ESG Rating Methodology Disclosure - (EU) 2024/3005

Annex III 1(f) · Delegated Regulation Article 3(1)

Objective and materiality

The Integrum ESG Grade assesses how well a company manages the sustainability and governance issues that are financially material to its business. It is a risk rating. It covers:

• sector-specific sustainability risks, as identified in the SASB Standards, which the International Sustainability Standards Board (ISSB) now maintains
• corporate governance risks, assessed under the Minerva Analytics framework.

Two further in-house ratings sit alongside the ESG Grade and do not feed into it:

• Climate Risk grade: assesses how a company manages climate-related risks and opportunities under IFRS S2. It is also a risk rating.
• Impact Score: assesses a company’s contribution to the UN Sustainable Development Goals using the Cambridge Impact Framework. It measures impact.

None of these three in-house ratings combines risk and impact.

Consensus Score: this provides an indicative external consensus assessment of a company’s ESG performance, powered by CSRHub. It combines assessments from providers with different approaches to ESG issues. It does not apply our in-house Awareness and Performance scoring rules and is reported separately from our in-house ESG Grade.

Sovereign scores: assess how a country performs on environmental, social and governance issues, using 36 metrics built from public data. The overall result is shown as a Total ESG Risk Grade from A to E. It is a risk rating.

Fund and portfolio scores: summarise the scores of the holdings in a fund or portfolio and share the objective of the ratings they are built from.

Where disclosed: Methodology Summary, pages 5 to 36; Scoring Framework summary sheet; Consensus ESG Score Methodology; Country ESG Dashboard sheet

Annex III 1(g) · Delegated Regulation Article 3(2)

Scope of the ratings

The ESG Grade is an aggregated rating covering environmental, social and governance factors. It is built from two dimensions:

• Sustainability: the 26 issue categories in the SASB Standards, assessed through 44 sub-metrics and scored where they are material to a company’s subsector. Between 2 and 11 categories are material to each subsector. The SASB categories span five areas: environment; social capital; human capital; business model and innovation; leadership and governance.
• Governance: nine corporate governance metrics, assessed through 39 sub-metrics, from the Minerva Analytics framework, covering board structure, oversight, incentives, accountability and shareholder protections. These apply to every company.

The Climate Risk grade is a separate rating covering the environmental factor only, through four IFRS S2 climate metrics. The Impact Score is a separate rating covering six environmental and social themes linked to the UN Sustainable Development Goals. The specific issues covered by each rating are listed under item 1(i).

Consensus Score: CSRHub aggregates assessments across 12 subcategories within four categories: Environment, Community, Employees and Governance. Environment covers the E factor, Community and Employees together cover the S factor and Governance covers the G factor.

Sovereign scores: an aggregated rating covering all three factors, through 13 environmental metrics (20 sub-metrics), 14 social metrics (26 sub-metrics) and 9 governance metrics (10 sub-metrics).

Fund and portfolio scores: the same scope as the ratings of the holdings they are built from.

Where disclosed: Methodology Summary, pages 5 to 23; Scoring Framework summary sheet; Consensus ESG Score Methodology; Country ESG Dashboard sheet

Annex III 1(h)

Weighting of E, S and G

By default, the overall ESG score is the average of the Sustainability and Governance dimension scores, so each dimension carries 50%. Within each dimension, every material metric carries equal weight, because the ISSB does not treat any of the issues it identifies as material for an industry as more important than the others.

As a result, the weight of each factor depends on the company’s subsector. The Governance dimension accounts for 50% and covers governance only: every one of its sub-metrics counts as governance. The other 50% is shared equally among the SASB categories material to the company’s subsector. The Sustainability sub-metrics cover environmental and social issues. Environmental sub-metrics such as greenhouse gas emissions, energy and water are material to more subsectors, so across all subsectors they make up about half of the Sustainability dimension’s assessments. On average, E carries just under a quarter of the ESG Grade, S just over a quarter and G half. SASB’s leadership and governance categories count as social, so the governance factor comes only from the Governance dimension.

The split between E and S within that 50% therefore varies by subsector, from wholly social to wholly environmental.

The six Impact metrics are also weighted equally by default. The Climate Risk grade and the Impact Score are not included in the ESG Grade.

