Start with the policy
A screening policy should describe the institution’s rule before a data provider or software screen is selected. Starting with a provider’s list can cause the provider’s definitions, thresholds, and blind spots to become the policy by accident.
The policy should be specific enough that an investment, compliance, or oversight professional can tell which portfolios are covered, what activity matters, what evidence is sufficient, and what happens after a result.
Policy
What the institution has decided or is required to do.
Screen criteria
The test needed to operationalize the policy clause.
Provider screen
An available screen whose published definition is mapped to that test.
Define the policy scope
The policy needs to resolve the questions below. If it leaves one open, record who has authority to decide it and how that judgment will be documented.
Purpose
Is the policy implementing a law, client mandate, fund commitment, risk limit, ethical position, disclosure, or several of these?
Why it matters: Different purposes can require different scope, urgency, exceptions, and evidence.
Portfolio coverage
Which funds, accounts, strategies, legal entities, and delegated mandates are covered?
Why it matters: A policy that says “all assets” without defining the operating perimeter is difficult to test.
Instrument coverage
Does it apply to equity, corporate debt, sovereigns, derivatives, funds, private assets, lending, or other financing?
Why it matters: The same issuer can be treated differently across instruments if the policy does not make this explicit.
Activity coverage
Which products, services, conduct, value-chain roles, or business activities are included and excluded?
Why it matters: Sector labels are usually less precise than activity-level rules.
Corporate reach
How are direct operations, controlled entities, associated companies, joint ventures, and passive holdings treated?
Why it matters: The company held in a portfolio may not be the company conducting the activity.
Thresholds
Are revenue, ownership, voting-rights, materiality, or zero-tolerance thresholds part of the rule?
Why it matters: Thresholds must come from the policy or governing requirement. They should not be inferred from a provider’s default.
Exceptions
Are there research, transition, legacy-holding, index, client-directed, or other exceptions?
Why it matters: Exceptions need an owner, approval path, expiry date, and recorded rationale.
Required action
Does a match block a purchase, require escalation, prevent increases, trigger engagement, or require divestment?
Why it matters: A screen is only useful when the resulting action is defined.
Translate the policy into criteria
Each operative policy clause should be rewritten as a test that a reviewer can apply consistently. This does not mean building a custom provider screen; it means knowing what must be true before choosing an available screen.
Include which companies or instruments when which activity or conduct occurs through which corporate relationship, subject to which threshold or exception, based on which evidence standard.
| Mapping result | Meaning | Action |
|---|---|---|
| Exact fit | The available screen’s definition, scope, threshold, and ownership treatment match the policy test. | Select it and preserve the definition and version used. |
| Partial fit | The screen covers part of the policy but is broader, narrower, or uses different assumptions. | Document the difference and the additional control needed outside the screen. |
| No fit | No available screen reliably represents the policy criterion. | Record the gap. Do not treat the absence of a matching screen as evidence that companies comply. |
Assess screens from any provider
Screen names are not enough. Two providers can use the same label while assessing different activities, ownership relationships, thresholds, evidence, and time periods.
- What exact activity causes inclusion?
- What activities or products are expressly excluded?
- Are components, services, distribution, and enabling activities covered?
- Is there a revenue or materiality threshold, and how is it estimated?
- How are parents, subsidiaries, associated companies, and joint ventures treated?
- Which sources can support a decision, and are they visible to the client?
- What do the provider’s outcomes actually mean?
- How are missing, stale, or conflicting data shown?
- When was each company last reviewed?
- Can prior results, rationale, sources, and changes be retrieved?
A trustworthy provider should make the screen definition, inclusions, exclusions, evidence approach, company scope, and last-review information understandable. It should not require the client to infer them from a flag.
Select the available screens that fit
Once the mapping is complete, select the available screens that best represent the policy for each portfolio or watchlist. Keep the policy-to-screen mapping with the policy record so the selection can be reviewed later.
- 01
Choose by definition
Select a screen because its criteria fit the policy, not because its title sounds similar.
- 02
Record the mapping
Note which policy clause each selected screen supports and which screen version was reviewed.
- 03
Keep gaps visible
Record criteria that are only partly covered or not covered by an available screen.
