EU Sustainable Finance Disclosure Regulation

The EU Sustainable Finance Disclosure Regulation (SFDR) is a set of European Union rules that came into effect on March 10, 2021, with the goal of making the sustainability profile of funds more comparable and easier to understand for investors. They categorise products into specific types and include metrics for assessing the environmental, social and governance (ESG) impacts of the investment process for each fund.

As the name suggests, this regulation emphasises disclosure. The information on this page describes our approach to SFDR and includes our policies and procedures, disclosed in accordance with these rules.

Many of our clients will also be subject to these requirements. Apart from our disclosures in prospectuses, annual reports and on this website, we will provide our clients with the information they need to comply with SFDR.

Background to SFDR and how it impacts Aviva Investors

SFDR is part of the EU’s wider Sustainable Finance framework, which is backed by a broad set of enhanced regulations that are applied across the region. The framework includes the Sustainable Finance Action Plan, which aims to promote sustainable investment across the EU, and a Taxonomy to categorise economic activity through a sustainability lens aimed at creating a more level playing field across the region.

Product reporting obligations under SFDR

The most visible and impactful aspect of SFDR is the reporting format funds and mandates will need to follow based on Articles 8 and 9. In addition, those funds that do not integrate any kind of binding sustainability constraints into their investment process, or have a sustainable investment objective, are subject to Article 6. While these funds are still allowed to be sold in the EU, they may not be promoted as funds with sustainability characteristics.

Article 8 products promote environmental or social characteristics, or a combination of those characteristics, provided the companies in which investments are made follow good governance practices.

Article 9 covers products targeting sustainable investments and those that have sustainable investment as their objective.

Aviva Investors - Principal Adverse Sustainability Impacts Statement

Remuneration

To meet the requirements set out under Article 5 of the SFDR, we have published additional information on remuneration and ESG in our IFPR Disclosures.

Asset Class Sustainability Risk Policies

Private Markets Sustainability Risk Policy

PDF 183.6 KB 12 pages

This policy describes how we integrate sustainability considerations into each asset class investment process across Private Markets. Private Markets covers real estate debt and equity, infrastructure debt and equity, private corporate debt and structured finance, venture, growth and natural capital.

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Public Markets Sustainability Risk Policy

PDF 192.1 KB 11 pages

This policy describes how we integrate sustainability considerations into each asset class investment process across Public Markets. Public Markets includes Fixed Income, Equities and Multi-Asset funds. Examples include funds managed by Aviva Investors that primarily invest in equities and bonds, as well as money market funds.

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Please see this page for related policies and documents.

Aviva Investors Luxembourg Sustainability Risk Policy

PDF 355.1 KB 7 pages

Aviva Investors Luxembourg (AILX) recognises and embraces its duty to act as long-term stewards of clients’ assets, maintaining a deep conviction that environmental, social, and governance (ESG) factors can have a material impact on investment returns and client outcomes. This policy includes the key pillars of AILX’s ESG approach including consideration of sustainability risk and how they apply to the funds we operate.

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Luxembourg SICAV funds with environmental and/or social characteristics (Article 8 and 9)

Aviva Investors has a wide range of sub-funds that are subject to Article 8 as well as some Article 9 funds. To ensure that underlying investments in these funds align with our relevant commitment to promoting environmental and social characteristics, our investment process includes key sustainability considerations such as ESG screens and sector exclusions, and the integration of ESG insights.

We also undertake stewardship activities. Our firm-wide approach to stewardship is to engage with stakeholders at multiple levels in the financial system, including with policymakers and regulators, with the aim of maximising long-term value for investors – we call this ‘holistic stewardship’. These activities are aligned to Aviva Investors’ overarching approach to sustainability.

For further information regarding these funds, please see the prospectus and the SICAV Impact Assessment Matrix below. Detailed pre-contractual information can be found within the prospectus or in the website disclosure section of this webpage.

Website product disclosures

For financial products that promote environmental or social characteristics, financial market participants are required to publish specific product disclosures for funds subject to Articles 8 and 9 of SFDR (as set out in Article 10(1)).

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Responsible investment views

Fund centre

Access key fund documentation and performance reports.

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