% holding.

    Filing Status agent, 5:30 a.m.: “Checked 23 agendas for the next 7 days: 20 clear, 3 sent to Legal, including a board-seat request at Hollis Marrow.”

  2. 02One click

    Each objective as a ladder, every note on its rung

    Claire Whitford · Head of Investment Stewardship

    Hollis Marrow opens on its three objectives, each a ladder of four rungs — Raised, Acknowledged, Plan committed, Implemented. Methane is Acknowledged since a meeting with the CSO on Sep 12, 2024; board skills is Raised since Jun 3, 2025; pay is Acknowledged since a meeting with the pay committee chair on Nov 6, 2025, and Quillfield voted against say-on-pay at the May 14, 2026 AGM, where it passed with 71.8% support. Beside the ladders runs the firm's escalation rail: the letter to the chair done on Apr 2, 2026, tomorrow's meeting with independent directors in progress.

    “At 6.10% every step is checked by the Filing Status agent first.”

  3. 03The proof

    The next rung, proposed only with the company's own words

    Evidence agent

    On Oct 15 the Evidence agent read Hollis Marrow's investor day deck and proposed Plan committed at 94% confidence. Slide 23, opened in one click: “We commit to a methane intensity of 0.20% by 2030 across our gathering and distribution assets, from 0.41% in 2024.” The target was approved by the Board on September 24, 2026, with OGMP 2.0 Level 5 reporting from 2027. Leah Brandt checked the slide against the press release and submitted it for approval.

    Below 85% confidence the Evidence agent asks a person instead of proposing a rung.

  4. 04Tuesday, 6:12 p.m.

    Item 4 asks for a board seat at a 6.10% holding

    Filing Status agent

    The agent read Leah's agenda draft v2, checked the holding — 8,742,000 shares, 6.10%, 14 funds — and applied C&DI 103.12, the firm's guidelines and its phrase library of 23 patterns. Item 4, “Request a board seat for an independent director … nominated with Quillfield's input,” is high risk. Item 5, “say we will support next year's say-on-pay if,” needs review wording. It drafted a safer question for each and sent the agenda to Rafael Mendes, due by 10:00 a.m. Wednesday.

    Claire asks why item 4 is a problem. “Asking for a board seat, or a say in who is nominated, is the clearest sign of control intent … The rewrite asks about the board's process instead.”

  5. 058:52 a.m., before the deadline

    Legal accepts the rewrite and clears the agenda

    Rafael Mendes · Legal Counsel, Securities

    Rafael accepts the rewrite of item 4 — “Ask how the nominating committee looks for energy-transition expertise in its next director search. We do not propose or endorse candidates.” He edits item 5 to share Quillfield's published pay guidelines, with voting decisions made case by case before each meeting, and clears the agenda with LC-02, cleared with edits. The agent re-checks agenda v3: all 6 items clear, and the meeting brief is ready for the engagement lead.

    Opening statement: “We are not seeking to change or influence control of the company, and we will not discuss how we will vote on directors.”

  6. 06Signed

    Maker, then checker: the rung lights up

    Claire Whitford · Head of Investment Stewardship

    Claire approves Leah's submission with reason code RG-01, “Evidence confirms the rung,” and her signature is recorded on the audit trail. Methane-intensity target is now Plan committed. The Report agent adds it to the 2026 Activities and Outcomes Report as outcome evidence, cited to investor day slide 23, and marks Hollis Marrow as a case-study candidate.

    A checker is never the maker: a lead cannot approve a rung change they submitted.

  7. 07The same day

    A 42-minute call becomes milestones, not a summary

    Notes agent

    Leah's transcript of a call with Kestrel Bay Foods' CSO becomes five proposals, each tied to its sentence: a no-deforestation soy policy proposed for Plan committed but marked verbal, with a 12-month evidence clock; the policy published by Mar 31, 2027; traceability to crusher level for 90% of soy volumes by Dec 31, 2027, from 64% today; board committee oversight twice a year; and a letter confirming what was heard. One sentence — “Claire said we'd find it hard to support the board next year if there is no policy by then” — is flagged for Legal at a 5.30% holding.

