Wellington Management engaged BlueMark to independently verify the alignment of our impact management (IM) system with industry best practices. BlueMark’s assessment findings cover both areas of strength and areas for improvement, as reflected in the Verifier Statement. Wellington Management did pay a fee for the verification.
BlueMark’s full assessment methodology, based on its professional judgment, consisted of:
1. Assessment of the IM system in relation to the impact investing industry best practices, using BlueMark’s proprietary rubric, and examining processes and policies against the following criteria:
> Compliance of the IM system with a threshold level of practice
> Quality of the IM system’s design in terms of its consistency and robustness
> Depth of subcomponents of the system, focused on completeness
2. Interviews with Wellington staff responsible for defining and implementing the IM system.
3. Testing of selected Wellington transactions to check the application of the IM system.
4. Delivery of detailed assessment findings to Wellington, outlining areas of strong alignment and recommended improvement, as well as BlueMark’s proprietary benchmark ratings on the extent of alignment with impact investing industry best practices.
The verification was made on 7 March 2025. Wellington provided BlueMark with the relevant supporting documentation for the policies, processes, and tools related to the IM system. The scope of BlueMark’s work was limited to processes in place between February and March 2025.
BlueMark’s verification does not constitute either an endorsement of the client’s practices or a verification of the resulting impacts achieved.
The verification may not be representative of any one client’s experience. The verification is not indicative of Wellington Management’s future performance. Past performance is no guarantee of future results.