Expert/Specialist Feedback on investRFP | Kristina Touzenis | BST-Impact

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By Kristina Touzenis, Managing Partner BST-Impact and Head of the investRFP Expert Group on Sustainability

| Expert/Specialist Feedback on investRFP

InvestRFP has decided to open the platform to experts who offer their services to users. A group of non-financial experts stands ready to provide advice on specific areas of competence, such as social sustainability, governance issues, specific environmental issues, international law, human rights due diligence and broader issues related to social aspects and “footprint” of investments and operations. The pool of expert is intended to grow over time and will be composed only of senior people with more than 15 years of work on their specific field to ensure value.


At regional and national levels, more and more regulations, reporting requirements on ESG and broadly sustainability and due diligence issues are being developed with growing speed.

Examples include the upcoming EU Sustainable Finance Disclosure Regulations, as well as Human Rights Due Diligence requirements being developed by e.g. the UNPRI. While the legal initiatives of the EU Action Plan relate directly to entities in the EU, they also have an (in)direct impact on entities outside of the EU, especially those wishing to manufacture or sell financial products to EU clients Respecting international and regional standards is by now a part of expected responsible business conduct and there is an increasing pressure – including in new and upcoming legislations – to demonstrate compliance.

Not being sustainable,
and not being able to show

that you are sustainable
is an increasing risk.

But very few investors are ready to address these issues because they, for obvious reasons are financial experts and not sustainability experts.

An unprecedented amount of money will, over the next 5 to 10 years, change hands to a generation that puts value at the heart of their decisions. Investors and asset managers will have no choice but to follow the wishes of these new asset owners and be able to show that their portfolio is not only “impact investing” but long term sustainable on a systematic basis.

Companies and investors need to be able to not only comply with these regulations but actively engage in a sustainability debate so they can participate in a dialogue on these issues, be at the forefront of regulatory developments and steer their impact in the right direction, while protecting their reputation and legal interests.

The offer of the Expert Group:

Whenever asset owners issue Requests on the investRFP platform asset managers registered on the platform are notified and able to review the Requests and submit a Response before deadline.

Asset owners use analysis tools on the investRFP platform to compare answers, aggregate data, evaluate results and also use scoring tools on an individual or team basis.

But on a number of issues more and more specialized scrutiny and expertise advice is needed to understand what lies behind the answers.

On ESG and Sustainability issues answers given and received by financial experts may – justly so! – not be fully covering sustainability questions – adverse or positive effects of investments, or the level of sustainability strategies and processes in place within a firm.

The Expert Group proposes to have the answers you receive thoroughly analyzed – including with potential follow up questions to the Asset Managers – from a purely sustainability perspective by a groups of senior level experts on sustainability issues such as human rights implementation, advocacy and policy making, social issues, inclusion, governance etc.

Examples could be that an Asset Manager (AM) shows that they have a broad understanding of Sustainability but have a long-standing focus on Environment in all sustainability discourses. In this case it would be beneficial to question more deeply how the AM really sees “sustainability” as understood by the SDGs, spanning society, environment and governance.

As sustainability professionals the Expert Group could then follow up with questions such as “could we possibly see your full sustainability policy” and then understand how strong this is, including specific references, e.g. does the AM consider at all the right to property and how it is closely linked to issues related to the environment; whether it is linked to deforestation, water pollution and the use of water resources, protection of agricultural sectors and diversity in crops, investments in ecological agricultural projects as well as investments in renewable energy, which can have either immense positive effects on the society or pose significant dangers if not handled in conscientiously. Concrete example: investment in a dam which ends up displacing 200.000 people, with no analysis of adverse effects or not recompensating or no relocation plan.

What the Expert Group now offers is that any investor, could be a pension fund, insurance company, family office, foundation, corporate or other type of investor who wants to be sure that there is real engagement on sustainability issues on the part of the responding AM and can get expert analysis from a sustainability perspective on answers given to their questions in the Search or Due Diligence Request on investRFP.

It is important to underline that this would not be a standard rating, but tailored analysis of each answer and specific follow up with the AM from a sustainability perspective. Any AM who feels the need to use eventual feedback to improve their sustainability strategies/processes/reporting could also avail themselves of the service.

