EU Sustainable Finance Disclosure Regulation
The EU Sustainable Finance Disclosure Regulation (SFDR) is a new 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 easy 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 will place much more emphasis on disclosure. The information on this page describes our approach to SFDR and includes our policies and procedures, disclosed in accordance with these new rules.
Many of our clients will also be subject to these new 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 new and enhanced regulations that will apply across the region. The framework includes the Sustainable Finance Action Plan, which aims to promote sustainable investment across the EU, and a new Taxonomy to categorise economic activity through a sustainability lens and help create a 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 make based on three categories, as laid out by Articles 8 and 9 of the SFDR and those funds not defined by either article, referred to as ‘neutral’ funds.
Neutral funds do not integrate any kind of binding sustainability controls into their investment process and can include stocks that may be excluded by ESG-focused funds, such as tobacco companies or thermal coal producers. While neutral funds are still allowed to be sold in the EU, they may not be promoted as ESG funds.
Among other 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, also referred to as ‘products targeting sustainable investments’, covers products targeting bespoke sustainable investments and those that have sustainable investment as their objective.
Aviva Investors - Principle 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 Pillar 3 disclosure.
Asset Class Responsible Investment Policies

Credit & Equities - Responsible Investment & Sustainability Risk Policy
This policy describes how we integrate our responsible investment philosophy into each asset class investment process. Credit and Equities covers funds managed by Aviva Investors that primarily invest in equities and bonds and includes money market funds.

Multi-Asset & Macro & Liability-Driven Investment - Responsible Investment & Sustainability Risk Policy
This policy describes how we integrate our responsible investment philosophy into each asset class investment process, Multi-asset covers a wide variety of product types including Multi-Strategy, Multi-Asset ranges, Fund of Funds, Liability Driven Investment, Global Convertibles.

Real Assets - Responsible Investment & Sustainability Risk Policy
This policy describes how we integrate our responsible investment philosophy into each asset class investment process, Real Assets covers traditional real estate products and our alternatives real assets business including infrastructure equity and commercial property/private market debt.
Discover our responsible investment policies.

Aviva Investors Luxembourg Sustainability Risk Policy
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 AILX’s ESG approach including consideration of sustainability risk and how they apply to the funds we operate.
Luxembourg SICAV funds with SFDR ESG characteristics (Article 8 and 9)
Aviva Investors has a wide range of sub-funds with Article 8 status as well as some Article 9 funds.
The investment process includes binding ESG characteristics (ESG screens and sector exclusions), and integration of ESG considerations and the investment manager’s transition philosophy into investment decisions.
This approach aligns with Aviva Investors’ long-standing investment philosophy and commitment to responsible investing.
For further information regarding these funds, please see the below documentation which includes the SICAV Impact Assessment Matrix and an outline of Aviva Investors’ approach to Article 9. The detailed pre-contractual information is within the prospectus and also in the website disclosure section of this webpage.
Article 9 Client Facing Summary
For further details of the Aviva Investors' approach to Article 9, please follow the below link.
Website product disclosures
For financial products that promote environmental or social characteristics, financial market participants shall publish the information referred to in Article 10(1) of Regulation (EU) EN 32 EN 2019/2088 and Articles 25 to 36 of this Regulation.
We know what it takes to make a difference
It takes working together to drive sustainable transition across People, Climate, and Earth. It takes Aviva Investors.

