In theory, a portfolio with no ESG controversies signals low risk. In practice, experienced analysts treat it as a warning sign. The absence of alerts often reflects not resilience, but limited coverage, fragmented data, or incomplete aggregation. What looks like reassurance may instead point to a gap in visibility.

This dynamic came up repeatedly during our recent webinar, Private Markets in 2026: Macro Trends, ESG Shifts, AI Innovation and What It Means for Deal-Flow. The discussion highlighted how gaps in coverage and aggregation can shape investor perception, particularly when portfolios appear “quiet,” not because risks are absent, but because relevant information is not being captured.

This dynamic matters more than ever as private market due diligence intensifies. With fewer deals, longer holding periods, and higher selectivity, investors are spending more time scrutinizing assets before acquisition and monitoring them for longer after entry. Yet the informational foundation behind many ESG assessments has not caught up with these expectations.

When "No Data" Becomes "No Risk"

Private assets operate under persistent disclosure constraints. Unlike public companies, most private firms do not produce standardized, recurring ESG disclosures, nor do they benefit from consistent analyst coverage. These gaps are structural and unlikely to disappear in the near term.

In this context, silence is ambiguous. A clean ESG screen may indicate the absence of material issues, but it may just as easily signal that no relevant information was captured. Language limitations, fragmented sources, and uneven coverage across geographies and asset types all contribute to this uncertainty.

This dynamic is particularly visible in secondary transactions. Deal teams often need to assess large portfolios under tight time pressure, with limited access to management and incomplete identifiers. In such cases, relying on the absence of signals can create false confidence rather than reduce risk.

How Weak Coverage and Duplicated Signals Create Blind Spots

Even when information exists, it is not always immediately actionable. Adverse media has become a valuable substitute where structured ESG data is limited, offering outside-in visibility into private assets. However, it is not without challenges. Without robust aggregation and cross-language consolidation, the same issue can appear repeatedly across multiple articles, jurisdictions, and languages, creating duplication rather than clarity. At the same time, gaps in coverage or weak filtering can allow other material risks to go undetected.

At the same time, some portfolios appear unusually quiet simply because the underlying assets fall outside the scope of traditional datasets. ESG and reputational expectations in private markets remain fragmented, with bespoke workflows driven by LP-specific requirements. This lack of convergence makes it difficult to distinguish between genuinely low exposure and analytical gaps.

More data does not automatically resolve this problem. Without traceability, source quality, and a way to assess financial, legal, or operational materiality, increased volume can add noise without improving decisions. In that environment, silence can be just as misleading as signal overload.

What Meaningful ESG Visibility Looks Like Under Disclosure Constraints

A core takeaway from the webinar was that point-in-time ESG assessments are no longer fit for purpose in private markets. A single diligence exercise conducted at entry cannot capture emerging governance failures, litigation, reputational issues, or supply chain risks over multi-year holding periods.

Instead, meaningful ESG visibility combines three elements:

• Broad coverage, to avoid portfolios appearing "low risk" simply because assets are not captured.
• Aggregation and severity assessment, to separate isolated news from controversies with real financial or operational implications.
• Continuous monitoring, so the original risk thesis evolves as new information emerges rather than remaining static.

This approach reframes ESG from a compliance exercise into a source of informational advantage. Rather than concluding that no alerts mean no risk, investors use ESG signals to guide follow-up questions, prioritize deeper diligence, and identify issues that were not visible at entry.

Replacing False Comfort with Informed Uncertainty

Private markets will continue to operate with imperfect information. Disclosure gaps, opaque supply chains, and bespoke reporting demands are inherent to the asset class.

Treating “no issues detected” as a conclusion creates false comfort. Treating it as a hypothesis, contingent on coverage quality and monitoring depth, aligns ESG analysis with how risk actually emerges in private assets.

SESAMm’s AI Technology Reveals ESG Insights

Discover unparalleled insights into ESG controversies, risks, and opportunities across industries. Learn more about how SESAMm can help you analyze millions of private and public companies using AI-powered text analysis tools.