- 04
Do not rewrite the result
Filtering or selecting screens changes what the client reviews; it does not recalculate the underlying company assessment.
Define what happens after an outcome
The provider supplies an assessment. The institution’s policy determines the investment, compliance, stewardship, escalation, or reporting action that follows.
Involvement identified
Confirm that the selected screen maps to the applicable policy, identify affected exposures, apply the approved action, and record the decision.
No involvement identified
Treat this as the result of a completed review under a defined screen and date. It is not a universal statement that no involvement exists.
Not yet evaluated
This is a placeholder, not a result. The policy should say whether trading is restricted, allowed with approval, or permitted while the review is queued.
Qualifiers should change the workflow
Evidence incomplete
Identify what is missing and whether a temporary restriction is needed.
Evidence conflicting
Escalate the conflict and preserve the reason for the selected source.
Evidence stale
Set a refreshed review date based on policy risk and materiality.
Review required
Keep the latest approved outcome visible while a new review is completed.
Set response times before an issue occurs
There is no single response time that fits every screen. The governing law, mandate, contract, exposure, materiality, and available facts determine urgency. The policy should assign response targets, owners, and temporary controls in advance.
| Trigger | Before investing | If already held |
|---|---|---|
| Hard legal or mandate prohibition | The relevant screen should be evaluated before the transaction is approved. | Escalate immediately, prevent further exposure where appropriate, and follow the approved legal or mandate-specific procedure. |
| Credible potential breach | Route for priority review and apply a temporary restriction if the policy requires it. | Triage promptly, identify affected portfolios, preserve the evidence, and assign a decision owner. |
| Client-specific exclusion | Check the account’s mandate and selected screens before trading. | Follow the contractual escalation and reporting timetable for that client. |
| Informational or stewardship screen | Make the information available to the investment or stewardship process. | Review within the policy’s normal cadence unless the new information is material. |
These are operating principles, not legal deadlines. The policy owner should obtain jurisdiction- and mandate-specific advice where timing is legally or contractually prescribed.
Resolve conflicting data without hiding it
Conflicting evidence is normal in company research. The goal is not to average incompatible claims; it is to make a supportable decision and preserve why it was made.
- 01
Preserve both sources
Keep the conflicting records, dates, excerpts, and the company or activity each one addresses.
- 02
Compare their role
Assess authority, directness, specificity, recency, scope, and whether one source relies on the other.
- 03
Seek the missing fact
Use a filing, official record, company response, ownership record, or other suitable evidence to narrow the conflict.
- 04
Apply the policy’s interim control
If the conflict is material, decide whether to restrict, escalate, or continue under approval while review proceeds.
- 05
Record the judgment
Explain which source was relied on, why, who approved the decision, and what would cause it to be reopened.
Preserve the decision, not only the flag
An audit trail helps an institution demonstrate that it applied a defined process consistently. It also lets internal oversight, regulators, auditors, and clients understand what information was available and why an action was taken at that time.
- 01The policy clause and version applied
- 02The portfolio, account, company, and instrument affected
- 03The provider screen and criteria mapped to the policy
- 04The outcome, qualifiers, and relevant corporate relationship
- 05The sources used and why they were considered appropriate
- 06Any conflict, gap, exception, or judgment
- 07The action taken, owner, approval, and date
- 08The next review date or event that will reopen the decision
Why history matters
A later outcome does not prove an earlier decision was unreasonable. Versioned evidence and notes show what changed and whether the institution responded appropriately.
Assign governance and review the policy
The policy should identify who owns it, who selects and reviews screens, who can approve exceptions, who acts on results, and who tests the control. Review it on a defined cycle and after material legal, mandate, methodology, provider, or portfolio changes.
Policy owner
Approves purpose, scope, criteria, exceptions, actions, and material changes.
Screening owner
Maps available screens to policy clauses and records coverage gaps.
Decision owner
Reviews results and evidence, applies qualifiers, and approves the documented action.
Oversight function
Tests whether the policy, screen selection, decisions, exceptions, and history are operating as designed.
Clients can select available screens for portfolios and watchlists, review source-backed outcomes, see screen definitions and review dates, filter results, preserve history, submit evidence, and request re-evaluation. The client remains responsible for its policy, the mapping of that policy to available screens, and the action taken.