The four IFRS S2 metrics are weighted equally within the Climate Risk grade, at 25% each.

Consensus Score: the category weights set out in the Consensus methodology are 3.7 for Environment, 2.6 for Community, 2.8 for Employees and 2.9 for Governance, normalised to 100%. These correspond to approximately 30.8% E, 45.0% S and 24.2% G. They reflect CSRHub’s consensus user weightings and are separate from the default Sustainability and Governance weights used in our in-house ESG Grade. Source weights and normalisation parameters can change as CSRHub optimises its model.

Sovereign scores: by default, the environmental and social scores each carry 25% of the overall score and the governance score carries 50%. Clients can change this blend in their own profile.

Fund and portfolio scores: the average of the holdings’ scores, weighted by each holding’s share of the fund or portfolio.

Where disclosed: Methodology Summary, pages 35 to 36; Consensus ESG Score Methodology; Country ESG Dashboard sheet

Annex III 1(i)

Topics covered

ESG Grade, Sustainability dimension: GHG Emissions; Air Quality; Energy Management; Water & Wastewater Management; Waste & Hazardous Materials Management; Ecological Impacts; Human Rights & Community Relations; Customer Privacy; Data Security; Access & Affordability; Product Quality & Safety; Customer Welfare; Selling Practices & Product Labeling; Labor Practices; Employee Health & Safety; Employee Engagement, Diversity & Inclusion; Product Design & Lifecycle Management; Business Model Resilience; Supply Chain Management; Materials Sourcing & Efficiency; Physical Impacts of Climate Change; Business Ethics; Competitive Behavior; Management of the Legal & Regulatory Environment; Critical Incident Risk Management; Systemic Risk Management. Only the categories material to a company’s subsector are scored.

Climate Risk grade, IFRS S2 metrics: Climate Governance; Climate Strategy; Climate Risk Management; Climate Metrics & Targets.

ESG Grade, Governance dimension: Management Process; Board Composition; Risk Management; Community Engagement; Audit; Remuneration Alignment; Remuneration Balance; Director Contracts; Shareholder Dilution Risk.

Impact Score: Basic Needs; Wellbeing; Decent Work; Resource Security; Healthy Ecosystems; Climate Stability.

Consensus Score: Community covers Community Development & Philanthropy, Human Rights & Supply Chain and Product. Employees covers Compensation & Benefits, Diversity & Labor Rights and Training, Safety & Health. Environment covers Energy & Climate Change, Environment Policy & Reporting and Resource Management. Governance covers Board, Leadership Ethics and Transparency & Reporting.

Sovereign scores, environmental metrics: Carbon Footprint; Water Consumption; Waste; Protecting Natural Environments; Climate Change Risk; Climate Change Mitigation; Biodiversity; Energy Efficiency, Infrastructure and Security; Food and Agriculture; Pollution; Resource Depletion; Transport Infrastructure Needs; Water Infrastructure Needs.

Sovereign scores, social metrics: Poverty; Life Chances; Decent Work; Affordable Energy; Personal Safety; Gender Equality; Demographics; Economic Inequality; Education; Health Infrastructure and Issues; Innovation and Human Capital; Labour and Social Protection; Lifestyle Risks; Vulnerability.

Sovereign scores, governance metrics: Corruption; Political Stability; Human Rights; Transparency; Democratic Life; Political Effectiveness; Rent Dependency; Security; Economic Freedom.

Correspondence with the European Sustainability Reporting Standards (ESRS): our topics are not taken from the ESRS, and we have not mapped them to ESRS topics.

Where disclosed: Methodology Summary, pages 5 to 34; Consensus ESG Score Methodology; Country ESG Dashboard sheet

Annex III 1(j)

Absolute and relative results

Our ratings use both. Awareness Scores are absolute: each company is scored 0 to 4 against fixed rules on whether it acknowledges an issue, has a policy and sets targets. Performance Scores are relative: a company’s reported figure is ranked in quartiles against all companies in the same subsector worldwide, or against our full coverage universe for Impact metrics, and a company that does not report the figure scores 0. For quantitative metrics, the two scores are averaged. Some governance metrics use fixed boundaries instead of quartiles, for example the vesting period of long-term incentive plans.