Sustainability trends have become ubiquitous in the business world, mainly due to the attention ESG is receiving. To state the obvious, this is a positive trend as it helps push companies to consider their impact on the environment, employees, and customers and ensure their governance practices are sound. However, it also incentivizes actors in the business world to try to game the system through marketing campaigns to improve their reputation.

Through the use of artificial intelligence and other technologies, we embarked on a mission to analyze the sentiment on the web and uncover to what extent companies are incurring reputational laundering techniques to deceive investors, customers, and other stakeholders but also to identify the ones that are actually performing actions to have a positive impact around them.

This analysis dives into the concept of greenwashing and reputational laundering. It reveals the nuanced interplay between genuine sustainability efforts and deceptive practices, offering a new lens to distinguish genuine from false corporate sustainability claims.

Beyond Greenwashing: Reputational Laundering

Let’s start with some definitions. Reputational laundering is deliberately hiding unethical behavior with highly visible positive actions. Greenwashing is just one component of reputational laundering. Another component is the social aspect of it, and it includes various forms of color washing such as purplewashing, pinkwashing, purpose washing, etc. So far, in 2023, greenwashing accounted for 55% of all the volume of reputational laundering mentions on the web. So, the remaining 45% represents color-washing.

TerraChoice defines greenwashing as “the act of misleading consumers regarding the environmental practices of a company or the environmental performance and positive communication about environmental performance."

Colorwashing, on the other hand, refers to a strategy used by organizations to create a positive public image by associating themselves with specific causes, ethics, or moral standpoints.

Beyond the conventional understanding of deliberate greenwashing, there’s a more nuanced concept and less discussed: unintentional greenwashing, where companies inadvertently convey misleading environmental claims. This can occur due to a lack of understanding of the true impact of their products or services, unverified claims, overlooking hidden consequences, unintentional confusion in marketing materials, or insufficient transparency. While these companies may not have malicious intent, their actions can inadvertently misrepresent their environmental efforts and mislead consumers about their commitment to sustainability.

Reputational laundering at a glance

Over the past eight years, reputational laundering mentions have increased steadily. However, from 2021 onwards, they’ve grown a staggering 3.3x. The mentions of reputational laundering are coming from different topics, from false advertising, and misleading practices to lawsuits regarding greenwashing. Furthermore, we have observed a growing number of references regarding the declining trust of the public in corporate pledges, such as those related to 'net-zero' climate goals.

This increase can be attributed to two main reasons: the actual increase in reputational laundering and, more interestingly, the growing awareness from stakeholders (i.e., Investors and eco-conscious consumer base).

According to a report published by the UN Environment Programme (UNEP), climate change lawsuits have continuously surged over the past five years.
Consequently, we analyze mentions of lawsuits related to environmental breaches and detect a significant increase in 2021 – which continues to the present day.

Lawsuit mentions have increased by more than 3x since 2020. These litigations span a spectrum of environmental issues, extending well beyond planned obsolescence practices by major consumer goods manufacturers. We also observe the rise of youth-led climate change lawsuits, instances of oil spills, wildfires, pollution-related legal actions, and the pervasive issue of PFAS contamination.

Breakdown by type of washing

While greenwashing often dominates the conversation around reputational risks, it's crucial not to overlook the social dimension, which tends to receive less attention from the public. Since 2020, we've observed a significant uptick in mentions of greenwashing and its less-discussed counterpart, colorwashing.

Historically, up until 2020, the distribution of mentions leaned toward one-third greenwashing compared to two-thirds colorwashing. However, post-2021, this pattern has shifted. We've witnessed a rise in the frequency of greenwashing mentions, surpassing those of colorwashing and signaling an evolution in the focus of reputational laundering concerns.

