Requirements for issuing ESG CKDs/CERPIs

This week I would like to discuss the requirements set forth by the Mexican Stock Exchange (BMV) for classifying Capital and Development Certificates (CKDs) and Investment Projects Certificates (CERPIs) as ESG. Given the growth ESG instruments have seen, the BMV has published the following minimum requirements necessary to enlist one of these instruments under the ESG Funds (A) or Impact Funds (I) categories:

1.       Adherence, membership, or subscription to collective reporting or compliance ESG organizations

Managers must be signatories or members, participating in the evaluation or grading of at least one recognized international reporting service or entity (UNPRI, EDCI, Sustainalytics) on an annual basis. Annual Sustainability Reports must also be published under the Global Reporting Initiative (GRI) and International Sustainability Standards Board (ISSB)’s criteria and disclosures.

2.       Include at least the following in the Offering Memo and/or Sustainability Report:

• Code of ethics
• Responsible investment or ESG policy
• Investment process manual with ESG aspects
• Risk management manual
• Conflict of interest management policy
• Compensation mechanisms for staff that consider ESG aspects
• Supplier hiring policy
• Information systems report (which information systems are used for management and data capture)
• Cybersecurity policy
• Business continuity plan
• Disaster recovery plan
• DEI policy
• Organizational favorable environment policy

3.       Requirements for projects or portfolio companies

The projects or portfolio companies in which investments are made must guarantee:

1. Transparency regarding voting on ESG aspects in their respective boards of directors and committees
2. Risk mitigation plan and capture of ESG opportunities identified during the investment analysis and monitoring processes
3. Promotion of transparency of ESG aspects in projects and investments
4. ESG commitments follow-ups
5. Carbon footprint measurement report

4.       Those funds that intend to be classified as Impact Funds (labeled in the “I” series)… in addition to complying with points 1) and 2) must have an independent third party certify that the resources’ destination will be directed towards green, social, or sustainable projects (depending on how they want to be classified).

In addition to all of this, certain maintenance and reporting requirements exist:

1.       Issuance of an audited Annual Sustainability Report to the Stock Exchange, including…

• Publication no later than May 31^st of each year (year after obtaining label)
• Disclosure based on GRI + ISSB
• An external auditor’s opinion
• Describing the adherence to its responsible investment policy criteria
• Carbon footprint measurement, at least scopes 1 and 2
• Annual evaluation result (ESG Funds)
• Independent third party’s review accrediting the use of resources (Impact funds)

These guidelines may seem overwhelming at first for CKDs and CERPIs that want to be labeled as sustainable. However, their main role is to help managers have a checklist of the minimum things they need to achieve. This, in turn, has the benefit of ensuring that ESG labels don’t go to managers that are not doing their homework. At Miranda ESG we would be happy to help any manager check this list off.

I hope you found this interesting. As usual, if there is anything we can help you with, or if there is an ESG topic you would like to know more about, please let us know.

Best,

Marimar

CEO, Miranda ESG