Letter grades from A to E are assigned using standard deviation bands around 2, the midpoint of the 0 to 4 scale. The meaning of each score and grade is set out under item 1(a).

Consensus Score: CSRHub provides an absolute rating on a 0 to 100 scale and relative percentile rankings on a 0 to 100 scale, with industry and country comparisons. Higher scores and rankings indicate stronger assessments. We also present Consensus scores as A to E grades. These outputs are distinct from our in-house 0 to 4 Awareness and Performance Scores.

Sovereign scores: Awareness Scores are absolute: each country is scored 0 to 4 against fixed thresholds, for example energy-related CO2 emissions per person. Performance Scores are relative: a country is ranked in quartiles against its peer group (see item 1(b)).

Fund and portfolio scores: built from the absolute and relative scores of their holdings.

Where disclosed: Methodology Summary, pages 5 to 7, 22 to 23 and 35; Heatstrips information sheet; Consensus ESG Score Methodology; Country ESG Dashboard sheet

Annex III 1(o) · Delegated Regulation Article 3(3)

Environmental factor and the Paris Agreement

ESG Grade: climate is assessed through the SASB categories in the Sustainability dimension. These include GHG Emissions, which covers Scope 1 and 2 emissions, the company’s strategy to manage emissions and, for financial companies, financed emissions (Scope 3, category 15), as well as Energy Management, Physical Impacts of Climate Change and Business Model Resilience.

Climate Risk grade: the four IFRS S2 metrics assess Climate Governance, Climate Strategy, Climate Risk Management and Climate Metrics & Targets. They reward verified emission reduction targets and rank companies against peers on measures including emissions intensity and climate value at risk.

The scoring rules for the ESG Grade and the Climate Risk grade do not refer to the Paris Agreement directly. The highest Climate Metrics & Targets score requires a company to disclose its Scope 1 and 2 emissions, with the data assured by a third party or following third-party standards such as the GHG Protocol. The company must also have a verified target in place to reduce its carbon emissions.

Implied Temperature Rise: our measure most directly relevant to the Paris Agreement. It compares a company’s emissions trajectory with a global carbon budget and translates the result into a temperature alignment: the warming, in degrees Celsius, that would follow if every company behaved the same way. This can be read against the Agreement’s goal of holding warming well below 2°C and pursuing efforts to limit it to 1.5°C. It uses constants from a University of Cambridge model and is based on the company’s latest reported emissions rather than its targets. It is reported separately from the ESG Grade and the Climate Risk grade.

Consensus Score: climate-related assessments enter through CSRHub’s Energy & Climate Change subcategory. The underlying providers use different measures and methodologies. The Consensus methodology does not specify a single test of Paris Agreement alignment applied across all those inputs, and the Consensus Score is not a temperature-alignment result.

Sovereign scores: the top score for CO2 emissions per capita requires energy-related emissions below 0.5 tonnes per person, in line with 1.5°C pathways towards mid-century. A separate metric scores a country on how many of 14 international environmental agreements it has signed, including the Paris Agreement. The scores do not test whether a country’s own climate commitments are aligned with the Agreement.

Where disclosed: Methodology Summary, pages 5 to 19 and 37 to 38; Temperature Score information sheet; Consensus ESG Score Methodology; Country ESG Dashboard sheet

Annex III 1(p) · Delegated Regulation Article 3(3)

Social and governance factors and international agreements

Social issues are assessed under the SASB Standards, including Human Rights & Community Relations, Labor Practices and Supply Chain Management. Corporate governance is assessed under the Minerva Analytics framework.

The ESG Grade takes recognised standards into account through the scoring rules for individual metrics. For qualitative Sustainability metrics, higher Awareness Scores can reflect an audited or standardised policy, or a policy subject to review or oversight, with further credit for targets where the metric’s rules require them. Supplier labour-audit scoring instead considers disclosure of supplier audit coverage and targets. The scoring rules do not name specific international agreements.

Consensus Score: CSRHub’s social and governance topics include human rights, labour rights, supply chains, leadership ethics and transparency. Its methodology refers to International Labour Organization conventions within Diversity & Labor Rights and participation in the UN Global Compact within Transparency & Reporting. These are topics considered within the source assessments, rather than a single certification that a company complies with every agreement.

