ICMA/IRSG Voluntary Code of Conduct

Our Statement of Application

Datamaran endorses the International Capital Market Association’s (ICMA) Voluntary Code of Conduct for Data Products Providers.

The ICMA and International Regulatory Strategy Group (IRSG) published the “Code of Conduct for ESG Ratings and Data Products Providers” in December 2023 in response to the International Organization of Securities Commissions (“IOSCO”) recommendation to “consider focusing more attention on the use of ESG ratings and data products and ESG ratings and data products providers that may be subject to their jurisdiction," including by improving practices across four key areas: transparency, governance, systems and controls, and management of conflicts of interest.

As a long-established ESG software company founded in 2014, Datamaran promotes the use of data-driven insights and information for smarter ESG governance. We are pleased to announce that we have voluntarily signed up to the ICMA/IRSG Code of Conduct for ESG Ratings and Data Product Providers to promote transparency and good governance. 

About Datamaran’s Smart ESG Platform

Datamaran AI platform empowers business leaders to navigate the complex ESG landscape confidently by transforming vast amounts of information into actionable insights. These insights are derived from publicly available information, which we analyze using AI and continuously monitor to support companies’ ever-growing need for better and smarter ESG governance.

We provide one product (“Datamaran”). The application of the principles below relates to Datamaran’s full Smart ESG platform.

The ICMA/IRSG Code of Conduct is built around the following principles: Good governance, Securing quality, Conflicts of interest, Transparency, Confidentiality, and Engagement.

Datamaran’s  Response to the Code

Principle 1 - Good Governance: ESG ratings and data products providers should ensure appropriate governance arrangements are in place to promote and uphold the Principles and overall objectives of the Code of Conduct.

Datamaran ensures appropriate governance and oversight throughout the organization, including clear roles and responsibilities that are defined and upheld in the determination, publication, and oversight of Datamaran’s platform. The Executive team is ultimately in charge of our business strategy, while the VP of Product is responsible for translating that strategy into a product strategy with sign-off from the executive team. This strategy is published in the form of a long-term product strategy document and operationalized through product roadmaps which they oversee.

The product’s determination or development also involves an internal group of ESG experts that helps to ensure the sound and appropriate application of ESG principles to the product’s objectives, usability, and application, ultimately enabling our mission to support “Smart ESG” governance. All those involved are responsible for and enabled to follow the Principles set out in this Statement of Application through their respective role.

Beyond those individuals, Datamaran recognizes the importance of having its employees and contractors well-versed in ESG. Datamaran’s internal ESG Academy aims to ensure that everyone across the organization receives the necessary training to understand and incorporate ESG principles in their day-to-day responsibilities, from external-facing teams to tech and product teams. This initiative, led by one of our in-house ESG experts, further strengthens our accountability and awareness of ESG principles and their application throughout the organization.

Principle 2 - Securing Quality: ESG ratings and data products providers should adopt and implement written policies and procedures designed to help ensure the issuance of high-quality ESG ratings and data products.

As the leader of the Smart ESG category, we balance the need for transparency of our methodology with the protection of our intellectual property. As such, broader information about our methodology is available through our Help Center, while more detailed information on our methodology can be obtained by our customers upon request or by other third parties under NDA.

As a “governance first” product, monitoring is a key requirement embedded throughout our methodology and platform. It contributes to our product quality by ensuring the continuous availability of up-to-date information.

Datamaran’s AI platform quality relies mainly on two elements: the data and the engine, which is “fed” with that data. Specific procedures are put in place to ensure the high quality of both. Regarding AI specifically, we have implemented an “AI Acceptable Use Policy,” which includes a critical review of AI-generated outputs. 

The methodology governing which data and how the data is used, as well as what the engine’s objectives and output should be and how it should generate those outputs, have been developed since Datamaran’s inception. As a “pure-play” ESG software, ESG considerations have been embedded in the product’s development from the beginning. As mentioned under Principle 1, a team of in-house ESG experts contributes to those quality controls through due diligence performed as part of their roles and responsibilities. In addition, our “Client Product Council” provides a forum for our customers to provide feedback on our approach, process, and methodology, contributing to our product's quality.

In addition, technological rigor, user-friendliness, and actionability are embedded in our product’s methodology, which ensures that the product helps our customers cut through the complexity and manage ESG in-house through technology. Our “Software Development Life Cycle Policy” covers the use of Agile methodology, change management and quality assurance which are best practices and all contribute to our product governance and quality during product development. 

It should be noted that we believe the value of Datamaran relies not only on the quality of the primary data we use and data insights we produce but also on the quality of the delivery and usability of that data and those insights through our Smart ESG platform. Therefore, equal importance is given to both elements, complementing a high-quality product that provides confidence and evidence to our customers.

More information about our practices and procedures is available upon request to our customers or other third parties under NDA. Datamaran commits to providing those details as needed, as we currently do through due diligence and procurement requests. 