    The Filing Status agent on the flagged sentence: “I flagged it; I did not change the note.”

  8. 08Letters

    The letter in the company's language, with the English beside it

    Follow-up agent

    For Kisaragi Precision Industries in Tokyo, the agent drafts the letter to the CFO in Japanese with an English copy for the record, from Aiko Tanabe's note. Each commitment is cited: outside directors to be a majority from the June 2027 AGM, and cross-shareholdings reduced below 10% of net assets by the end of FY2027. The engagement lead approves and sends it, or returns it to the analyst.

    Agents never send a letter.

  9. 0925 months

    A stalled objective, and a group-risk warning

    Escalation agent

    Brenmoor Group has not acknowledged a request for an independent chair, or a lead independent director with defined powers, in 25 months, against an 18-month policy; two letters and a meeting request went unanswered. The agent proposes the next step on the rail, collaborative engagement. At 7.40%, the Filing Status agent warns that agreeing with other holders to act together could make Quillfield a “group” under Section 13(d)(3), and recommends a letter that only shares views. It needs Claire and Rafael.

  10. 10Report season

    The stewardship report, from approved records only

    Report agent

    The 2026 UK Stewardship Code Activities and Outcomes Report, with the SRD II engagement report and PRI answers, is 71% drafted. Every sentence cites the record behind it; the 13 rung changes still waiting and 1 verbal commitment are left out until approved. Compliance (Owen Pryce) reviews every claim, Legal reviews the section on US filing rules, and Claire signs before the FRC window closes on Apr 30, 2027.

    “Rejected and returned records are never used.”

Who it’s for

Built for everyone who carries an engagement.

Five of the people who carry Quillfield's engagements — what their year looked like, and what it looks like now.

CW
Claire WhitfordHead of Investment Stewardship · engagement lead for 61 focus companies
Head of Investment Stewardship
Before
Signs a stewardship report built from years of notes and pasted links, while agendas go to Legal by email with no record of what changed.
Now
Opens each company on its ladders, approves rungs on the company's own words, and signs a report in which every sentence cites an approved record. “Show me what moved, and prove it with the company's own words.”
LB
Leah BrandtStewardship Analyst · logs 6–10 engagements a week
Stewardship Analyst
Before
Types meeting summaries into the tracker days or weeks later; commitments, dates and names get lost on the way.
Now
Adds the transcript and accepts, edits or rejects the Notes agent's proposals the same day; submits rung changes as the maker. “I want the meeting logged before I leave the building, not three weeks later.”
RM
Rafael MendesLegal Counsel, Securities · clears flagged agendas, letters and escalations at holdings above 4.5%
Legal Counsel, Securities
Before
Gets agendas by email the day before a meeting and has to find the problem sentence himself; nothing records what he changed.
Now
Sees each flagged item with its reason, the rule and a drafted rewrite, and clears with a reason code before the deadline. “Tell me which sentence is the problem, and give me a better one.”
TR
Tom RidleyPortfolio Manager, US Large Cap Value · 61 companies under engagement
Portfolio Manager
Before
Asks the stewardship team where an engagement stands before he adds to a position.
Now
Reads the ladders for the companies in his funds and requests a new engagement, without changing a record. “Before I add to a name, I want to know where the engagement stands.”
OP
Owen PryceCompliance Testing · tests stewardship records and report claims
Compliance Testing
Before
Traces each claim in the stewardship report back to an email or a spreadsheet row by hand.
Now
Reads every note, check, proposal and decision on a hash-chained audit trail and exports the evidence by company or period. “Every claim in the report goes back to a record.”
Built on the engine

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

Six agents log notes, check every agenda for 13G risk, prove progress and draft the report; analysts submit, leads approve, Legal clears.

Notes agent

Turns meeting notes, transcripts, emails and company handouts, in any language, into objective updates, milestones with dates, commitments and follow-ups, each tied to its sentence.