Sovereign scores: social and governance metrics use indicators published by international bodies, such as the World Bank, the World Health Organization, the International Labour Organization and UN agencies. The scores do not assess alignment with specific international agreements on social or governance matters.

Where disclosed: Methodology Summary, pages 5 to 7 and 20 to 23; Consensus ESG Score Methodology; Country ESG Dashboard sheet

Annex III 1(a) · Delegated Regulation Article 4(1)

Overview of our methodologies

Methodology: Integrum ESG Methodology Summary, version 2026.1.

Rated items: listed and private companies, funds and portfolios (scored from their holdings) and sovereigns

How ratings are built: Each material metric is scored from 0 to 4 for Awareness and, where the metric is quantitative, for Performance. Metric scores are combined into dimension scores and an overall ESG score, which is converted into a grade from A to E. The Climate Risk grade and the Impact Score are built from their own metrics on the same 0 to 4 scale and reported separately from the ESG Grade. Every score can be traced to the company data behind it through our Glass Box, which shows the excerpt and the report page it comes from.

Rating categories: Awareness Scores run from 0, where a company does not acknowledge an issue, to 4, the highest level of policy, disclosure and target-setting in each metric’s scoring rules. Performance Scores run from 0, where the key figure is not disclosed, to 4, where the company is in the top quartile of its subsector. Grades run from A, for scores more than 1.5 standard deviations above the midpoint of 2, to E, for scores more than 1.5 standard deviations below it. A C grade covers scores within 0.5 standard deviations of the midpoint.

Key rating assumptions: material issues are set by subsector; each material metric carries equal weight by default; the Sustainability and Governance dimensions carry equal weight in the overall score; a company that does not disclose a key figure scores 0 for Performance.

Supporting models: our proprietary data extraction models, described under item 1(k), and a University of Cambridge model for the Implied Temperature Rise.

Data quality: an automated data-cleaning process checks millions of datapoints a month for inconsistencies, and an ESG analyst reviews every datapoint before it is published.

Time horizon: our in-house company analysis mainly uses the latest data each company has published. We update our data within 10 days of a new report. Forward-looking elements enter through the targets companies set, which raise their Awareness Scores. Most companies publish annual and sustainability reports once a year, so the underlying data generally reflects one reporting year. A rating may change between reports as new data, corrections or updated peer benchmarks are incorporated.

Most recent methodology update: version 2026.1, 27 October 2026. This is the first numbered version of the methodology. It replaces the edition dated 22 October 2025, corrects drafting errors in it and clarifies that the Climate Risk grade is reported separately from the ESG Grade. It describes how our ratings are calculated today and does not change them. Later versions will set out what has changed from the previous one. Ongoing changes are recorded in our Release Notes.

Consensus methodology: the separate Consensus ESG Score Methodology describes CSRHub’s collection of ratings and other ESG assessments, mapping of inputs to subcategories, conversion to a 0 to 100 scale, adjustment for source biases, weighting and aggregation. Source ratings are fitted to a beta distribution during conversion. Inputs are combined into subcategory, category and overall scores, subject to minimum data-quality and source-coverage rules. Consensus ratings are updated approximately monthly as sources change or are updated.

Sovereign methodology: each of the 56 sub-metrics is scored 0 to 4 for Awareness, against fixed thresholds, and for Performance, against the country’s peer group. By default the two scores carry equal weight. A sub-metric without reliable data scores 0 unless its rules state otherwise. Scores combine into environmental, social and governance scores, an overall score and a grade from A to E. Each country’s Glass Box shows why it has its score and where the data comes from.

Fund and portfolio methodology: scores are calculated from the scores of the underlying holdings, looking through any fund held in a portfolio to the companies it holds. Holdings come from fund holdings data or, for client portfolios, from the client’s upload. The aggregation method is set out under item 1(h). A fund’s own score includes proxy scores for holdings that need them. A portfolio score includes them only when the client switches proxy scores on.

Funds and portfolios use grading bands half as wide as the company bands, centred on the same midpoint of 2. Averaging holdings tends to bring scores closer together, so narrower bands help distinguish funds and portfolios that would otherwise fall within the same grade.