During the COP27 conference at the end of 2022, a call was made to verify carbon and other environmental claims and show zero greenwashing tolerance. As a result, there has been a rise in scrutiny, and data now shows an increase in the number of allegations related to greenwashing. Here are a few examples:

June 2022: Head of Deutsche Bank’s DWS stepping after ‘greenwashing’ raids,
October 2023: Suncor accused of greenwashing
September 2023: Greenwashing cases against airlines in Europe, the US,

In analyzing advertisements, we found instances of reputational laundering through various means. Some companies engaged in social washing, while others used sportwashing to bolster their reputation. The mining and energy industries were particularly guilty of this practice. Meanwhile, the communication industry, including companies such as Netflix and Disney, was associated with black and whitewashing.

Inspecting the Regulatory Landscape

To analyze the regulatory environment of reputational laundering, we studied the effects of different legal frameworks and government organizations on greenwashing and other forms of reputational laundering. We measured the influence of legal frameworks and regulatory bodies on greenwashing by analyzing the quarterly growth of greenwashing mentions over the study period.

In this analysis, we define the concept of legal frameworks by capturing references related to the 'Green Claims' directive, Sustainable Finance Disclosure Regulation, EU Taxonomy, Green Product Certification, Fair Labeling and Advertising Act, Non-Financial Reporting Directive, FTC Act, FTC Green Guides, etc.

Concepts of Regulation bodies are defined by references to governments and Supranational entities (i.e.,  US government, FTC, SEC, Chinese government, Japanese government, etc.) or regulatory agencies established to safeguard the environment (United Nations Environment Programme (UNEP), Environmental Protection Agency (EPA), European Environment Agency (EAA), Intergovernmental Panel on Climate Change (IPCC), etc.)

Over the past three years, mentions of frameworks and laws have grown substantially, with increasing ESG scrutiny, new green claims guidelines, and a focus on sustainability and ESG reporting.

There has been a slight increase in the mentions of regulatory bodies over the years, mainly due to the growing interest in greenwashing, which has peaked during events like COP26 and COP27. Legal frameworks and regulatory bodies have played a significant role in the fight against greenwashing. Although there is no decrease in the mentions of this topic, the growth rate has reduced significantly. In fact, the quarter-on-quarter growth for greenwashing web mentions has been decreasing lately.

The trends reveal an interesting fact that there is a negative correlation between the growth in mentions of frameworks, laws, and regulatory bodies and the growth in mentions of greenwashing. Though the mentions of greenwashing are still increasing, the growth rate has significantly decreased from a 75% quarterly growth rate to 10% in the last year (except for spikes related to controversial events such as Greta Thunberg labeling COP26 as a “greenwash festival,” and not attending COP27).

Conclusion

As we navigate the landscape of corporate sustainability, it becomes evident that distinguishing genuine efforts from greenwashing is not just a matter of skepticism but a necessity. This exploration underscores the importance of vigilant analysis and the role of AI in unmasking deceptive practices. It calls for a collective commitment to transparency and accountability, empowering stakeholders to make informed decisions and advocating for a future where corporate responsibility aligns authentically with sustainable development.

At SESAMm, we used AI to study billions of articles and analyze greenwashing trends. Download this comprehensive ebook for an in-depth understanding of the evolving landscape of reputational laundering, notably greenwashing, and dive into its trends in the corporate world.

SESAMm’s AI Technology Reveals ESG Insights

Discover unparalleled insights into ESG controversies, risks, and opportunities across industries. Learn more about how SESAMm can help you analyze millions of private and public companies using AI-powered text analysis tools.

Discussions around nuclear weapons and defense have recently highlighted how differently investors interpret weapons exclusions. In particular, Russia’s invasion of Ukraine has brought security considerations back into focus across Europe and prompted some investors to revisit long-standing exclusion policies.

At the same time, regulatory frameworks such as the Sustainable Finance Disclosure Regulation (SFDR) encourage investors to screen portfolios for controversial activities and disclose how those risks are managed. However, these frameworks do not impose a single global definition of weapons exposure. As a result, policies can vary widely between institutions.

Controversial Weapons

What Do We Mean by Controversial Weapons?