Importantly the advice provided by the Expert Group does NOT constitute a rating, but additional insight into specific areas of sustainability related competence.

The Service:

Concretely services would consist of different possible layers. Each can be chosen separately or as a package:

  • If so desired the initial questionnaire of the Asset Owner can be revised by the relevant expert(s) before being issued as part of a Request on the investRFP platform.
  • The Asset Owner can mandate the Expert Group to support in the analysis of the information provided by Asset Managers from specific expert perspectives, human rights, social sustainability, environmental viability etc. This can include a gap analysis of the answers.
  • After above mentioned analysis the expert(s) can present to the Asset Owner the reports which STRICTLY FROM THE EXPERT(S)’S SUBJECT MATTER PERSPECTIVE provide not only the most relevant information but which shows most real engagement. IMPORTANTLY this does NOT constitute a rating nor a financial advice!
  • Follow up questions to AMs when appropriate and when so desired by the Asset Owner.
  • Final Evaluation of strength of policies, strategies, processes, indicators, reporting from a sustainability perspective.
  • Evaluation of next steps in case improvement is needed, and also of willingness to engage on these issues on the AMs part
  • Considering that the expert(s) carry out their analysis SOLELY FROM THEIR SUBJECT MATTER PERSPECTIVE AMs can also approach the Expert Group to ask how to do better on specific issues. Again, it is important to note that the experts do NOT PROVIDE FINANCIAL ADVISORY SERVICES nor do they make a final “ranking” to Asset Owners who at the end decide on a range of criteria and are solely responsible for selection and investment decisions.

| Please note: The Asset Owner is responsible for the decision to engage the Expert Group and it is the decision of the Asset Manager to Opt-In and make their Response available to the Expert Group (as registered user on the platform). The instruction how to use the new “Allocate to” function on the investRFP platform by the Asset Manager is given in the Request description (if applicable). The service is offered and provided by the Expert Group to Asset Owners and/or Asset Managers. as platform operator is not the recipient of the information provided in Requests, Responses and Messages (as described below in “ as Platform Operator”) and is not party in the communication, offers, negotiations, contracts and compensations between the platform users and the Expert Group.

It is important to keep in mind that the Expert Group service is being offered as a complimentary analysis on highly specialized issues which are generally speaking not within the competence of financial experts.

And this analysis is only complimentary to any financial analysis Asset Owners or Asset Managers carry out. And the weight given to the expert(s)’s advice will be entirely up to the Asset Owner and their engagement on e.g. sustainability issues.

For enquiries please contact Kristina Touzenis on or Silvia Scozia on in order to potentially set up the specific group that you as an Asset Owner need. Pricing will depend on the level of in-depth work required and the seniority of the person(s) needed.


| The Expert Group:

| Kristina Touzenis

Kristina Touzenis is a lawyer and recognised leader in the business of international human rights standards and principles. Kristina has more than 20 years of experience in advocacy, human rights reporting, monitoring and evaluating as well as in policy making and negotiating at national, regional, and global level. Before launching her consulting business, helping companies and investors effectively operationalise ESG criteria and the Business and Human Rights agenda into their strategy, Kristina created the International Law Unit at the International Organisation for Migration – IOM, the UN Agency for Migration. She served as Head of the Unit from 2011 to 2020. Prior to her appointment at the IOM HQ, Kristina worked from 2006 to 2011 in the IOM Regional Office for the Mediterranean Region and from 2002 to 2006 on implementing children’s rights in the Mediterranean Region for an NGO.

| Silvia Scozia

Silvia Scozia has over seven years of experience working in policy-making and legal research on national and international law issues, both in the private and public sectors. She has worked as a British Red Cross Research Fellow in Cambridge (UK), as a Legal Associate at the International Committee of the Red Cross (ICRC) Advisory Service on International Humanitarian Law, and as a Counsel to the former Minister of Foreign Affairs of Spain at the law firm Palacio & Asociados in Madrid. Silvia brings her broad experience reviewing the compliance of existing frameworks with internationally recognized standards, and creating feasible, substantiated, action-oriented policy strategies for diverse stakeholders. She has previously worked with the International Migration Law Unit of the International Organization for Migration (IOM), the Office of the Prosecutor at the UN International Criminal Tribunal for the Former Yugoslavia (ICTY), and the NGO Oxfam.