Where disclosed: Methodology Summary; Scoring Framework summary sheet; Glass Box information sheet; Consensus ESG Score Methodology; Country ESG Dashboard sheet

Annex III 1(b) · Delegated Regulation Article 4(2)

Industry classification

We use the Sustainable Industry Classification System (SICS), issued with the SASB Standards and now maintained by the IFRS Foundation through the ISSB. Every company is assigned to one of its 77 industries, which we call subsectors, grouped into 11 sectors. The subsector determines which SASB issue categories are material to a company and sets its peer group: Performance Scores rank a company against all companies in the same subsector worldwide. For proxy scores, subsectors are combined with four regions: North America, Latin America, EMEA and Asia.

SICS version: the 77-industry classification in the latest edition of the SASB Standards, which the ISSB last amended in December 2023.

Consensus industry classification: CSRHub uses its own industry groupings, based loosely on the North American Industry Classification System (NAICS) with additional groupings. These support its industry benchmarks and are separate from the SICS classification used for our in-house company ratings.

Sovereign scores do not use an industry classification. By default, each country is compared with the other countries in its region: East Asia and Pacific; Europe and Central Asia; Latin America and the Caribbean; Middle East and North Africa; North America; South Asia; or Sub-Saharan Africa. Clients can change the peer group in their own profile.

Where disclosed: IFRS Foundation: Understanding the SASB Standards; Proxy Scores methodology sheet, section 3; Consensus ESG Score Methodology; Country ESG Dashboard sheet

Annex III 1(c) · Delegated Regulation Article 4(3)

Data sources and processes

Company data comes from the annual reports, sustainability reports and other documents companies publish on their corporate websites. These are public sources and include sustainability statements where companies publish them. Governance data is provided by our partner Minerva Analytics, which compiles it from public company disclosures.

Private companies assessed through our data capture portal submit their own data when an investor client invites them. Our research team validates each submission before it is scored.

Company financial data, such as revenue, is licensed from EODHD and used to express Performance Values relative to the size of the company. Identifiers such as ISINs, LEIs and tickers are licensed from Exchange Data International (EDI), along with issuer information. Where company disclosures leave gaps, the ESG Grade and the Impact Score use supplemental ESG data licensed from LSEG (Refinitiv). Fund holdings and fund reference data are licensed from Finnhub; fund and portfolio scores are calculated from our own company scores.

Consensus data is licensed from CSRHub. It combines assessments from ESG rating firms, specialist data providers, non-governmental organisations, government databases, research reports and other sources. The contribution of each source depends on the information it supplies, the relevant subcategory and CSRHub’s normalisation and weighting process.

Sovereign data comes from public datasets published by international organisations and research bodies, including the World Bank and its Worldwide Governance Indicators, the World Health Organization, UN agencies, the International Labour Organization, the Energy Institute, the Notre Dame Global Adaptation Initiative and Transparency International. Sovereign data is refreshed every six months.

Our proprietary AI models extract and structure the data, an automated data-cleaning process checks it for inconsistencies and an ESG analyst reviews every datapoint before it is published.

Where a company discloses too little to be rated, clients can choose to apply proxy scores, based on the average scores of companies in the same subsector and region. In portfolio views, proxy scores are off by default, and the share of holdings shown using proxies is stated. A fund’s own score always includes proxy scores for the holdings that need them.

Engagement with rated companies: rated companies can contact us to raise factual errors in the data we hold on them. Our research team reviews each request and amends data only where it finds an actual error. Because our ratings are based on what companies disclose, a company’s published disclosures take priority over statements that contradict them. Where there is a contradiction, we tell the company, and it is for the company to correct its disclosure. Any change is based on evidence and our methodology, never on commercial considerations.

Where disclosed: Methodology Summary, pages 3 to 4 and 20 to 23; Proxy Scores methodology sheet; Statement of compliance; Consensus ESG Score Methodology; Country ESG Dashboard sheet

Annex III 1(e) · Delegated Regulation Article 4(4)

Scientific basis

The ESG Grade is built on established standards rather than on scientific research of our own. Materiality follows the SASB Standards, which were developed over five years with input from multiple stakeholder groups, and governance follows the Minerva Analytics framework. The Impact Score follows the Cambridge Impact Framework, developed at the University of Cambridge Institute for Sustainability Leadership with a group of impact-focused fund managers. The Implied Temperature Rise uses constants from a University of Cambridge model.

