“In reality, Purpose did not consider ESG in making investment decisions for many of the funds it managed. Purpose did not implement any formal policy and did not have documented procedures relating to the consideration of ESG by its portfolio management team for funds managed by Purpose; instead, consideration of ESG at Purpose… was ad hoc,” it alleged. That action followed a review by the OSC, which saw the firm tell the regulator that only about a third of its funds could be classified as ESG funds, based on their consideration of ESG factors. In addition to the allegations against the firm, the OSC also alleged that Seif breached the rules too. “We are struggling to understand how the OSC is seeing this as a topic for enforcement action against Purpose, and even more specifically against me,” Seif said in a statement.