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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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.
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Equities
Defensive sectors offer value amid AI frenzy: What next for global equity income investors?
7 Aug 2023
Dividends proved resilient in the first half of 2023. Richard Saldanha considers what the rest of the year might have in store for income investors.
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Equities
Conflict and complexity: The investment view on defence
2 Aug 2023
The war in Ukraine and rising geopolitical tensions are prompting governments around the world to beef up defence spending. We explore the key investment implications.
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Equities
Over(shooting) the limit: Why we need to keep within planetary boundaries
26 Jul 2023
Demand for fuel and raw materials is decimating the natural world, making extreme climate effects more likely. So, what might the world be like for people and investors as we go beyond planetary boundaries?
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Responsible Investing
Methane: Heating up
25 Jul 2023
Methane is the second most important gas contributor to climate change after carbon dioxide, but its warming potential is many times greater. Mikhaila Crosby explains why addressing emissions is a key priority.
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Fixed income
Something borrowed, something blue: Emerging markets drive innovation in sustainability bonds
6 Jul 2023
Faced with escalating climate and biodiversity crises, developing economies are innovating with new ways to link bond issuance with sustainability goals. This brings risks and opportunities for investors, say Liam Spillane and Emilia Matei.
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Economic Research
Accelerating climate solutions: The Edinburgh Earth Initiative in profile
30 Jun 2023
In the 17th and 18th centuries, academics at the University of Edinburgh helped drive the Industrial Revolution. Today, they are connecting with businesses to tackle the climate emergency. Words by Miles Costello.
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Responsible Investing
Plug in and power up: How EV-charging infrastructure can help future-proof real assets portfolios
28 Jun 2023
As the transition away from petrol-powered cars to electric vehicles accelerates, demand for charging points is rising. We explore the implications for investors in real assets.
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Equities
Don’t stand so close to me: Why UK equity income investors need to stop hugging the benchmark
22 Jun 2023
Chris Murphy and James Balfour believe this is shaping up to be a much better year for UK income investors as the performance disparity between large and mid-cap stocks begins to unwind.
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Equities
Cellular agriculture: Science fiction or reality?
13 Jun 2023
Cultured lab-grown meat and precision fermentation could significantly reduce the environmental impact of the food industry. But these technologies are at an early stage and questions remain around regulation and demand.
Responsible investment
Responsible investment isn’t just the right thing to do, it makes sound financial sense.