Methodology note
Screening data coverage and as-of dates
An exclusion screen needs a verdict for every holding from an approved source with a stated as-of date. An unscreened holding means the book cannot report "no exclusions". Any excluded holding is a breach regardless of weight, with the weight reported for materiality.
exclusion_list · Permitted and prohibited investmentsinstrument_list · Eligibility tests (investment grade, listing, domicile)eligibility_testCoverage first
A screen reads a verdict field for each holding, supplied by an approved data source. Holdings without a verdict are unscreened.
With coverage required, unscreened holdings block a clean reading (SCREEN_COVERAGE_INCOMPLETE). The rule can relax that requirement, but a clean result then covers only the screened holdings.
Weight does not decide
Any excluded holding is a breach, however small. A 1% position in an excluded company breaches as surely as a 30% one, and the weight is reported for materiality.
That differs from a concentration limit, where size is the test. Write exclusion clauses accordingly.
Source and as-of date
Record the source, the dataset and the as-of date with each screen. Vendors reclassify companies, and a screen run against last quarter's list may miss a new exclusion.
Vendor errors happen. A Spanish fund's 2026 breach log attributed part of a fossil-fuel excess to an ESG vendor's misclassification of a supermarket chain.
Pitfall: lists and screens
A prohibited list names the holdings itself, while a screen relies on a vendor's verdicts. Lists suit a few named exclusions or sanctioned countries; screens suit categories such as thermal coal.
Either way, the result should name the offending holdings, so the case starts with the right sale. A list is also easier to audit, because the rule itself fixes its contents.
Worked example
One excluded holding worth 1% of the book is enough: the screen reads breach, with the 1% reported for materiality.
Rule template:exclusion_list screen: esgfieldCode: ESG_SCREENexcludedValues: excludedsourceName: Approved ESG screensourceAsOf: 2026-06-01requireScreenCoverage: true
| Holding | Market value | ESG_SCREEN |
|---|---|---|
| Screened core holdings | 990 | pass |
| Tobacco company | 10 | Excluded |
| Group | Status | Value | Bounds | Headroom to the hard bound | Code |
|---|---|---|---|---|---|
| ESG exclusions | Breach | 1% | – | – | EXCLUDED_HOLDING_PRESENT |
EXCLUDED_HOLDING_PRESENT: At least one holding matched the approved exclusion list.
Largest contributors: ESG exclusions → Tobacco company 1%
Computed at build time by the Acclimetry rule engine (backend commit 8197063); the same code runs in the product.
Questions
Is a holding with no verdict treated as excluded?
No. It is unscreened, which blocks a clean reading but does not count as an excluded holding.
How often should screens be refreshed?
As often as the vendor updates its list, and ideally before each monitoring run. Record the as-of date the screen used.
Sources
- Santalucía Ibérico Acciones FI, semi-annual report for the first half of 2026 (CNMV format) · terms not verified · Read on12 October 2026