| Giulia Biselli

brings several years of experience working with different stakeholders from both the public and private sector, across a range of sectors, in diverse regions across the world. She started her career working on external relations for private companies in Italy and China and she has then served different Italian governmental and military entities as an analyst and as part of diplomatic delegations. she worked for an NGO on developing, executing and monitoring tools and assessment mechanisms to investigate potential social and human rights risks in companies’ supply chains, in a multitude of countries. She has an extensive experience in monitoring and evaluating human rights aspects of projects and processes, and a very practical approach to measure impacts and setting realistic indicators, goals and priorities grounded on a norms-based approach.

| Colin Curtis

As former Group Head of Sustainability for one of the world’s largest technology companies, Colin spent years helping business leaders understand the importance of balancing people, planet, and profit. Prior to this, his career spanned a diverse range of roles including marketing, HR, business development, and technology. He works specifically on realizing the SDGs through sustainable business – LinkedIn.

| Andrew Young

He’s worked in retail and manufacturing, across commercial, marketing and business strategy and transformation, but spent the majority of his time working in sustainability with a focus on sustainable sourcing and production.

| Paul Mather

Paul has been Operations and programme management and has experience in diversion and inclusion issues. He became passionate about increasing sustainability through innovation, developing strategies for electric vehicles and circular packaging.

| Liza Freudmann

Experienced senior marketing professional with extensive multi-channel experience. She has a real passion for fast-paced retail and customer-centric businesses, with experience in sustainability/CSR, food, fashion, home and health & beauty

| Allan Hendry

Alan has worked in sustainability and innovation since 1996, in both the public and private sector. In the last 12 years he has worked as Sustainability Director and Sustainability Lead for two global engineering companies.

| Claire Louse Chapman

Claire Louise is a Social Impact Practitioner who has worked at senior level within the Charity sector and as Corporate Responsibility consultant for energy company RWE NRL. She was CEO of Lancaster District Chamber of Commerce and has represented the VCSE sector at senior level, as a member of Sheffield First Local Strategic Partnership.

| Louise Eaglesfield

Has over a decade of leadership in ESG/CSR, developing, delivering and communicating the ESG aspirations of brands of all sizes across the real estate, hospitality, charity and professional services industries – in house and consultancy. Although Lucy has a broad background in ESG strategy and sustainability, she is also a specialist in award-winning community investment programmes, team engagement and sustainability communications.

| Amanda Wiseman

has worked in sustainability for over 10 years, 8 of those focussed on the Food and Drink sector. She previously worked at WRAP as a Business Account Manager on the Courtauld Commitment and the launch of the Plastics Pact, aligned to the UN Sustainable Development Goals. Projects Amanda has worked on have spanned all areas relating to achieving a circular economy from design and procurement to resource efficiency along the supply chain, communicating with consumers to help them reduce waste.

| Adam Higgins

is a Certified Sustainability Practitioner and specialises in Social Impact strategy and Carbon Management, specifically in the financial services and FMCG sector. Adam’s journey in sustainability derived from his passion for helping others. A role in the charity and community department, for a large finance company, snowballed into a position as CSR Business Partner.

| Oliver Bradley

specialises in non-financial data and reporting, most recently leading sustainability reporting at FTSE 100 packaging manufacturer, DS Smith. He has advised a range of companies on sustainability strategy and reporting, focussed on climate change and the circular economy. He has co-authored peer-reviewed sustainability accounting research and is a member of the Centre for Social and Environmental Accounting Research (CSEAR). Passionate about furthering corporate sustainability and accountability, he contributes to the Standards Advisory Group at SASB (Sustainability Accounting Standards Board) and Circulytics sounding board (Ellen MacArthur Foundation).

