Case Study — Asset Management / Regulatory Strategy
An asset manager needed a defensible ESG disclosure framework built ahead of tightening reporting requirements, after years of unreconciled data from five different internal and third-party sources.
The Transformation Framework™
ESG data came from five sources — three third-party providers and two internal teams — with no reconciliation process when they disagreed, which happened on a meaningful proportion of holdings.
No team owned the judgment calls required when sources conflicted, so the most recently entered number won by default, regardless of which source was more reliable for that holding type.
We designed a source-hierarchy framework assigning a primary source by asset class and disclosure type, with a documented escalation path for conflicts — the investment team accepted narrower data-selection autonomy for defensible, explainable numbers.
The hierarchy was back-tested against two prior reporting cycles to confirm it wouldn't have materially changed already-published figures, then adopted for the next live disclosure cycle.
Holdings requiring manual escalation fell from an estimated 22% to 6%, and disclosure preparation time fell by three weeks against the prior cycle.
Measured Outcomes
Reflection
"An ESG number nobody can defend under questioning isn't a disclosure. It's an exposure with a chart attached."
Elena Marchetti — Principal, Asset ManagementEngagement team
Principal, Asset Management
Principal, Regulatory Strategy
Senior Consultant