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.
Through Aviva Investors’ Global Reward Framework, all investment employees should support responsible investment and integrate ESG considerations into their investment processes, including the consideration of sustainability risk. ESG metrics and research are embedded in the investment process and form part of the investment scorecard and annual risk attestation. The chief investment officers and investment desk heads consider how investment employees demonstrate their commitment to ESG processes as part of the determination of performance and pay outcomes.
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
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.
Cut it out! The complex quest to decarbonise heating
16 Mar 2021
More countries are contemplating their visions for a lower carbon world. Norway has excluded fossil fuels entirely for heating buildings, while others are taking a more nuanced approach. So, what are the options for those with environment at the heart of their agenda?
Could hydrogen be a green and cost-effective solution to our energy needs?
15 Mar 2021
As the efforts to battle climate change intensify, scientists are getting excited about hydrogen’s potential as a wonder fuel again. We explain why this is important to investors.
Is ‘purpose’ the new green? Pandemic exposes leaders and laggards in stakeholder capitalism
11 Mar 2021
In 2019, some of the world’s biggest companies pledged to look beyond short-term shareholder value and protect the interests of all stakeholders. The coronavirus pandemic has put these commitments to the test, says Mirza Baig.
Outlook for auto giants unclear in an EV-driven future
10 Mar 2021
Investors are betting the likes of Tesla will win the race for sales of electric vehicles, but traditional carmakers and technology giants may have a say in who passes the chequered flag first.
Can a shift in UK policy help make the ESG case for nuclear?
8 Mar 2021
The UK government says nuclear energy may have a vital role to play in cutting carbon emissions. However, more detail is needed to help investors assess nuclear technology’s ESG credentials, argue Darryl Murphy and Stanley Kwong.
Everybody wants one: Are sustainable bonds the new smartphones?
5 Mar 2021
The COVID-19 pandemic has highlighted the importance and fragility of the natural balance. As governments, companies and investors aim for a just transition, sustainable bonds are being issued at pace in different formats. Is it a fad, and do markets really need so many varieties?
From crisis comes opportunity: What’s normal now?
2 Mar 2021
Big challenges bring us the opportunity to think differently. Our investment teams reveal what they have learnt from COVID-19, and how they are preparing to face whatever ‘normal’ emerges in a post-pandemic world.
Weather shifts and white elephants: How climate risk is moving the goalposts for emerging market investors
10 Feb 2021
Droughts and water shortages used to be associated with the world’s poorest countries. Now middle-income economies are suffering the effects of extreme weather too, with significant implications for investors, says Will Ballard.
The COVID Nudge
28 Jan 2021
In these data visualisations, we look at whether COVID-19 will achieve something that millions spent on public health campaigning has failed to do.
Hot wheels: Cars, climate change and the great EV disconnect
25 Jan 2021
With traditional carmakers under intense pressure to cut emissions in the fight against climate change, investors are putting their money behind pure play electric vehicle producers. Alessandro Rovelli digs into the numbers to assess whether this trend is sustainable.