| Ian Cordier

Ian has a unique combination of corporate experience and environmental insight, having worked for many years for large international companies in the infrastructure, energy and defence sectors, specialising in real investment modelling and business improvement. He then moved to the UK Environment Agency, becoming head of cost and carbon forecasting for the national flood defence programme before joining ESI Monitor in 2020. As well as being a Chartered Water and Environment Manager with CIWEM, and member of the CIWEM Specialist Panel on Climate Change, Ian holds an MSc in Environmental Management, a certificate in business accounting from the Chartered Institute of Management Accountants (CIMA) and qualifications from the Association for Project Management (APM) and the Institute for Leadership and Management (ILM). Ian’s recent work has included a report for WWF-UK on Environmental and Human Rights Due Diligence, as well as reviewing ESG (Environmental, Social and Governance) approaches to sustainable investment for a Guernsey-based client.

| Ian White

Is specialising in board evaluation and also act as an executive coach, mediator/facilitator, and trainer. Clients range from FTSE 100 companies to mid-sized charities and every type of organisation in between. His principal aim is to help boards and senior management enhance their performance and thereby improve the organisations they lead. Ian has been the chief legal officer and company secretary for both listed and major private companies. He has spent most of my career as a lawyer, but also spent some time working as a strategy consultant. He has expertise in corporate governance and working with boards on effectiveness, enhancement and performance. While most of his work takes place in the corporate sector, he has also undertaken assignments in the not-for-profit and public sectors. As well as being a lawyer he has an MBA from Ashridge Business School, has a coaching qualification, and is a CEDR (Centre for Dispute Resolution) accredited mediator.

| Fred Betley

Fred is an energetic and passionate expert in global sustainable development. With a degree in Global Sustainable Development from the University of Warwick, he brings a passion for research and for the implementation of the UN Sustainable Development Goals into the private sector. He continues to work as the Sustainability Advisor at ESI Monitor; as well as having worked with the Guernsey Chamber of Commerce in their Sustainable Business Initiative Policy Group; with Guernsey Finance on the Guernsey 21st Century Fiduciary Duty; and with Levin Sources in developing a carbon offset product that simultaneously rectifies the land-use practices of the mining industry.

| investRFP as Platform Operator Data GmbH is operator of the website, a web-based interactive communications platform for the exchange of information between Request Issuers and Respondents, mainly used for Asset Manager, Strategy & Fund Search as well as Due Diligence Requests. Registered users of the platform may upload content and share it with other platform users (Requests, Responses and Messages). The data flow thus takes place directly from user to user. is at no time recipient of the information. To the contrary, is deliberately not involved in the information flow and consequently does not take part in any subsequent business transactions. therefore do not use the data for its own purposes and does not evaluate it.

Since investRFP is no data recipient, it merely provides the technical means for the exchange of information. However, in accordance with our General Terms and Conditions we are obliged to maintain the confidentiality of the content provided by our users from a technical perspective and to guarantee secure data processing. In order to provide adequate protection and prevent unauthorised access to user’s content, the platform also employs modern security systems and employees are obliged to maintain data secrecy.


Kristina Touzenis is the Managing Partner of BST Impact and Head of the investRFP Expert Group on Sustainability. A lawyer and a recognized leader in the effective and concrete operationalization of international human rights standards and principles in complex settings worldwide requiring long-term engagement with a multitude of stakeholders, form both the public and private sectors. She has more than 20 years of experience in advocacy, human rights reporting, monitoring, and evaluating as well as in policy making and negotiating at national, regional, and global level. Kristina founded BST Impact with two other partners in mid 2020, together with a pool of experts to help companies and investors to effectively operationalize ESG criteria, SDGs, international norms and the Business and Human Rights agenda into their respective sustainable business strategies, investment processes and risk assessment management systems. Previously, Kristina created the International Law Unit at the International Organization for Migration – IOM, the UN Agency for Migration and served as Head of the Unit from 2011 to 2020. She engaged with government counterparties on legislation development and review as well as with other Agencies within the UN common system, on advocacy and implementation of programmes worldwide. Prior to her appointment at the IOM HQ, Kristina worked from 2006 to 2011 in the IOM Regional Office for the Mediterranean Region, on translating international norms and standards into practice on the ground and from 2002 to 2006 on implementing children’s rights in the Mediterranean Region for an NGO.

All opinions expressed are those of the author. is an independent and neutral platform dedicated to generating debate around ESG investing topics.