Consensus supporting model: CSRHub converts different types of source assessments to a common scale, normalises systematic differences between sources and applies weights before aggregation. The Consensus methodology explains this statistical process and its coverage rules; it is a separate model from our in-house scoring rules.

Where disclosed: Methodology Summary, pages 5, 20 to 25 and 38; Consensus ESG Score Methodology

Annex III 1(k)

Use of artificial intelligence

AI is central to how we collect data. More than 200 proprietary machine learning models, each trained on a specific ESG metric, read company reports and extract the relevant data. A data-centric AI process using semi-supervised learning checks millions of datapoints each month for inconsistencies.

AI does not publish data unreviewed. An ESG analyst checks every datapoint before it appears, and analysts’ corrections are fed back into the models. Scores are then calculated by fixed rules from the reviewed data.

A separate natural language processing model classifies ESG-related news as positive, negative or neutral for our Real-Time ESG Sentiment data, which is reported separately from the ESG Grade.

Limitations and risks of our use of AI: a model can misread or miss a datapoint, particularly where a report uses an unusual format or terminology, and it can only extract what a company has published. Analyst review of every datapoint before publication is how we manage this risk. Sentiment classification can misjudge the tone of a news item; Real-Time ESG Sentiment is reported separately and does not feed into the ESG Grade.

Where disclosed: Methodology Summary, pages 3 to 4 and 58 to 60; Our AI

Annex III 1(m) · Delegated Regulation Article 5

Limitations of data and methodology

• Our ratings depend on what companies disclose. A company that does not report the figure a quantitative metric needs receives a Performance Score of 0, so a low score can reflect limited disclosure as well as weak performance.
• Performance Scores rank companies against peers, so a company’s score can move when its peers’ results change, even if its own do not.
• By default every material issue carries equal weight, which may not reflect how much each issue matters to a particular company.
• Proxy scores use subsector and regional averages. They indicate the typical risk in a peer group, not the position of the company itself.
• The Implied Temperature Rise uses a company’s latest annual emissions and fixed model constants, so by default it assumes emissions stay at current levels.
• The Impact Score covers the six themes in the Cambridge Impact Framework and does not capture every way a company affects the UN Sustainable Development Goals.
• The Climate Risk grade is being rolled out by subsector and is not yet available for every company.
• A company is assessed against the materiality of the one subsector it is assigned to, so activities that fall outside that subsector are not scored.
• Performance Values expressed per $1m of revenue depend on third-party financial data, so a missing or out-of-date revenue figure affects the Performance Score.

Consensus scores depend on the range, quality and agreement of the underlying sources. CSRHub may suppress a subcategory or category where data weight or source coverage is insufficient, or where scores are extreme. A full rating requires coverage across all four categories and at least five subcategories, alongside its source and data-weight requirements. A partial rating does not represent the same breadth of coverage as a full rating.

Sovereign scores rely on public datasets that are published with a lag and do not cover every country for every metric. A sub-metric without reliable data scores 0, which can lower a country’s score. Regional peer groups vary in size, from 2 countries in North America to 48 in Europe and Central Asia, so a Performance Score in a small region rests on few comparisons.

Fund and portfolio scores depend on complete and current holdings data, and on how many of the holdings we cover. Because a fund’s score includes proxy scores, a fund whose holdings disclose little can have a score based mainly on proxies.

Where disclosed: Methodology Summary; Proxy Scores methodology sheet; Temperature Score information sheet; Consensus ESG Score Methodology; Country ESG Dashboard sheet

Annex III 1(q) · Delegated Regulation Article 5

Limitations of available information

• Coverage is limited by the number of companies that publish meaningful ESG data. Smaller companies and companies in markets with lighter reporting requirements tend to disclose less.
• Most companies report once a year. We update our data within 10 days of a new report, but between reports our data reflects the company’s last published figures.
• Our ratings use figures as companies report them, and not all reported data is assured by a third party.

Consensus coverage and timeliness depend on the data available from its contributing sources. Different sources cover different companies and update at different times. Mapping their assessments to common subcategories requires judgement, and model parameters may change over time.