  • Never edits what was said and never moves a rung
  • Marks unreadable text unreadable
  • A verbal commitment stays verbal until a public source exists
Filing Status agent

Reads every agenda, letter and escalation before it reaches a company, checks the holding today and the Schedule 13G basis against the passive-filer rules and the firm's phrase library, flags each risky item and drafts a rewrite for Legal.

  • Never clears an item — Legal does
  • Never contacts a company
  • Routes every flag to Legal with the deadline
Follow-up agent

Drafts follow-up letters in the company's language with an English copy, every commitment cited to the note.

  • Never sends — the engagement lead approves and sends
  • Never adds a demand, a deadline or a vote statement
  • Anything flagged goes to Legal
Evidence agent

Watches each company's filings, reports, slides and AGM results in any language, and proposes the next rung or a met milestone with the passage cited beside the English.

  • Never moves a rung
  • Only public sources count as evidence
  • Below 85% confidence it asks a person instead of proposing
Escalation agent

Watches the clock on every objective against the engagement policy, proposes the next step on the escalation rail and checks it for 13G and group risk with the Filing Status agent.

  • Never escalates on its own
  • Never threatens a vote — vote escalations go to the voting committee
  • Reduce or exit is the portfolio manager's decision
Report agent

Drafts the UK Stewardship Code Activities and Outcomes Report, the SRD II engagement report, PRI answers and client sections from approved records only, every sentence cited, and proposes case studies with outcome evidence.

  • Never uses a pending, returned or rejected record
  • No impact claims beyond the cited evidence
  • Never publishes — the Head of Stewardship signs
Analyst, engagement lead, Legal, Head

Maker, checker, clearance, sign-off. The agents propose; a named person decides.

Ask in plain words

Ask the agents, on every screen

Every screen has the agents in the conversation. Ask about a company, a meeting, a letter or the report, or tell them what to do — every answer cites its source, and nothing changes on a record until a person approves it.

Why is item 4 a problem?

At 6.10% Quillfield certifies on Schedule 13G that it holds the shares without a purpose of influencing control. Asking for a board seat, or a say in who is nominated, is the clearest sign of control intent; the staff guidance also names conditioned support for directors. The rewrite asks about the board's process instead.

What exactly did they commit to?

Slide 23: 0.20% methane intensity by 2030 across gathering and distribution assets, from 0.41% in 2024; approved by the Board on September 24, 2026; OGMP 2.0 Level 5 reporting from 2027. It is public and dated, which is what Plan committed requires.

Which meetings this week need Legal?

3 meetings wait for Legal: Hollis Marrow Thu 10:00 a.m. (board-seat request, high), Cobalt Ridge Mining Fri 9:00 a.m. (sale of the coal unit, high) and Brenmoor Group Mon 2:00 p.m. (wording). The other 20 are clear.

What does the group warning mean for Brenmoor?

At 7.40% in Brenmoor, agreeing with other holders to act together, on votes or on a demand, could make us a “group” under Section 13(d)(3): our shares would be counted with theirs, and a group seeking change cannot file as passive. A letter that only shares views, with no agreement on voting, is the safe form. Rafael Mendes reviews the final text before anyone signs.

Every screen

The working solution, as it ships.

