EU Sustainable Finance Disclosure Regulation

The Sustainable Finance Disclosure Regulation (SFDR) is a European Union regulation that came into effect on 10 March 2021 and governs how financial market participants disclose sustainability-related information. SFDR aims to improve transparency and consistency of sustainability-related disclosures, enabling investors to make more informed comparisons between financial products. Sustainability disclosures include information on sustainability risks and, where applicable, environmental, social and governance (ESG) characteristics for financial products, so that investors can assess how sustainability risks are integrated into the investment process.

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 are also subject to these requirements. In addition to our disclosures in prospectuses, annual reports and on this website, we will provide our clients with the information they require to comply with their own SFDR obligations.

Background to SFDR and how it impacts Aviva Investors

SFDR is part of the EU’s wider Sustainable Finance framework, which is supported by a broad set of enhanced regulations which apply across the region. The framework includes the Sustainable Finance Action Plan, which aims to promote sustainable investment across the EU, and the EU Taxonomy Regulation, a classification system that defines which economic activities can be considered environmentally sustainable against detailed regulatory criteria.

Product reporting obligations under SFDR

SFDR sets out different disclosure requirements for financial products based on the criteria set out in specific Articles of the Regulation. The characteristics and objectives of a financial product establishes what levels of disclosures need to be made.

Article 9 products have sustainable investment as their objective and are subject to the most detailed sustainability disclosure requirements.

Article 8 products promote environmental or social characteristics, or a combination of these, provided that the companies in which investments are made follow good governance practices. While Article 8 products may make sustainable investments, they don’t necessarily have a sustainable investment goal so they are subject to a corresponding level of disclosure.

Article 6 products do not promote environmental or social characteristics and do not have sustainable investment as their objective. While they may still consider sustainability risks as part of the investment process, they are subject to a lower level of sustainability-related disclosure than Article 8 and Article 9 products and they may not be promoted as funds with sustainability characteristics.

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, 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 documentation available at our fund centre, linked below. Detailed pre-contractual information can be found within the fund prospectuses or in the website disclosure section of this webpage.

Prospectus - Luxembourg SICAV

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)).

View documents

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.

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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Aviva Investors Luxembourg Sustainability Risk Policy

PDF 409.4 KB 8 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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Please see this page for related policies and documents.

Responsible investment views

Fund centre

Access key fund documentation and performance reports.

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