Procedures of Engagement

ESG Scores and ESG Data Products, last updated on July 26, 2024

1 Introduction and Purpose

These Procedures of Engagement (the “Procedures”) set out general principles adopted by Bloomberg L.P. (“Bloomberg”) for engaging with a Company that wishes to review, discuss or raise any reasonable concerns with an ESG Score and / or any ESG Data Product that has been assigned to or attributed to it by Bloomberg. Bloomberg intends to treat all communications between Bloomberg and a Company subject to these Procedures. Additional principles may be followed, or reasonable deviations may occur, as may be required from time to time.

For the meanings of capitalised terms used in this document please refer to Section 2 (Definitions) below.

2 Definitions

  • “Company” refers to a company that has been assessed by Bloomberg.
  • “ESG” stands for “environmental”, “social” and “governance”.
  • “ESG Reported Data” refers to any raw ESG data that (i) is collected and aggregated from Companies’ public disclosures or from other publicly available information, and (ii) does not entail any estimations, calculations or analysis. ESG Reported Data does not include an ESG Data Product or ESG Score.
  • “ESG Data Product” refers to Bloomberg’s proprietary data products (including any applicable sub-components) that can be found here. For the avoidance of doubt, ESG Data Products exclude any ESG Reported Data.
  • “ESG Score” refers to Bloomberg’s proprietary scores (including any applicable sub-components, such as sub-scores) that can be found here.

3 Principles for Engagement

Bloomberg follows an engagement process when communicating with Companies. Our objective is to provide transparency to our ESG Score and ESG Data Product methodologies and the underlying ESG Reported Data collected from Companies we analyse. Bloomberg’s proprietary ESG Scores and ESG Data Products are calculated using defined quantitative and data-driven methodologies. We do not create ESG Scores on an “issuer-pay” basis.

Bloomberg follows these principles when engaging with Companies:

  1. We allow Companies to provide feedback on our ESG Scores and ESG Data Products to help promote accuracy and transparency.
  2. We review and improve the methodologies we apply to determine our ESG Scores and ESG Data Products.
  3. We take measures to ensure that Companies are assessed transparently by applying quantitative, rules-based and data-driven methodologies.
  4. We have established policies and procedures that seek to safeguard non-public information which may be used to determine some of our ESG Scores and ESG Data Products.
  5. We seek to follow high standards of conduct in our engagement and expect Companies not to provide any (i) price sensitive or inside information; or (ii) monetary or non-monetary benefits (including gifts and entertainment) to our product specialists or other employees.

4 Overview of Bloomberg’s ESG Data Collection, Engagement Process and Disclosures

4.1 Data collection

Bloomberg obtains input data for its ESG Scores and ESG Data Products from a variety of sources. For example, Bloomberg collects publicly disclosed ESG Reported Data, data acquired from third parties, press releases, news articles, various government databases, etc. ESG Reported Data collected by Bloomberg goes through data quality procedures, both at pre-publication and post-publication stages. The processes used to manage data may vary between asset classes and datasets. However, assessing data quality is a principle that is adopted broadly across the company. Bloomberg publishes the majority of ESG Reported Data and its sources on the BLOOMBERG TERMINAL service.

When no ESG Reported Data is available, for some products Bloomberg produces and uses estimates, generated by in-house data models and analysis.

Bloomberg acknowledges the importance of monitoring of company disclosures and reporting trends and has implemented reasonable measures to extend the ESG data sources that are acquired for data collection.

4.2 Engagement process

All Companies must observe high standards of market conduct and not seek to improperly influence the objectivity of the assessment process, including (without limitation) by providing Bloomberg with price sensitive or inside information or any monetary or non-monetary benefits. If we have concerns about improper conduct in the course of our engagement with a Company, we may suspend, amend or cease our engagement with immediate effect, and/or disregard information received from a Company’s feedback.

We seek to follow this process for all Companies – unless we consider there are exceptional circumstances or otherwise good reasons that justify deviation.

