Issuer Gateway Knowledge Hub


Internal Documents Protocol 

How Morningstar Sustainalytics Uses a Company's Non-Public Documents

March 2024

Document Submission Overview 

Companies are encouraged to submit non-public documents to Morningstar Sustainalytics as evidence of management policies, practices, and performance data that meet our assessment criteria. Morningstar Sustainalytics will not accept documents that are material or confidential. Each company is responsible for determining if a document is material or confidential/non-confidential. 


Defining Materiality and Confidentiality

In general, Morningstar Sustainalytics defines “non-material” as information that will not have an impact on a company’s enterprise value. Confidential information consists of proprietary information – including details relating to business activities and operations, technical information, and trade secrets – that is confidential to its owner at the time of disclosure. This information should be understood by a reasonable person to be of a proprietary or confidential nature. (See definitions of all document types below). 



Documents AllowedDocuments Not Allowed
Published on the website or as part of a filing available to the public at large. 

Proprietary information, including details relating to business activities and operations, technical information, and trade secrets, that is confidential to its owner at the time of disclosure and should be understood by a reasonable person to be of a proprietary or confidential nature.   
Public - Accessible Upon Request  
Not published on the website, but the company will share the information upon request and without restriction. 

Material Non-Public Information  
This information refers to any details that may have a positive or negative impact on the market price of the company’s securities and could be reasonably expected to be considered relevant by reasonable investors in their investment decision-making.  
Internal – Excluding any Material Confidential Details 
Information not published on the website and which the company may not share. Although this information is not material - i.e., may not affect the price of the securities/ financial instrument - it may, if widely disclosed, commercially affect the issuer.  
Morningstar Sustainalytics may, at our discretion, request (additional) confirmation in writing that any document(s) shared by an issuer as part of the research feedback process does not contain any confidential or material non-public information.    



Non-Disclosure Agreements

Morningstar Sustainalytics will not sign any confidentiality / Non-Disclosure Agreement (NDA) related to any Internal (non-material, non-public) documents that an issuer shares with us. 


Public vs Internal Information

The Morningstar Sustainalytics Research Team gathers publicly available information to assess companies. Common public sources of information include government regulatory agencies, corporate websites, annual reports, codes of conduct, press releases, and corporate sustainability reports. 

Notably, if a document is easily found from a company website, Morningstar Sustainalytics likely has it and companies do not need to share the document directly. Companies can provide a URL to any public information (e.g., sustainability report, website content, press releases).   

The information below outlines how Sustainalytics stores and uses any internal documents that a company submits.  


Document Storage

Any non-public documents submitted to Sustainalytics for the purpose of a research assessment are securely stored within our internal database and accessible only to ESG Research analysts. Learn more about Morningstar’s Security Practices here

Sustainalytics Protocol

Use of Non-Public Documents


The table below provides guidance on how Sustainalytics uses any non-public documents that a company shares with us.

Also refer to our general guidance on documentation and supporting evidence for the ESG Risk Rating assessment. Learn more here.  

Types of Non-Public Documents Companies Can Submit

Internal Use by


External Use by Sustainalytics

Internal (non-material, non-public) 

Although this information is not material, it may, if widely disclosed, commercially affect the issuer.


See examples here.









Sustainalytics allows our ESG Research team to share relevant ESG management performance information internally. 

Each research team will use the information shared, according to the applicable independent process and methodology. 

Sustainalytics is committed to ensuring adequate data protection across all group entities. 

For more information, see an overview of Morningstar's security practices here.





Sustainalytics will not share such information externally, i.e., within reports that we publish and distribute to investor clients.

Sustainalytics will not include any excerpts from these documents within public documents.

Sustainalytics may reference details within our research, following the standard citation rules.

Accessible upon request 

The company will share the information upon request and without restriction.


See examples here.


Sustainalytics will treat documents of this type shared by an issuer as publicly available. 


Brief excerpts may be included within public documents, provided appropriate citation is in place.

Sustainalytics may reference details within any research products, following the standard citation rules. 



Source Citation 

Morningstar Sustainalytics lists the document(s) used to produce an assessment. The citation can be found alongside the assessment of relevant metrics such as the following: 

MetricResearch Product                                        
  • Management Indicators
  • Events
  • Areas of Involvement
  • Management Indicators
  • ESG Risk Rating
  • Controversies Research 
  • Product Involvement
  • Low Carbon Transition Rating  


    Issuer Gateway: Uploading Documents 

    To upload documents to the Issuer Gateway portal, refer to the following guidance. 

    Technical Restrictions How to Upload Documents
  • Do NOT use any special characters in the document title including [`!@#$%^*_+=[]{};':"\|,<>/?~]
  • Log into your Issuer Gateway account.
  • In the Research tab, go to Documents (left sidebar).
  • Select the Uploads mini tab. Choose a file from your computer or drag it onto the page. 


    If you have any questions concerning document types or other research matters, please contact us via our Chat Box or email: [email protected]