Test a fund’s ESG screens and exclusions against its holdings
Key facts
- Human involvement
- YellowClose supervision
- How AI is used
- Extract every screen, exclusion and sustainability representation from the fund’s disclosure documents, website and marketing, then compare each with the holdings file and the issuers’ sector and revenue data, listing every holding that appears to fall inside a stated exclusion with the representation and the data point cited.
- What the lawyer must review
- The lawyer decides whether each flagged holding actually breaches the representation as an investor would read it, whether any threshold or exception in the documents applies, what the fund must change (the holding, the wording or both), and whether past statements need correcting.
- Written for / version
- US
Open a jurisdiction version of this task to see which instruments apply: US
Who does what
| Role | What they do |
|---|---|
| Assistance | Extract every screen, exclusion and sustainability representation from the fund’s disclosure documents, website and marketing, then compare each with the holdings file and the issuers’ sector and revenue data, listing every holding that appears to fall inside a stated exclusion with the representation and the data point cited. |
| Lawyer | Set the scope, supervise the work closely, verify every part relied on, resolve omissions and exceptions, and approve the exact output. |
Checklist
- Check every representation is captured, including website, marketing and media statements, not only the disclosure document.
- Confirm the holdings file and the sector data are as at the same date.
- Check each flagged holding against the issuer’s own reporting before treating it as a breach.
Sources
- ASIC INFO 271 — How to avoid greenwashing when offering or promoting sustainability-related products · 2026-10-18
- ASIC 25-042MR — Active Super ordered to pay $10.5 million penalty in ASIC’s third greenwashing court action · 2026-10-18
These are suggested working checks. Confirm the required checking with the responsible lawyer before work starts; the checking approach does not establish permission to use AI.