We would be happy to explain our methodologies, data sources used to create our ESG Score and ESG Data Products and clarify the interpretation of reasonable questions – however, you are solely responsible for the feedback and responses you provide and must ensure that all information you provide to us is public, free from confidentiality obligations and accurate.

4.3 Disclosures
We may include a description and explanation of  sources of input data used to determine ESG Scores and ESG Data Products in our methodologies and marketing materials. We may publish our methodologies on the BLOOMBERG TERMINAL, Bloomberg NEF or Bloomberg DATA <GO> websites which are accessible by clients of Bloomberg. Methodologies for certain products are published on the Bloomberg Data Upload Portal and accessible by an evaluated Company seeking information about an ESG Score assigned to it by Bloomberg. We may also make our methodologies available to Companies upon request.

5 Company feedback and contact

Companies can contact us to review an ESG Score or ESG Data Product attributed to them, and input data used to create such products in a variety of ways.

Bloomberg customers can:

  • contact their Bloomberg Relationship Manager via email or phone;
  • submit their inquiry to the Bloomberg Support Desk, which can be reached by pressing the “HELP” key twice on the BLOOMBERG TERMINAL; or
  • submit their inquiry via Bloomberg Customer Service Center.

Non-Bloomberg customers can:

  • send an email to esgcorporate@bloomberg.net;
  • access certain ESG Scores via the Bloomberg Data Upload Portal; or
  • contact us here.

We will be happy to arrange calls and/or meetings on reasonable request to discuss the information sources used by Bloomberg or any factual errors identified during your review.

Our product specialists will consider any information provided in respect of potential errors and assess if a change in our assessment or methodologies is required.

 

6 Disclaimer 

The information included in these materials and all related information (whether oral or written) which may be provided in connection with these materials is for illustrative purposes only and is not intended to be, or should be treated as, establishing a contractual relationship or otherwise constituting any legally binding terms or commitments. The BLOOMBERG TERMINAL service and Bloomberg data products (the “Services”) are owned and distributed by Bloomberg Finance L.P. (“BFLP”) except (i) in Argentina, Australia and certain jurisdictions in the Pacific islands, Bermuda, China, India, Japan, Korea and New Zealand, where Bloomberg L.P. (“BLP”, together with its affiliates, including BFLP, “Bloomberg”), and its subsidiaries distribute these products, and (ii) in Singapore and the jurisdictions serviced by Bloomberg’s Singapore office, where a subsidiary of BFLP distributes these products. BLP or one of its subsidiaries provides BFLP and its subsidiaries with global marketing and operational support and service.

Certain features, functions, products and services are available only to sophisticated investors and only where permitted. The Services are standard services offered by Bloomberg. Users are responsible for their use of the Services and for assessing whether the Services help meet any regulatory obligations that apply to them. Bloomberg does not guarantee the accuracy of prices or other information in the Services. Nothing in these materials or the Services shall constitute or be construed as an offering of financial instruments by Bloomberg, or as investment advice or recommendations by Bloomberg of an investment strategy or whether or not to “buy”, “sell” or “hold” an investment. Information available via the Services should not be considered as information sufficient upon which to base an investment decision. Nothing in these materials or the Services is designed to be, or should be treated as, advice. If you are in any doubt as to your obligations or should you wish to seek advice, you should consult your own professional advisers. Bloomberg makes no claims or representations, or provides any assurances, about the sustainability characteristics, profile or data points of any underlying issuers, products or services, and users should make their own determination on such issues. The following, among other marks, are trademarks and service marks of BFLP, a Delaware limited partnership, or its subsidiaries: BLOOMBERG, BLOOMBERG ANYWHERE, BLOOMBERG MARKETS, BLOOMBERG NEWS, BLOOMBERG PROFESSIONAL, BLOOMBERG TERMINAL and BLOOMBERG.COM. Absence of any trademark or service mark from this list does not waive Bloomberg’s intellectual property rights in that name, mark or logo. All rights reserved. ©Bloomberg Finance L.P..