In responsible investment policies, the term “controversial weapons” has a relatively clear meaning. It refers to weapons that are prohibited or heavily restricted under international conventions because of their indiscriminate or humanitarian impacts.
Typical examples include:

• cluster munitions
• anti-personnel landmines
• chemical weapons
• biological weapons
• nuclear warheads

Because these weapons are banned or widely condemned under international treaties, investors usually apply strict zero-tolerance exclusions. Any company involved in producing these weapons, or supplying critical components for them, is typically excluded from ESG-focused portfolios.

What Counts as Weapons Exposure?

The broader category of weapons exposure is more complex and is where investor interpretations often begin to diverge. Recent discussions across Europe’s sustainable finance community have focused on whether defense companies should remain excluded from ESG portfolios, particularly in light of renewed security concerns following Russia’s invasion of Ukraine.

Many exclusion frameworks distinguish between controversial weapons and other forms of military-related activity. Companies may be involved in conventional weapons manufacturing, such as firearms, missiles, bombs, or military electronics. Others produce defense systems and equipment, including radar, communications technology, or aircraft components. Civilian firearms are also frequently treated as a separate category within exclusion policies.

In these cases, investors often rely on revenue thresholds rather than absolute bans. A company may be excluded if more than five to ten percent of its revenue comes from weapons manufacturing, while smaller or indirect exposure may still be permitted depending on the investor’s mandate.

A key challenge in these screenings is that a company’s weapons exposure is not always obvious from its core business description. A firm may supply components, software, or materials used in weapons systems or operate as part of a broader defense supply chain. This is particularly difficult to identify in private markets, where companies are not required to disclose detailed segment revenues or defense-related contracts.

As a result, defining and detecting weapons exposure requires clear policy definitions and structured screening logic. What counts as weapons involvement, and where the exclusion threshold lies, ultimately depends on each investor’s mandate and risk tolerance.

What's Different Now?

These questions are no longer abstract. Since Russia's invasion of Ukraine, major asset managers have visibly shifted their positions. Allianz Global Investors, for instance, updated its Article 8 fund policies in 2025 to allow defense companies. Global Trading UBS and Franklin Templeton made similar moves, each removing revenue-based weapons thresholds that had been standard practice for years. At the regulatory level, Hortense Bioy, Head of Sustainable Investing Research at Morningstar Sustainalytics, noted that "since the start of the war in Ukraine in 2022, it has become increasingly clear that geopolitics plays a more significant role in shaping the boundaries of sustainable investing than ethics." What these shifts share is a common thread: the thresholds and definitions that once felt settled are now being redrawn, which is precisely why screening frameworks need to be flexible enough to reflect each investor's current policy, whatever that may be.

Customizable Screening

Because exclusion policies are defined at different levels, it’s rarely as simple as establishing a generic exclusion list. Limited partners often impose their own restrictions or revenue thresholds, which general partners must apply alongside the fund’s internal ESG policy and regulatory restraints. In some cases, LP requirements may further restrict or override the fund’s baseline approach.

As a result, acceptable levels of exposure to activities such as conventional weapons can vary significantly across portfolios.

Screening frameworks, therefore, need to adapt to the investor’s policy rather than forcing the policy to adapt to the tool.

In this case, SESAMm’s AI-generated exclusion screening report can be customized to match each investor’s requirements. Threshold-based classifications help identify different levels of involvement, allowing investors to distinguish between companies with no exposure, limited exposure, or significant involvement in controversial activities. Each classification is supported by underlying evidence and source documentation, allowing analysts to verify the reasoning behind the flag.

This approach makes it possible to apply a consistent methodology across both public and private companies while remaining aligned with the investor’s specific exclusion framework.

Discussions around defense and responsible investment will continue to evolve as geopolitical and regulatory contexts shift. Recent debates around nuclear deterrence and defense participation illustrate how differently investors can interpret weapons exclusions, even when they operate under the same regulatory frameworks.

For investors, the challenge is therefore not only defining exclusion policies but ensuring that those policies can be applied consistently and transparently across portfolios. As definitions of weapons exposure vary, and as supply chains and private market structures add further complexity, screening frameworks must be capable of translating policy into clear, operational rules.