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.
Many of the new measures are a response to the landmark Paris Agreement on climate change in December 2015, and the United Nations 2030 Agenda for Sustainable Development published earlier the same year, which set out the 17 Sustainable Development Goals. SFDR and other regulations are also aligned with the European Green Deal, which aims for the EU to be ‘climate neutral’ by 2050.
Product classifications under SFDR
The most visible and impactful aspect of SFDR is the classification of funds and mandates into 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 – provided they are clearly labelled as non-sustainable – they may not be promoted as ESG funds when matched against more sustainable products.
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 fund classifications under SFDR
Currently, most funds managed by Aviva Investors will be classified as neutral under SFDR. We also have a number of Article 8 funds, including our Climate Transition range. We do not currently manage any Article 9 funds or mandates.
Aviva Investors has updated EU fund prospectuses, website product information and Key Investor Information Documents to align with SFDR rules where applicable, along with updated responsible investment policies shown below.
Adverse impact statement
We have described our adverse impacts policy in our responsible investments policy. Subsequently, we will publish an adverse impact statement before the end of June 2021. The statement will describe how we measure the main adverse impacts investee companies have on sustainability factors.
It will use a system of 14 mandatory and 18 voluntary indicators, with sets of specific indicators for individual asset classes. Mandatory indicators range from carbon emissions, fossil fuel exposure and waste levels to gender diversity, due diligence on human rights and exposure to controversial weapons.
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.
Luxemburg SICAV funds with SFDR ESG characteristics (article 8)
For more details of how the objective and policy of the Aviva Investors Climate Transition Global Credit Fund, Aviva Investors Climate Transition European Equity Fund, Aviva Investors Climate Transition Global Equity Fund and Aviva Investors Sustainable Income & Growth Fund works, including a description of their characteristics.
Responsible investment views
Carbon accounting: Measuring what matters
11 Jun 2021
The focus on net-zero targets has intensified scrutiny on measurement and disclosure of greenhouse gas emissions. But carbon accounting is a young art, explains Dr Matthew Brander, senior lecturer at the University of Edinburgh.
Action now! Accelerating litigation to meet climate targets
3 Jun 2021
A landmark legal ruling in the Hague has ordered Royal Dutch Shell to move faster to bring its emissions in line with the Paris Agreement on climate. Thomas Tayler, a trained lawyer and senior manager at Aviva Investors’ Sustainable Finance Centre for Excellence, assesses the fallout.
What does the data say?
What does the data say? Tesla, the halo effect and reasons for CEO departures
28 May 2021
In the latest instalment of our visual series on topical data themes, we look at Tesla’s market cap relative to the European “Big Five” carmakers, the average CSR spending of FTSE 100 companies versus their procurement budget and the most common reasons for a CEO to leave a company.
Carbon credits: Seeing the wood for the trees
20 May 2021
As governments and companies strive to reduce carbon emissions and achieve net zero, questions are being asked about the role of natural climate solutions. We analyse differing approaches to offsetting and their impact on forest management.
Green is not always clean: Rising tide of greenwash brings risks for investors
19 May 2021
Some companies have long sought to mislead the public about their commitments to sustainability, but greenwashing has become more widespread and sophisticated in recent years. Now regulators and investors are fighting back.
Will companies embrace a more inclusive form of capitalism?
18 May 2021
Just before COVID-19, some of the world’s biggest companies pledged to look beyond the pursuit of profit alone to consider the interests of a wider group of stakeholders, including employees and local communities. But are they ready to back up their words with actions?
By the people, for the people: Why investors should care about human rights
17 May 2021
Companies cannot thrive without healthy and happy employees, consumers, and communities. Investors must use their influence with companies and other stakeholders to ensure the basic rights of these groups are respected.
Unlocking carbon capture and storage: An Interview with Stuart Haszeldine
12 May 2021
The professor of carbon capture and storage at the University of Edinburgh discusses why achieving net zero needs multiple technologies and explains the thinking behind the UK’s evolving approach.
Are sustainable bonds the new smartphones?
10 May 2021
The market for sustainable bonds to fund activities that have a positive impact on the environment or society is booming. But there are many factors to consider before investing. Not least among them is a crucial question: is your money really being used to fund the activities promised?
To improve diversity, asset managers should rip up the rulebook on recruitment
21 Apr 2021
For too long, the investment industry has relied on staid recruitment methods that maintain the status quo. By doing things differently, we can improve diversity and future-proof our businesses, says Apiramy Jeyarajah.
Joana Setzer Q&A: On the climate litigation front line
9 Apr 2021
Joana Setzer from the Grantham Research Institute on Climate Change at LSE discusses the implications on governments and companies of the growing wave of climate litigation.
Law and climate disorder: Understanding physical, transition and litigation risk
9 Apr 2021
Major listed companies are finding themselves the target of legal action designed to make them move faster towards a lower carbon world. These cases could mark an inflection point; when the conversation turns toward specific responsibilities to move away from fossil fuels rather than broad commitments to change.
Living in the past: Why are controversy scores so controversial?
8 Apr 2021
Many investors use controversy scores as a filter to avoid firms whose damaging behaviour has hit the headlines, from human rights violations to environmental disasters. But these scores have serious limitations, making them an inadequate tool for investors who want to manage ESG risks and have a positive impact.
Lean on me: How can bond investors influence government climate action?
25 Mar 2021
The coronavirus epidemic has further accelerated the rise of ESG into the investment mainstream. As deficits skyrocket, bond investors have an opportunity to engage with governments on climate change, argues Thomas Dillon.
Building a better world after COVID-19
18 Mar 2021
There is a growing consensus among companies, governments and electorates across the globe that the world after the pandemic should be greener. But how should we go about this?
Podcast: A clear green premium
18 Mar 2021
Our Head of ESG, Ed Dixon, recently joined Blackstock Consulting on a PropCast episode to launch their new series of ESG insights with industry leaders. Together, they discussed how the government needs to be partnering with businesses to reach their climate pledges, how the “green premium” is yielding higher rents for eco-friendly offices, and much more.