From May 2025, new requirements have applied to the use of terms such as „sustainable“ or „ESG“ in the names of fund products. The European Securities and Markets Authority guidelines set binding requirements for the first time. At least 80% of the assets in a labelled fund must demonstrably comply with sustainability criteria. The industry is reacting with a series of adjustments – and also often with uncertainty.

Comgest, an independent asset manager with an AuM figure of 27 billion euros, takes a nuanced view of the developments. „We expressly welcome the new ESMA guidelines,“ says Catriona Marshall, Head of Sustainable Investment. „In our view, they are a big step towards clarity for investors.“

Comgest's investment style is long–term, quality, and growth oriented – including in the ESG context. „When we analyse a share, ESG is not an afterthought,“ explains Marshall. Rather, ESG factors flow directly into the assessment of a company. „Our ESG analysis influences valuations, risk assessments and, above all, the quality rating. No portfolio manager is allowed to invest without this internal categorisation", she says.

ESG integration is not rigid, it is continuously adapted to regulatory developments. This can be seen, for example, in the current discussion on defence stocks. The group–wide exclusion policy with regard to conventional weapons has been revised – also in response to changes in EU standards. But Marshall makes it clear: „Short–term tailwinds from political developments are not enough. What counts for us is long–term quality, sustainable growth, and stable revenue models. These are criteria that many defence companies do not fulfil.“ Far–reaching exclusions remain in place for the company's so–called ESG Plus funds anyway.

In practice, this means that even if certain stocks could formally be invested in, they are only bought if they fulfil the internal requirements. This applies in particular to sensitive sectors, but also when dealing with the large number of external ratings. „ESG ratings are often not transparent, and are inconsistent and difficult to compare,“ says Marshall. Comgest uses the ratings, but primarily relies on its own analyses, direct contact with the companies, and an independent review of critical information.

This evaluation logic also applies to actively influencing the companies. For Marshall, one thing is clear: „For us, successful engagement means not only achieving our goals, but also being able to communicate openly and confidently with the company.“ It's not just about making demands, but about building a resilient relationship.

Regulatory requirements are increasing – not only for asset managers, but also for the companies themselves. With the Corporate Sustainability Reporting Directive (CSRD), large and medium-sized companies are faced with an ESG reporting obligation. Comgest also sees this as an opportunity. „We have deliberately not made any exaggerated sustainability promises, but have documented what we are actually doing", she says.

Even in an environment with growing political headwinds and heated debates, Marshall believes that ESG remains in the focus of many institutional investors. For example, demand for clean energy strategies or environmentally sustainable business models is proving to be robust.