FAQ: Implementing the Updated PRI Framework
The reporting window for Principles for Responsible Investing (PRI) signatories is currently open for the 2021 reporting season. Signatories reviewing the 2021 framework may quickly notice the increased breadth and depth of the scored questions compared to prior reporting periods.
How does the scoring work?
The Principles for Responsible Investment (PRI) report has two types of questions, Core and Plus. Core questions are mandatory, if applicable, and Plus questions are optional. Each applicable Core question is assessed out of a possible 100 points and receives a weighting of 1, 1.5 or 2. Each module is assessed as 1-5 stars based on the aggregate calculation for each module. At this time, it is unclear how the raw score correlates to the stars. There is no score for the firm, only for each module.
Do we have to complete the Plus questions?
Only the unlocked (applicable) Core questions are required to be completed. Answers to Core questions will also be publicly available in the firm’s transparency report. Plus questions are optional to complete and often are free text responses to provide additional information on a particular topic. Firms can choose whether to include Plus responses in the transparency report.
Are PRI scores publicly available?
No, module scores are only provided to the firm. The firm will receive an overall rating or score for each module, along with the ratings for their peer group. The peer groups are determined by asset class and asset under management (AUM). The firm’s responses to all Core or mandatory questions will be publicly available in the transparency report, which is available on PRI’s website . Firms may choose to promote their score or rating and many have done so in the past, especially if they received a high score. Firms may choose to promote their score or rating and many have done so in the past, especially if they received a high score.
How do we know which modules to complete?
All signatories must complete the Senior Leadership Statement (SLS), Organizational Overview (OO), and Investment and Stewardship Policy (ISP) modules. Of those, only the ISP module is scored. The SLS is required but not scored and the OO unlocks certain questions in the ISP. The OO will also determine which asset class modules must be submitted. Asset classes that represent more than 10% of the firm’s total AUM or more than $10B must be completed.
In the current reporting period, can we report on ESG processes that were implemented after December 31?
A signatory must report on their responsible investing activities annually. Although firms can stipulate their reporting years, most signatories report on the previous calendar year. Only activities that were implemented and occurred during the annual period under review may be reported. That does not mean they have to be in place for the entire year, but they must have occurred during the year. Any activities that are under consideration and not implemented during the year under review should not be reported.
This year is our voluntary reporting year. If we choose to report, will our responses be public?
If a firm chooses to report in the voluntary reporting period, the firm has the option to keep the responses private or make them public. If a firm is still developing their ESG program, or unsure how they will perform, the firm may want to keep the responses private and use it as a tool to determine where to focus their efforts in anticipation of the next reporting period.
Does PRI require a verification?
The short answer is no, it is not required. However, firms are incentivized through the scoring methodology to have some level of third-party review of their responses, along with review and sign-off from internal stakeholders. Most of the third-party assurance options require an audit process which can be difficult to execute during the short reporting period, particularly since this is new mandatory reporting this year. Firms may choose to have a third-party readiness review instead, which would result in the same score for the confidence-building measures question as an audit and is not as formal. The readiness review assesses the firm’s responses in the PRI report and identifies areas where the firm may want to improve controls or processes with the intent to have an audit conducted next year. Given the focus on ESG and green washing, we expect investor pressure will drive firms to have their responses verified.
There are questions about whether the firm publicly supports The Paris Agreement and/or TCFD. Is it enough just to have a statement on our website that we support them?
Yes, but that is just one component of supporting them. In order to effectively support them, the firm needs to have processes and other program elements in place to execute on fulfilling the mission of the Paris Agreement and/or TCFD. Starting to evaluate carbon inventory and the risks associated with climate change, like what would be identified in climate scenario analysis, are good places to start. There are several Plus questions related to carbon and climate that will likely become Core questions next year.
Webcast: Implementing the Updated PRI Framework
Join ACA’s Dan Mistler, Partner, and Crista DesRochers, Partner, for a discussion on key PRI areas where signatories may have room to improve and ways to mitigate the program gaps going forward.
The webcast recording is available to watch on demand here.
If you have questions for us on any of the topics highlighted here and how we can help you, please reach out to our ESG advisory team to request a meeting.