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

Today: engagements, meetings and approvalsThe stewardship engagement home: engagements against plan, meetings with Legal, rung changes waiting, objectives moved up, one next step each and what the agents did overnight.
A company's objectives as laddersESG engagement tracking by objective: four rungs each, the current rung lit, every note, letter and vote on the rung it moved, the escalation rail and the agents' conversation.
The proof behind a rungThe investor day slide behind the proposed rung, opened from the ladder: a 2030 methane-intensity target approved by the board.
Pre-meeting Schedule 13G checkThe agenda checked against the holding and the passive-filer rules: a board-seat request flagged high risk, a conditioned vote to reword, rewrites drafted, and the agent explaining why.
Cleared by LegalLegal Counsel accepts the rewrite, edits a second item and clears the agenda with a reason code; the brief opens with the opening statement.
Rung approved by a second personThe engagement lead approves the analyst's submission with a reason code; the Report agent adds it to the stewardship report as outcome evidence.
A meeting note becomes milestonesThe transcript as written beside the Notes agent's proposals — a verbal rung, milestones with dates, a commitment and a follow-up — and a sentence flagged for Legal.
Follow-up letters in any languageA follow-up letter to a Japanese company drafted in Japanese, with the English copy for the record and every commitment cited to the note.
Engagement escalationObjectives past the policy clock with the proposed next step, a Section 13(d)(3) group-risk warning, who must approve, and the escalation steps taken in 2026.
Schedule 13G filing statusEvery issuer above 5% with its Schedule 13G basis, last amendment, next window, engagements this year and meetings coming.
The stewardship reportThe UK Stewardship Code 2026 Activities and Outcomes Report, SRD II engagement report and PRI answers, drafted from approved records only, with the sign-off order and exports.
Engagement audit trailEvery note, check, proposal, clearance and approval by people and agents, with the reference, evidence, reason code and hash chain.
Schedule 13G filing-status rulesThe passive-filer rules owned by Legal: thresholds by market, the phrase library, and a new version waiting for approval with its test results.
Governance

Built for stewardship engagement: cited, cleared, signed.

Every rung and sentence cites its sourceA rung moves only on a public source — a filing, a slide, a report page — opened in one click in its original language beside the English. Milestones cite the sentence of the note, and every sentence of the stewardship report cites its approved record.
A maker and a checker on every rungThe analyst submits, the engagement lead approves with a reason code and a signature, and the screen will not let a lead approve their own submission. Bulk approval leaves out own submissions, verbal commitments and low-confidence proposals.
Legal clears before a company hears itEvery agenda, letter and escalation at a holding above 4.5% is checked before it is sent. Agendas are checked 48 hours before the meeting and cleared by Legal 24 hours before; the brief is blocked until then, and only Legal can clear.
Agents propose; people decideThe agents never move a rung, clear an agenda, send a letter, escalate, vote or publish. Votes are decided by the voting committee under the published guidelines and are never stated as a condition in a meeting.
A hash-chained audit trailEvery note, check, proposal, decision and letter is recorded with who — person or agent, with its version — what, the evidence and the reason code, hash-chained and read-only for everyone, including administrators. Records are kept 7 years in their region, with legal hold.
Versioned rules, tested before they go liveThe engagement framework, escalation rail, filing-status rules and agent versions change only as a version another person approves after the evaluation runs. Filing-status rules v8 waits for Legal after 310 agenda tests with 0 missed high-risk items.
Configuration

Your engagement policy and filing rules, not ours

The ladder, the escalation rail, the filing-status rules and the clocks are settings — each change is a version one person proposes and another approves, on the audit trail.

SettingDefaultChoose from
Ladder rungsRaised · Acknowledged · Plan committed · ImplementedEvidence set per rung; framework 2026.3, approved by the Head of Stewardship
Evidence for Plan committedA public, dated commitmentOr a verbal one, marked verbal with a 12-month evidence clock, never in the report until public
Escalation clock18 months on one rungThen the Escalation agent proposes the next step on the rail
Escalation railLetter to the chair → meeting with independent directors → collaborative engagement → vote against → public statement → reduce or exitCollaborative engagement and a public statement need Legal at 13G issuers; vote against is the voting committee's; reduce or exit is the portfolio manager's
Filing-status watch (United States)Schedule 13G · watch from 4.5%10% amendment within 5 business days after the month end; Japan large-shareholding reporting at 5% and 10%
Phrase library23 patterns, owned by Legal“request a board seat”, “support … if”, “or we will consider our options”, “group letter” …; v8 adds 3 more
Agent confidence threshold85%Below it the agent asks a person; a new threshold is a version the Head approves after the evaluation
Service levelsNotes in 1 business day · rung approvals in 10 · letters in 5Late notes and rung approvals go to the Head of Stewardship, late letters to the engagement lead; each notification can be turned on or off
Connections