Where disclosed: Proxy Scores methodology sheet, section 1; Consensus ESG Score Methodology

Annex III 1(d) · Delegated Regulation Article 6(1)

Ownership structure

Integrum ESG AB is a Swedish limited company (organisation number 559606-4534) and is wholly owned by Integrum ESG Ltd, a company registered in England and Wales (company number 11857070).

Integrum ESG Ltd
England and Wales, company number 11857070
Parent undertaking

↓ 100% owned

Integrum ESG AB
Sweden, organisation number 559606-4534
Provides our ESG ratings in the EU

Neither entity carries out any of the activities listed in Article 16(1) of the Regulation. Alongside our ESG ratings, we provide ESG data, screening and reporting tools to our clients. These are other services within the meaning of Article 16(6); none of them is consulting or advice.

Where disclosed: Statement of compliance with the EU ESG Ratings Regulation

Annex III 1(l) · Delegated Regulation Article 6(2)

Fees and business model

Clients pay an annual subscription for access to our ratings, data and tools. Standard prices depend on the products and coverage a client subscribes to. Where a larger client needs additional work, we set a bespoke price based on its use case and the work involved. The same criteria apply to every client, and the price never depends on the ratings a client receives.

Our business model is subscription-paid: investors pay for access to our ratings, data and tools. Subscriptions account for 100% of our total annual revenue.

Our ESG ratings are priced on the same criteria whatever other services, such as ESG data and reporting tools, a client also subscribes to.

Annex III 1(n) · Delegated Regulation Article 6(3)

Conflicts of interest

Integrum ESG Ltd’s Conflicts of Interest Policy sets out how the company identifies, records, manages and, where appropriate, discloses actual, potential and perceived conflicts of interest. It applies to employees, directors, contractors, consultants and other persons acting on its behalf.

The policy requires methodologies, classifications, controversy assessments, ESG data outputs and analytical judgements to be free from client or issuer pressure, sales considerations, investor relationships and other improper influence. The main areas where conflicts may arise include:

• Client interests: clients who invest in rated companies may prefer particular ratings. Our standard ratings follow the published methodology. Clients may change weightings for their own view, but those changes do not alter our standard ratings.
• Relationships with rated companies: a company we assess may also be a client, supplier, partner, investor, prospective client or other commercial counterparty. Private market clients may also collect data from their own portfolio companies through our data capture portal. These relationships must not improperly influence our analytical conclusions.
• Personal interests, gifts and hospitality: personal, financial or family interests and other benefits may influence, or appear to influence, professional judgement. Relevant interests must be disclosed. Benefits that could reasonably influence judgement or create a perception of improper influence must not be offered, solicited or accepted.
• Other services, partnerships and incentives: outsourcing, data supply, referral, reseller and partnership arrangements may affect independence. Sales targets, remuneration arrangements and commercial incentives may also create pressure on research quality, methodology or client fairness.
• Confidential information: information received from one client or counterparty must not be used for the benefit of another or for any unauthorised purpose.

Anyone covered by the policy must report conflicts as soon as they arise or become apparent, either to the CEO or to the relevant Head of Team. A Head of Team must escalate the matter promptly to the CEO. The CEO oversees the policy, assesses material conflicts, determines appropriate mitigation and maintains the conflicts register. A conflict involving the CEO is escalated to the Chair or another appropriate Board representative.

Material conflicts are recorded in the register together with the assessment, mitigation, any disclosure provided and any follow-up action required.

Depending on the nature and seriousness of the conflict, controls may include separating commercial discussions from analytical decisions, restricting access to confidential information, excluding conflicted individuals, requiring independent review or senior approval, documenting material judgements or corrections and disclosing the conflict where appropriate. An engagement, relationship or activity may be declined or terminated where the conflict cannot be managed appropriately.

Clients, issuers and other third parties may provide feedback, corrections or additional evidence. Any resulting change must be based on objective assessment, evidence and methodology rather than commercial preference, as described under Data sources and processes.

Integrum ESG AB has adopted this policy, which applies to its ESG rating activities.

Where disclosed: Conflicts of Interest Policy; Policies & Compliance