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Silver helps clients develop ESG practices for each stage of the investment process

Evolving stakeholder demand for environmental, social and governance (ESG) competency presents a challenge and an opportunity for investment managers. Managers must demonstrate their ability to identify and address ESG risks and opportunities as part of a well-executed investment strategy. At the same time, continued concerns about greenwashing have led to a rapidly shifting regulatory environment, putting pressure on managers to be more rigorous in their execution of ESG practices in each stage of the investment process.

Developing and maintaining an ESG program is dynamic and complex. Navigating regulatory requirements and a steady increase in ESG-related information requests, investment managers may struggle to answer pointed questions and meet related demands. Falling short on expectations related to the maturity of a manager’s ESG practices can have costly regulatory and financial consequences.

Recognizing the surge in interest around ESG and responsible investing, Silver was among the first regulatory-focused organizations to develop ESG advisory services for investment firms. We offer a range of services that align client processes with regulator and investor expectations without creating unmanageable complexity. By combining industry expertise and innovation savvy, Silver’s customized guidance reflects each client’s size, strategy and culture in order to develop tailored ESG programs that withstand investor scrutiny and address the evolving regulatory landscape.

ESG Policies & Procedures

Advise firms on best practices when creating an ESG program

ESG Program Maintenance

Maintain investor confidence in the strength of ESG practices

SEC Focused ESG Audit

Review ESG practices against SEC guidance and rulemakings

ESG Reporting

Build and implement ESG reporting and monitoring tools

ESG Diligence

Identify potential ESG risks and opportunities prior to investment

ESG Marketing

Ensure all ESG-related marketing materials are compliant with current SEC guidelines

Bespoke ESG Project Solutions

Deploy ESG experience to meet clients’ unique needs

ESG Policies & Procedures

Advise firms on best practices when creating an ESG program

  • Understand a client’s investment strategy, disclosures, stakeholder pressures and current focus areas
  • Define ESG priorities and approach to ESG strategy
  • Create ESG policies and procedures in line with firm, investor, regulator and industry expectations
  • Advise on the development of ESG governance structure (e.g., ESG Committee)
  • Build an analysis-based ESG diligence framework that fits firm investment processes
  • Review and update existing ESG policies to keep pace with changes in firm, regulator and industry environment

ESG Program Maintenance

Maintain investor confidence in the strength of ESG practices

  • Provide periodic firm wide ESG training that can focus on a specific ESG project, the use of customized ESG tools (e.g., questionnaires) in due diligence and on-going portfolio management, regular updates on evolving regulatory requirements and pertinent industry trends
  • Conduct internal data analysis of responses gathered during due diligence to inform current and future ESG engagement areas
  • Partner with firm to engage directly with investments on specific ESG focus areas arising from on-going diligence and ESG review
  • Develop a client’s statement on corporate practices and align it with the firm’s ESG program

SEC Focused ESG Audit

Review ESG practices against SEC guidance and rulemakings

  • Review a firm’s ESG program (e.g., policy, procedures, etc.) and associated documentation against the SEC’s ESG-focused risk alerts, enforcement actions, proposed rules, exam priorities and other communications
  • Conduct interviews with relevant personnel who implement and oversee ESG practices
  • Based on review, identify areas of enhancement to ensure on-going compliance with regulatory expectations
  • Assist firm to build or augment existing practices based on identified enhancements

ESG Reporting

Build and implement ESG reporting and monitoring tools

  • Support firms that are applying or have been approved as a Signatory to the United Nations backed Principles for Responsible Investment (PRI)
    • For new or potential Signatories: conduct PRI gap analysis to determine a firm’s ability to complete PRI reporting requirements, including determining approximate performance utilizing PRI’s scoring resources
    • For current Signatories: provide comprehensive support throughout the reporting period, including maintaining rational for all responses, determining regulatory impact, and assessing consistency between prior and current reporting efforts
  • Advise on and assist with reporting obligations for ESG industry organizations (e.g., Task Force on Climate Related Financial Disclosure, ESG Data Convergence Initiative, Net Zero Asset Managers Initiative, UK Stewardship Code, etc.)
  • Evaluate and manage regulatory reporting obligations related to ESG (e.g., updates to Form ADV; draft PAI statements, TCFD reporting, etc.)
  • Assist with the completion of investor ESG reporting: including responding to due diligence questionnaires and one-off requests for information, building a firm’s response database, updating annual DDQ responses based on changes to the ESG program, and reviewing responses for consistency, applicability and alignment with regulatory guidance

