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025

Case 025Scheme design and product strategyHard

An AMC wants an ESG equity fund. Its exclusion list removes 18% of benchmark weight and raises expected tracking error to 3.1%. Design the investment thesis for a long-only manager, and show how you would stop the fund becoming a label on an ordinary portfolio.

Neuberger BermanNew York · 2025

1The situation

Haritika Asset Management, an invented AMC, wants to launch an ESG equity fund benchmarked to a broad large and mid cap index. Its proposed exclusion list, covering tobacco, thermal coal, weapons and companies with serious governance findings, removes 18% of the benchmark's weight. The quant team estimates that the fund, once built, will carry a tracking errorHow much a fund's return is expected to differ from its benchmark in a typical year, measured as the standard deviation of the difference. of about 3.1% a year. The fund will charge about 1.0%, against about 0.2% for the AMC's index fund.

The head of products has seen rival ESG funds that hold almost the same stocks as the index and asks you to write the investment thesis for the fund's long-only manager, and to show how the fund will be kept honest.

2Your task

What is the thesis, what does the 3.1% tracking error buy, and what would stop this fund becoming the index with a green label?

Quick check

If the fund only removed the 18% of excluded stocks and spread the money across the rest in proportion, how different would it be from the index?

Worked solution

Try it on paper, then open one step at a time.

30-second answerThe answer to give first

The thesis is that companies managing the issues material to their industry carry less tail risk, and the fund expresses it by exclusion, then scoring and tilting, then engagement, with the holdings different enough to prove it. Exclusions alone give an active share of about 18%, an index fund with holes. The 3.1% tracking error is the cost of a real tilt and buys, at an assumed information ratio of 0.3, about 0.9% a year of expected difference, with a bad year near minus 6%. Honesty comes from measurable targets and a published record.

Step 1What is the thesis, in a form a long-only manager can act on?

A restaurant that calls itself organic because it dropped two dishes from the menu has not changed what it cooks. An ESG thesis for a long-only manager has to say what the fund believes about returns and risk, not about virtue, and the honest version is that companies which handle the environmental, social and governance issues material to their own industry carry less tail risk: fewer fines, strikes, stranded plants and accounting surprises. That is a risk thesis, not a return promise, and the manager should say so. It then has three consequences for the portfolio: avoid what the mandate forbids, tilt towards companies that manage their material issues well, and use the fund's votes and meetings to push the ones it still owns. Each stage has to show up in the holdings, or it is a brochure.

An ESG fund built in three stages: the holdings have to change for the label to mean anything1. ExcludeRemove the exclusion list:18% of benchmark weightActive share only 18%Tracking error about 1.2%An index fund with holes2. Score and tiltScore each company on theissues material to its industryOverweight leaders, underweightlaggards: active share 55%Tracking error 3.1%, the cost3. EngageVote every resolutionMeet the laggards you still ownPublish the voting recordand what changedEvidence, not adjectivesThe cost: a tracking error of 3.1% means a bad year can trail the index by about 6 points, and the fund must say so up frontTest before launch: would a reader of the holdings, with the name hidden, know this was an ESG fund?Exclusions alone fail that test at 18% active share; the tilt and the engagement record are what pass it
The fund is built in three stages: exclusions remove 18% of the benchmark but leave an active share of only 18%, scoring and tilting raise it to about 55% at a tracking error of 3.1%, and engagement provides the evidence, with the cost of a bad year stated up front.
Step 2Why are exclusions alone not a fund?

Measure the difference. Active shareHalf the sum of the absolute differences between a fund's weights and its benchmark's. An index fund scores zero; a fund with no overlap scores 100 per cent. after removing 18% of the index and scaling up the rest is only about 18%, with a tracking error near 1.2%. At that distance from the index the fund cannot justify a 1.0% fee against 0.2% for the index fund: at an assumed information ratio of 0.3 its expected excess return is about 0.4% a year, less than the 0.8% extra it charges. This is the arithmetic behind the head of products' complaint about rivals: an exclusion-only fund is an index fund that costs more and owns less.

The relationship
Active share=12∑i∣wifund−wiindex∣=12(0.18+(1−0.18)(11−0.18−1))=0.18\text{Active share} = \tfrac{1}{2}\sum_i |w_i^{fund} - w_i^{index}| = \tfrac{1}{2}\left(0.18 + (1 - 0.18)\left(\tfrac{1}{1-0.18} - 1\right)\right) = 0.18
wweight of each stock in the fund and in the index
0.18share of index weight removed by the exclusion list
1/(1 - 0.18)the scale-up applied to every remaining stock
What it says in wordsRemoving a slice of the index and spreading it across the rest moves the fund away from the index by exactly the slice removed, counted once.
Step 3What does the 3.1% tracking error buy, and what does it cost?