Principle 3 - Conflicts of Interest: (1) ESG ratings and data products providers should adopt and implement written policies and procedures designed to help ensure their decisions are independent, free from political or economic interference, and appropriately address actual or potential conflicts of interest that may arise from, among other things, the ESG ratings and data products providers’ organizational structure, business or financial activities, or the financial interests of the ESG ratings and data products providers and their officers and employees. (2) ESG ratings and data products providers should identify, avoid or appropriately manage, mitigate and disclose actual or potential conflicts of interest that may compromise the independence and integrity of the ESG ratings and data products providers’ operations.

Datamaran outputs are calculated or generated by AI algorithms based on publicly available information. The development of algorithms and their underlying rules and methodology are the joint responsibility of our CTO and VP of Product, who ensure that the integrity of our data is maintained.

It must be noted that user data can only be edited by the user, and Datamaran employees and contractors can not edit it directly. Any production data changes go through a review and validation process. Further, as part of our “AI Acceptable Use Policy,” we cover prohibited uses, including the manipulation of information.

Customers can only affect outputs generated by Datamaran through the initial customization of parameters to define the scope of any analysis and the ability to complement calculated or generated outputs with their own data. This data is solely available to those customers and is protected by our “Data Protection Policy” and our “Information Security Policy.” 

Finally, all our employees and contractors must adhere to our Code of Conduct, which covers our key values, including our commitment to prevent any conflicts of interest.

Principle 4 - Transparency: ESG ratings and data products providers should make adequate levels of public disclosure and transparency a priority for their ESG ratings and data products, including their methodologies and processes to enable the users of the product to understand what the product is and how it is produced, including any potential conflicts of interest and while maintaining a balance with respect to proprietary or confidential information, data and methodologies.

Transparency is the cornerstone of Datamaran’s business. Datamaran has always been transparent about its methodology with clients and partners. As mentioned in Principle 2, Datamaran being the leader of the Smart ESG category, we need to balance the need for transparency of our methodology with the protection of our intellectual property. As such, some information about our methodology is available through our Help Center, while more detailed methodological information can be obtained by our customers upon request or by other third parties under NDA.

The intended purpose of Datamaran is to empower business leaders to confidently navigate the complex ESG landscape by transforming vast amounts of information into actionable insights. Different use cases fall into this objective, including: Implementing a good governance process, focusing on the G in ESG;  Identifying and prioritizing the issues that are material to their organization; Elevating their teams with insights to deepen their ESG knowledge and authentically own their strategy; and Monitoring their ESG risks and opportunities in real-time.

The product, its insights, and underlying data available through the platform all contribute to operationalizing and documenting the above use cases. 

Principle 5 - Confidentiality: ESG ratings and data products providers should adopt and implement written policies and procedures designed to address and protect all non-public information received from or communicated to them by any entity, or its agents, related to their ESG ratings and data products, in a manner appropriate in the circumstances.

Principle 5 does not apply to Datamaran, as Datamaran does not acquire any non-public information on companies for the purpose of generating ESG evaluations and data. As mentioned in other principles, publicly available information constitutes the core of data used to calculate and generate insights on Datamaran. Customers have the option to add custom data  (e.g., from a survey) to their analysis, which is only available and accessible to them. The use and storage of this data are governed and protected by our “Data Protection Policy”, “Data Retention and Deletion Policy,” and “Backup Policy.” When used, our survey functionality always includes a mandatory field for the customer’s own Privacy Policy. 

Principle 6 - Engagement: (1) ESG ratings and data products providers should regularly consider whether their information-gathering processes with entities covered by their products leads to efficient information procurement for both the providers and these entities. Where potential improvements to information-gathering processes are identified, ESG ratings and data product providers should consider what measures can be taken to implement them. (2) Where feasible and appropriate, ESG ratings and data products providers should respond to, and address issues flagged by entities covered by their ESG ratings and data products and by users while maintaining the independence and integrity of these products.

Datamaran only relies on publicly available information and does not collect additional or individual information from covered entities. The quality of our data and insights rely, in part, on the consistency of data taken into account to generate outputs. We therefore ensure that similar content by companies is used in our corporate report database, which includes: annual financial, integrated, and sustainability reports with a specific publication date and scoping period (e.g., financial year, calendar year). Customers are able to provide feedback on the classification of their information, but content-related feedback would not be taken into account in order to ensure consistency of our methodology across the pool of companies analyzed. Our team also regularly performs controls to ensure the quality of our corporate report database.

What We Will Do Next

We believe that these principles constitute the cornerstone of robust and reliable ESG software, especially given recent regulatory changes that have increased the scrutiny of our product’s methodology in the context of our customers’ sustainability statements’ external assurance. We are committed to continuously improving the transparency of our practices, systems, controls, methodology, and processes to give our customers the confidence they are looking for in using ESG software. As a SaaS company dedicated to Smart ESG governance, we already subscribe to all the overarching objectives outlined in the Code of Conduct. Still, we will strive to improve our practices wherever possible without jeopardizing our intellectual property. As we officially signed up to the Code on 27 June 2024, we are committing to implementing the code by 26 June 2025, at the latest, in accordance with the 12-month period allowed for ESG Data Product Providers. During this period, we will further monitor and develop our existing policy framework, processes, and governance to ensure continued compliance with the Code of Conduct. Upon implementation, we will update our statement on our website and notify ICMA.