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 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 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.
Aviva Investors Liquid Markets - Principle Adverse Sustainability Impacts Statement
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)
Aviva Investors will transition specific sub-funds from Article 6 to Article 8 Funds in compliance with the European Commission’s Sustainable Finance Disclosure Regulation (or “SFDR”). This transition will be effective 1 July 2022 and was advised in the Notice to Shareholders on 31 May 2022 for Aviva Investors (SICAV) and 1 June 2022 for Aviva Investors Global (SICAV-SIF).
The investment process will now include binding ESG characteristics (ESG screens and sector exclusions), further integration of ESG considerations and the investment manager’s transition philosophy into investment decisions.
This change aligns with Aviva Investors’ long-standing investment philosophy and commitment to responsible investing. The changes will not affect the sub-funds’ stated investment objectives, the way they are managed or the overall risk profile.
For further information regarding these changes, please see the below documentation which includes the Notice to Shareholders, the SICAV Impact Assessment Matrix and an outline of Aviva Investors’ approach to Article 8.
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.
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It takes working together to drive sustainable transition across People, Climate, and Earth. It takes Aviva Investors.
Responsible investment views
All change: Positioning for a new market regime and climate action in IG credit
17 Mar 2023
Justine Vroman and Tom Chinery discuss the opportunities in investment-grade credit to drive climate action.
Engaging on neurodiversity: What can be learned from other DE&I initiatives
10 Mar 2023
Many diversity, equity and inclusion initiatives have seen improvements in recent years, but neurodiversity has not progressed at the same pace. Abigail Herron explores what can be applied from other successful DE&I campaigns to put neurodiversity firmly in the spotlight.
Gas versus renewables: Does natural gas have a future?
8 Mar 2023
The war in Ukraine has thrown up huge uncertainties around the role of gas in the energy system. Experts from our credit, ESG and real assets teams discuss the implications for traditional energy and renewables companies.
To build or not to build, that is the question: Decarbonising the built environment
28 Feb 2023
We assess the financial and environmental pros and cons of developing new buildings versus retrofitting old ones.
Pragmatism, policy and pace: An interview with Julie Hirigoyen
20 Feb 2023
The chief executive of the UK Green Building Council sets out her blueprint for a net-zero-aligned property and construction industry. Words by Miles Costello.
The economics of renewables: Challenges and solutions
10 Feb 2023
Meeting 2050 net-zero targets will require adding renewable energy capacity at scale and speed. Can it make financial sense, or will we need to rely on our commitment to do the right thing?
Our annual letter to company chairpersons
6 Feb 2023
Every January, we send a letter to the chairs of companies we invest in (and some we don’t, but still want to influence) to set out our stewardship priorities for the year. Here, in full, is our 2023 letter.
Why infrastructure investors better beat beta: End of cheap-money era brings risks and opportunities
25 Jan 2023
Benign macroeconomic conditions have boosted infrastructure investments over the past decade. But with higher interest rates, investors in the asset class will have to show they can create true value, says Darryl Murphy.
Charging up: Batteries and the fight against climate change
5 Jan 2023
Batteries are set to play a crucial role in helping to decarbonise the global transport and energy sectors. As capital floods into an industry experiencing exponential growth, we look at the key considerations for investors.
What does the data say?
What does the data say? Reflections on COP27
14 Dec 2022
In this month’s instalment of our visual series on topical themes, we look at climate in the aftermath of November’s COP27 event in Egypt.
Building to net zero: The outlook for climate transition real assets
8 Dec 2022
James Tarry and Luke Layfield explore how the accelerating climate transition is creating risks and opportunities for real assets investors.
Confronting a permacrisis? The intersection between antimicrobial resistance, climate change and biodiversity loss
23 Nov 2022
Will a warmer and less biodiverse world give pathogens new opportunities, and do we have the tools to confront disease? This report discusses the complex intersection of three planetary crises and calls for urgent action to slow resistance to antimicrobial drugs – an obvious public health emergency.
Building better: Investing in the climate transition through real assets
15 Nov 2022
Investors in real assets can propel the transition to a more sustainable future while also benefiting from portfolio diversification and attractive returns, says Mark Meiklejon.
Circularity, consumers and change: Making the switch to sustainable materials
3 Nov 2022
To meet net-zero and other environmental targets, companies and governments increasingly need to move towards more sustainable materials. But this will not be without challenges.
Act now: A climate emergency roadmap for the international financial architecture
1 Nov 2022
To help tackle the climate emergency, financial institutions and governments must work together to reform the global financial architecture and create a more robust net-zero transition plan, argue Steve Waygood and Thomas Tayler.
ESG considerations for social housing
28 Oct 2022
Social housing plays a pivotal role in providing affordable housing for those most in need of it, benefiting local communities and countries as a whole. But investors considering an allocation to the asset class must pay close attention to the ESG implications, argues Mikhaila Crosby.
Responsible investment isn’t just the right thing to do, it makes sound financial sense.
Access key fund documentation and performance reports.