Tracking error is the fund's budget for being different. Spending it on a scored tilt, overweighting the companies that manage their material issues well and underweighting the laggards, takes active share to around 55%, a level at which the holdings would tell a reader what the fund is without the name. At an assumed information ratio of 0.3, 3.1% of tracking error buys an expected excess return of about 0.9% a year, which covers the fee gap with an information ratio of only 0.26; the cost is that a two-standard-deviation bad year trails the index by about 6 points. The 0.3 is an assumption for the illustration, not a forecast, and ESG tilts have had multi-year stretches on both sides of the index. The thesis document should carry that sentence, because the first bad year is when the fund gets tested.

Exclusions only against a designed fund: how different, at what cost, for whatExclusions onlyActive share18%Tracking error1.2%Expected excess at IR 0.30.4%Extra fee over index0.8%Expected excess 0.4% does not cover the 0.8% fee gapExclude, score, tilt, engageActive share55%Tracking error3.1%Expected excess at IR 0.30.9%Extra fee over index0.8%Needs an IR of only 0.26 to cover the fee gap; a bad year is about -6%Information ratio 0.3 is an assumption for the illustration, not a forecast; a bad year is two tracking errors
An exclusion-only fund has about 18% active share and an expected excess return near 0.4% that does not cover its 0.8% extra fee, while the designed fund at 55% active share and 3.1% tracking error expects about 0.9% with a bad year near minus 6%.
Step 4How do you stop it becoming a label?

With numbers the trustees can check every quarter. Active share above a floor, say 50%, so that the fund cannot drift back to the index. A portfolio carbon intensity at least 40% below the benchmark's, or whichever material metric the thesis names, measured the same way every time. A published voting record and an engagement log that names the companies, the issue and what changed, because engagement without a record is a claim. Scores built from company disclosures the auditor has checked, not from a vendor's black box, and a stated rule for what happens when a holding's score falls: a deadline to engage, then sell. The regulator has set categories for ESG schemes, minimum shares of assets that must follow the strategy, and disclosure and assurance requirements; the design should name its category and confirm the current rules before launch.

TestFloor or targetWhy it keeps the fund honest
Active share against the benchmarkabove 50%Stops the fund drifting back to the index after launch
Material metric, such as carbon intensityat least 40% below benchmarkMakes the tilt visible in a number, not a narrative
Voting and engagement recordpublished yearly, by companyTurns engagement from a claim into evidence
Score-fall ruleengage within 6 months, then sellPrevents keeping a laggard because it is in the index
Tracking errorabout 3.1%, with a bad year of about -6% disclosedTells investors the cost of being different before they pay it
Five checks, each a number or a document, keep the fund different in holdings: an active share floor, a measured gap on a material metric, a published engagement record, a rule for falling scores, and a disclosed tracking error of about 3.1% with its bad-year cost.
Step 5What do you tell the board the fund will not do?

It will not promise a higher return than the index; the thesis is about risk and about owning what the mandate says it owns. It will not match the index in a year when the excluded sectors rally, and the board should expect to field that question. And it will not call itself ESG on exclusions alone, because the arithmetic shows that an exclusion-only fund is the index with holes, and investors paying an active fee for it would be right to complain. Said plainly at launch, those three limits are what make the fund credible when the first hard year arrives.

Where candidates lose it

The common loss is writing the thesis as a list of values: clean, responsible, sustainable. A long-only manager cannot trade adjectives; the interviewer wants a claim about risk and return, a method for expressing it in weights, and a way to measure whether it happened.

The second is treating the exclusion list as the fund. Removing 18% of the index gives an active share of about 18%, and a fund that close to the index with an active fee is the label-on-a-portfolio problem the question asks you to prevent.

What the interviewer asks next

  • The excluded sectors rise 30% in the fund's first year. What do you tell investors, and does anything in the design change?
  • How would you build the company scores without relying on a single ratings vendor?
  • The AMC wants an ESG debt fund too. Which parts of this design carry over, and which do not?
  • A top holding is hit by a governance scandal. Walk through what the score-fall rule does, and what the manager should say publicly.

Asked at Neuberger Berman, Investment Research, New York, 2025 (Wall Street Oasis): how I would advice a long only manager on establishing an esg investment thesis

← Case 024The manager who ran a Rs 12,000 crore large and mid cap fund for 11 years, adding 3.5% a year over the benchmark, resigns; the successor has a four-year record at a smaller fund with 1.2% a year. A client holds Rs 45 lakh in the fund with Rs 18 lakh of unrealised gains. Hold, watch or exit?Case 026 →A balanced advantage fund returned 11.4% a year against 12.9% for its benchmark, but with 8% volatility against 11%. Which is the better risk-adjusted result, and what would you tell a client who only sees the lower return?

Company names and figures are illustrative.

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