Works with the systems a stewardship team already runs on

CRM, email and calendarcompanies, contacts, meetings, letters sent
Portfolio accounting and order managementholdings by fund, nightly; shares outstanding from the data vendor
Beneficial-ownership filing systemSchedule 13G basis and amendments
Proxy voting platformvote records and rationales
Filings feedsEDGAR, national registers and company websites, in any language
Transcripts and documentsmeeting transcription, notes, company handouts, read-only copies of every source
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
high-risk agenda items reaching a company without Legal's clearance
Todayagendas emailed to Legal the day before
With agentsevery agenda over 4.5% checked
target
100%
of rung changes backed by a cited source and a second person
every rung
maker and checker
target
Sameday
from meeting note to milestones and a drafted letter

“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 and rules (SEC staff Schedule 13D/G C&DI 103.12, February 11, 2025; SEC Schedule 13G amendments, effective September 30, 2024; ShareAction, Rules of Engagement — 3 of 50 large asset managers). Regulatory context: FRC UK Stewardship Code 2026; SRD II Article 3g. People, firms, companies and holdings named on this page are fictional — characters and sample data in the working solution.

Questions

What stewardship teams ask about engagement tracking.

What is Stewardship Engagement Tracking?

Stewardship Engagement Tracking is engagement tracking software for investment stewardship teams: it logs every company engagement against its objectives, follows each objective up a ladder from Raised to Implemented, and drafts the annual stewardship report. Six AI agents turn notes into milestones, check every agenda for Schedule 13G risk before the meeting, draft letters in the company's language, prove progress from the company's own filings and watch the escalation clock. Analysts submit, engagement leads approve, Legal clears and the Head of Stewardship signs.

How do you track ESG engagement outcomes, not just activity?

Each objective moves up a rung only on evidence: for Plan committed, a public, dated commitment; for Implemented, a public source showing it done. The Evidence agent watches filings, reports, slides and AGM results in any language and proposes the next rung with the passage cited; an analyst submits it and an engagement lead approves it. The stewardship report counts only those approved rungs.

Can a stewardship meeting put our Schedule 13G passive status at risk?

Under the SEC staff's February 11, 2025 guidance, a holder above 5% that seeks a board seat, pressures management on specific measures or conditions its support for directors can lose its eligibility to file Schedule 13G as a passive investor. The Filing Status agent reads every agenda, letter and escalation at a holding above 4.5% against your filing-status rules, flags the sentence and drafts a rewrite. Your Legal counsel decides and clears; the agent never does.

Does it draft the UK Stewardship Code 2026 report and the SRD II engagement report?

Yes. The Report agent drafts the UK Stewardship Code Activities and Outcomes Report, the SRD II engagement report on how your SRD II engagement policy was applied, PRI answers and client excerpts from approved records only, with every sentence cited. Pending rung changes and verbal commitments are left out until approved. Compliance and Legal review, the Head of Stewardship signs, and exports are marked draft until then.

How does it handle notes, filings and letters in other languages?

Notes, company handouts and filings are read in their own language — Japanese, German and French in the sample — and every passage is shown in the original beside the English. Follow-up letters are drafted in the company's language with an English copy for the record.

How does it follow our engagement escalation policy?

The escalation rail is your policy as a setting: letter to the chair, meeting with independent directors, collaborative engagement, vote against, public statement, reduce or exit. When an objective sits on one rung past the clock — 18 months in the sample — the Escalation agent proposes the next step and checks it for 13G and Section 13(d)(3) group risk. The Head of Stewardship approves, with Legal at 13G issuers; votes stay with the voting committee and exits with the portfolio manager.

Do people stay in control?

Yes. The agents propose and explain; they never move a rung, clear an agenda, send a letter, escalate, vote or publish. Every decision carries a person, a reason code and a signature, a lead can never approve their own submission, and the audit trail is hash-chained and read-only.

How long does it take to go live?

The Agentic Solution Engine builds and deploys it from your requirements and documents — your engagement policy, escalation rail, filing-status rules and past engagement records — and it goes live once every quality gate has passed. First-time setup connects your systems and imports your engagement history from spreadsheets, and lists the rows that need a person.

See it on
your engagements.

We'll run Stewardship Engagement Tracking on a sample of your own meeting notes, agendas and last year's stewardship report.