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Lesson 12 of 12 · Free

A Written Sustainable Investment Policy: Exclusions, Label Requirements and a Look-Through Checklist

Write a one-page sustainable investment policy with numeric exclusion thresholds, minimum label requirements, a look-through checklist and a yearly review, and test it on a sample portfolio.

Author: Moustafa HijaziContent reviewed: 2026-10-306 min readSelf-study course

What you will learn

  • The six sections of a short sustainable investment policy and why each needs a number, not an adjective.
  • How to set exclusion thresholds and a portfolio-level tolerance that you can actually measure.
  • How to write label requirements that survive the EU rule changes under way as of 2026.
  • How to run a ten-point look-through checklist on a fund and record the result.

Explanation

A general investment policy is covered in the course "ETFs, Funds & Long-Term Investing". A sustainable investment policy adds one page answering a single question: what will I refuse to own, what must a product prove, and how will I check? Without written numbers, every fund with a pleasant name passes.

Section 1 – Purpose and honesty statement. One or two sentences on why you screen (values, risk management or both) and what you do not expect, for example: "I do not expect screening to raise my returns or to change company behaviour by itself" (lessons 10 and 11).

Section 2 – Exclusions with thresholds. Use revenue-based thresholds like those in index rules (lesson 3), because they are measurable. A typical set: controversial weapons 0 %; tobacco production 0 %, distribution above 5 % of revenue; thermal coal mining or coal power above 5 %; oil sands above 5 %; confirmed severe violations of the UN Global Compact principles. Choose your own numbers, but write them. Add a portfolio tolerance: the maximum share of your total portfolio that may sit in excluded activities through funds, for example 2 %. Broad funds almost always contain small residual exposures; a zero tolerance would force you into very concentrated products.

Section 3 – Label requirements. As of 2026, EU labels are in transition: SFDR Articles 8 and 9 (lesson 5) still apply, the ESMA fund-naming guidelines have applied to all funds since May 2025, and in November 2025 the European Commission proposed replacing Articles 8 and 9 with new product categories, a proposal still in the legislative process when this lesson was written. Write requirements that survive any outcome, for example: "equity funds must publish full holdings monthly, apply at least the Paris-aligned benchmark exclusions, and publish a voting record; green bond funds must hold at least 90 % ICMA-aligned or EuGB bonds (lesson 9)". Add: "check the current EU rules at each yearly review".

Section 4 – Look-through checklist. Ten yes/no items for every candidate fund (table). Set a pass mark, for example at least 8 of 10 with no failure on items 1–3.

# Check Source
1 Full holdings available (daily or monthly)? Provider website
2 Exposure to my excluded activities within the fund-level limit (e.g. 3 %)? Holdings file × activity data
3 Index or strategy rules published, with named thresholds? Index methodology
4 Overlap with parent index below my chosen limit (e.g. 90 % of weight)? Holdings comparison
5 WACI reported with benchmark and date (lesson 7)? Factsheet, SFDR annex
6 Voting record and engagement objectives published (lesson 10)? Stewardship report
7 Impact claims limited to alignment unless additionality is shown (lesson 8)? Marketing material
8 TER within 0.15 percentage points of the cheapest conventional fund on the parent index? Key information document
9 Tracking error of the index disclosed and acceptable to me (lesson 11)? Index factsheet
10 No regulatory action against the manager for sustainability claims in the past five years? Regulator and press search

Section 5 – Allocation and products. Target weights and the product types that fill them. Cap genuine impact or illiquid products (lesson 8), for example at 5 %, and only with money you can lose entirely.

Section 6 – Review. Once a year: re-run the checklist, recalculate the tolerance, record changes to EU rules. Change the policy only in writing at the review, not after a news story.

Worked example

Hypothetical example: portfolio of EUR 50,000; policy tolerance for excluded activities: 2 % of the portfolio. Allocation: 60 % global ESG equity ETF (Fund A), 20 % green bond ETF (Fund B), 20 % conventional euro government bond ETF (Fund C, no corporate exposure).

