John Richards, under cross-examination in the Unilever case, said he could accurately estimate the level of risk in any given portfolio and that, therefore, he did not need to use quantitative measures of risk.

The Unilever Superannuation Fund is suing Merrill Lynch Investment Managers (MLIM), previously known as Mercury Asset Management, for £130m (€212m). Unilever alleges that MLIM negligently took too much risk when managing £1bn for it between January 1, 1997 and March 31, 1998, under a revised mandate that included a downside risk tolerance for the first time. MLIM contests the claim.