ESG Diligence

Identify potential ESG risks and opportunities prior to investment

  • Partner with client’s deal team to undertake targeted ESG review of a prospective investment
  • Identify potential material ESG considerations with respect to the company’s industry and sector, as informed by, among others, SASB, GRI, TCFD, etc.
  • Evaluate data room files, third-party diligence reports and responses to requests for information and/or requests for interviews with management teams
  • Following review, develop a final report identifying ESG-related policy and process changes, as well as opportunities based on potentially material findings to be included in client’s investment committee memo, or other deal-related documentation

ESG Marketing

Ensure all ESG-related marketing materials are compliant with current regulatory guidelines that a firm is subject to

  • Prepare and review ESG-related marketing materials
  • Develop a firm’s annual report on ESG efforts and focus areas
  • Develop annual investor updates (e.g., annual general meetings content, investor letters, etc.)
  • Develop website content and disclosures related to client’s ESG program

Bespoke ESG Project Solutions

Deploy ESG experience to meet clients’ unique needs

  • Develop Diversity, Equity and Inclusion (DEI) statement for application at the firm, including identifying personnel to oversee DEI practices
  • Build climate strategy for application at the firm and investment level
  • Develop approach to managing specific ESG considerations (e.g., controversial weapons, faith-based considerations, etc.)
  • Evaluation of new or bespoke reporting frameworks to support a firm’s ESG approach (e.g., reporting to the United Nations Sustainable Development Goals)

SilverVision

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January 24, 2024

Silver to Discuss 2024 ESG Regulatory Trends in Upcoming Webinar

Silver’s Trysha Daskam-Smith, Managing Director & Head of ESG Strategy, will be participating in a webinar on 2/1 that will focus on 2024 Climate Regulations and the ESG environment. To register for the event, and to learn more about what will be discussed, please click here.
  • Trysha Daskam-Smith
    Trysha Daskam-Smith
    Managing Director & Head of ESG Strategy
Contact us to learn more about Silver and our ESG Services

646-838-2180
[email protected]

Trysha Daskam-Smith
Managing Director & Head of ESG Strategy

646-838-2180
[email protected]
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LinkedIn

A seasoned sustainability practitioner and expert in policy writing and implementation of regulatory controls, Trysha Daskam-Smith advises investment firms on Environmental, Social and Governance (ESG) and regulatory compliance. She specializes in interpreting the impact of global regulation on a firm’s ESG efforts and regulatory compliance program.

Trysha’s interest in ESG began during her graduate work building financial models that showed the social and financial returns of investment in international health initiatives. Bringing this experience to the financial services industry, Trysha develops and advises on investment firm ESG programs (including ESG policies and procedures), helps firms respond to investors’ ESG questions and designs their ESG reporting processes.

Prior to joining Silver, Trysha was a Vice President for U.S. Compliance Consulting at Duff & Phelps, where she served as a global point person addressing ESG issues and completing ESG projects for a wide base of clients across various industry sectors. Trysha also worked with CounselWorks clients on all aspects of their regulatory compliance programs. Trysha developed her in-house perspective at Universa Investments, as part of the team managing the firm’s business operations and was involved in both mock and actual SEC exams.

A frequent speaker and commentator on a wide range of ESG topics related to the investment management industry, Trysha is an officer of the Sustainability Investment Leadership Council and a member of the GWU Board of ESG Ambassadors. She received a Bachelor of Science in Biological Sciences from the University of Denver and a Master’s of Public Health from The George Washington University where she dually concentrated on International Economics and Global Health Policy.

Trysha holds the CFA Certificate in ESG Investing.