Step 1 – fund-level exposures. Look-through shows Fund A has 3.0 % of weight in excluded activities (mainly a utility with coal power above the threshold); Fund B has 1.0 % (a bond from an issuer with oil-sands revenue above 5 %); Fund C has 0 %.

Step 2 – euro amounts. Fund A: EUR 50,000 × 0.60 × 0.030 = EUR 900. Fund B: EUR 50,000 × 0.20 × 0.010 = EUR 100. Fund C: EUR 0. Total = EUR 1,000.

Step 3 – compare with tolerance. 2 % × EUR 50,000 = EUR 1,000: exactly at the limit. "At most 2 %" passes, but with zero headroom; new savings into Fund A would breach it. Record a watch item.

Step 4 – checklist for Fund A. Fund A scores yes on items 1–8 and 10 and no on item 9 (tracking error not disclosed): 9 of 10 with items 1–3 passed. Pass.

Step 5 – action. Options at the next review: (a) replace Fund A with a stricter index, accepting higher tracking error; (b) lower the allocation to Fund A; (c) raise the tolerance in writing, with the reason. Each is legitimate; ignoring the breach is not.

Assumptions: exposures invented; fees, spreads and taxes ignored; real activity data has gaps and lags.

Common mistake

Writing adjectives instead of numbers"Avoid harmful companies" and "no greenwashing" cannot be checked, so they will not be checked. Every rule should let a stranger with the holdings file reach the same yes or no as you. If you cannot measure a rule, find a measurable proxy (a revenue threshold, a published document, a percentage) or drop it.

Practice activity

On paper: write your own one-page policy using the six sections. Then test it: a EUR 30,000 portfolio holds 70 % in Fund X (excluded-activity exposure 2.5 %) and 30 % in Fund Y (exposure 4.0 %); tolerance 2.5 % of the portfolio. (a) Euro exposure of each fund and in total? (b) Does the portfolio pass? (c) Maximum weight of Fund Y that still passes, with Fund X taking the rest?

Show solution

(a) Fund X: EUR 30,000 × 0.70 × 0.025 = EUR 525. Fund Y: EUR 30,000 × 0.30 × 0.040 = EUR 360. Total = EUR 885.

(b) Tolerance: 2.5 % × EUR 30,000 = EUR 750. EUR 885 exceeds EUR 750, so the portfolio fails by EUR 135.

(c) With y the weight of Fund Y: (1 − y) × 2.5 % + y × 4.0 % ≤ 2.5 % gives 2.5 % + 1.5 % × y ≤ 2.5 %, so y ≤ 0. Fund X alone uses the whole tolerance, so no positive weight in Fund Y passes: replace Fund Y, choose a cleaner Fund X, or change the tolerance in writing.

Limitations: exposures are snapshots that change with index rebalancing; re-check at every review.

Key takeaways

  • A sustainable policy needs numbers: revenue thresholds, a portfolio tolerance, a checklist pass mark and a review date.
  • Write label requirements around disclosures you can verify, because EU label rules are changing as of 2026.
  • The ten-point look-through checklist turns lessons 7–11 into a repeatable test.
  • Breaches are decided in writing at the review, with one of three actions: replace, reduce or re-justify.

Next step

You have completed this course; continue with "Alternative Investments: Private Markets, Hedge Funds and Collectibles", where private-market funds, including many genuine impact vehicles, are examined in detail.

Self-check

Answer the questions, then check your answers. You can retry as often as you like.

1. A policy says: 'Avoid companies that harm the climate.' Why is this rule weak under the method of this lesson?

2. A EUR 40,000 portfolio holds 50 % in a fund with 2 % excluded-activity exposure and 50 % in a fund with 3 % exposure. The policy tolerance is 2 % of the portfolio. What is the result?

3. Why does the lesson recommend writing label requirements around disclosures (holdings, exclusions, voting records) rather than around 'Article 9' alone?

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