Responsible investment views
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Responsible Investing
Changing course: Creating a stable investment framework for offshore wind
30 Nov 2023
Better market mechanisms and grid connection arrangements are essential to restore a stable investment environment in the offshore wind sector, as Nick Molho explains.
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Economic Research
The tipping point for climate finance: Making financial flows consistent with the Paris Agreement
29 Nov 2023
Transition plans, including from governments in response to the Global Stocktake, will be crucial to bring about the shift to a low-emissions, climate-resilient world. Markets need clear implementation signals to align capital with the goals of the Paris Agreement. Our in-depth report calls for the creation of a transition-plan ecosystem connecting all levels of the global economy.
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Fixed income
The time to lead: Reforming multilateral development banks through a climate lens
28 Nov 2023
To have a chance of limiting global warming to less than two degrees, the world must unlock huge investments in emerging markets. This is prompting calls for the reform of multilateral development banks, but will this be enough?
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Responsible Investing
Paying fair: The living wage comes of age
31 Oct 2023
Paying employees a living wage is a growing concern for companies and regulators. As this concept gains traction, it should be viewed as a long-term investment in workers and businesses rather than a cost.
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Economic Research
Gender balance in the workplace: Levelling up
25 Oct 2023
Despite progress on female representation in senior financial roles, the industry is nowhere near parity. We explore how finance can create a level playing field for all genders to thrive.
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Economic Research
Fairness, climate action and nature protection: Our key takeaways from AGM season
18 Oct 2023
Investing to create a more sustainable, stable and prosperous world should be a core part of the purpose of any responsible asset manager. Louise Piffaut reviews our recent engagement activity designed to hold investee companies to account.
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Economic Research
Race, ethnicity and investing: Developing an inclusive culture
13 Oct 2023
Since 2020, we have taken action to improve our own performance on diversity, equity and inclusion and engaged with investee companies on the key issues. On black representation specifically, building an inclusive culture and pipeline of talent are long-term efforts, as Mark Versey explains.
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Fixed income
Integrating net zero in sovereign bond portfolios: Understanding the impacts, risks and opportunities
2 Oct 2023
Investing in climate transition and adaptation plans today adds to governments’ funding needs, but over time should make for stronger, more resilient economies. How should investors approach this to embed net-zero considerations into their sovereign bond portfolios?
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Economic Research
Disability inclusion in the workplace: Taking down the barriers
28 Sep 2023
Disabled employees continue to face a variety of hurdles to cope with in addition to their day job. We look at how employers can help remove those barriers to allow everyone to thrive.
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Fixed income
Navigating uncertainty and avoiding underperformers: Plotting a course for the long term in buy-and-maintain credit
13 Sep 2023
As the current economic cycle draws to a close, our buy-and-maintain team discuss opportunities and risks in credit markets.
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Equities
The big dig: How mining could power a greener future
12 Sep 2023
Clean energy technologies are set to drive growth in demand for critical minerals over the next two decades, throwing up a rich seam of investment opportunities – and challenges.
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Responsible Investing
When the chips are down: Geopolitics threatens the semiconductor boom
11 Sep 2023
While the semiconductor industry should see strong demand thanks to the rise in artificial intelligence and cloud computing, geopolitical and supply-chain risks loom.
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Responsible Investing
Deals delayed and crowded trades…But investors can still find value in infrastructure debt
4 Sep 2023
Private infrastructure debt still offers a broad spectrum of opportunities, but investors face complex challenges. In this Q&A, our infrastructure debt team contemplate the current state of the market and where it goes from here.
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Fixed income
Mad about the boy: Understanding the economic and investment impacts of El Niño
25 Aug 2023
How much do ocean circulation patterns impact economic outcomes and sovereign risk? Rick Stathers and Carmen Altenkirch assess El Niño, the climate phenomenon driving atmospheric circulation in the tropics, affecting everything from GDP to inflation and social stability.
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Equities
Tipping points and transformation: Getting on the right side of change
16 Aug 2023
Rapid changes in the global economy could tip some sectors into low-carbon phases faster than incumbents expect, with important investment implications.
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Fixed income
The heat is on: Opportunities and risks for climate-focused bond investors
8 Aug 2023
Thomas Chinery and Justine Vroman discuss current conditions in the investment-grade market, the ECB’s “green QT” programme, and why oil and gas firms must go further and faster to decarbonise.
Responsible investment
Responsible investment isn’t just the right thing to do, it makes sound financial sense.