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
Private Markets Responsible Investment and Sustainability Risk Policy
This policy describes how we integrate our responsible investment philosophy into each asset class investment process. Private Markets covers traditional real estate products and our alternatives business including infrastructure equity and commercial property/private market debt.
Public Markets Responsible Investment and Sustainability Risk Policy
This policy describes how we integrate our responsible investment philosophy into each asset class investment process across Public Markets, which includes Credit & Equities (funds managed by Aviva Investors that primarily invest in equities and bonds and includes money market funds) and Multi Assets (including Multi-Strategy, Multi-Asset ranges, Fund of Funds, Liability Driven Investment, Global Convertibles).
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.
Responsible investment views
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Economic Research
Only connect: How a holistic approach to investment stewardship can enhance client outcomes
27 Sep 2024
From direct investments and engagement with companies to dialogue with governments and regulators, we believe stewardship efforts can deliver better outcomes for clients.
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Real Assets
Get networking: Will the next decade be a golden age for UK infrastructure?
3 Sep 2024
While there are obstacles to overcome, the coming years could see new opportunities for the UK government and the private sector to work together on infrastructure projects, says Darryl Murphy.
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Real Assets
Real asset stories: Curtain House
8 Aug 2024
In the first instalment of a new series of case studies on our real asset investments, we look at Curtain House, a Victorian warehouse Aviva Investors is converting into a modern, environmentally friendly office building.
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Economic Research
Boosting low-carbon investment in the UK: A Policy Roadmap
16 Jul 2024
Our in-depth Roadmap for the UK’s journey towards a low-carbon economy contains policy recommendations to unlock private investment in the transition.
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Responsible Investing
The future of green premia in real estate, part two: Searching for value and resilience
8 Jul 2024
Do energy-efficient buildings have more pricing power, and what could that mean for those investing in the built environment? We bring together the views of leading capital markets researchers, a valuer and an asset manager for the second part of our deep dive into green premia, analysing the investment implications.
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Responsible Investing
Avoid, reduce, remove, align: Finding climate transition investment opportunities in real assets
3 Jul 2024
In this article, Luke Layfield and Zoe Austin explain four key pillars that can help real asset investors align their strategies with the climate transition and uncover opportunities to deliver attractive returns.
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Responsible Investing
The future of green premia in real estate, part one: The view from the ground
27 Jun 2024
Do greener buildings have more pricing power, and if so, how much? We bring together the views of leading capital markets researchers, a valuer and an asset manager for a two-part deep dive on the latest market dynamics.
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Economic Research
Blueprints for a greener economy: Creating a transition planning ecosystem
25 Jun 2024
National transition plans can give investors support, confidence and direction to accelerate the flow of finance to bring about a low-carbon economy. As such, they should be seen as a strategic opportunity.
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Economic Research
Nothing to fear: Sustainable investing trade-offs
19 Jun 2024
Sustainable investing, and the supposed trade-offs involved, have been a topic of heated debate. But trade-offs are a fundamental part of all types of investment; the key is to be clear about your objectives, as Mirza Baig explains.
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Fixed income
See the wood, not just the trees: How climate-focused credit investors can help drive real-world change
14 May 2024
Green bond funds and Paris-aligned benchmarks are aimed at climate-focused credit investors who also want the simplicity of passive investing. But while they decarbonise portfolios, they exclude the companies in the real economy that need to transition if the world is to meet the Paris Agreement goals. This is why an active approach can be beneficial.
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Real Assets
Building better: Opportunities for DC schemes to invest in the climate transition through real assets
22 Mar 2024
By investing in climate-aligned real assets, defined-contribution pension schemes can help propel the transition while also benefiting from portfolio diversification and attractive risk-adjusted returns, says Mark Meiklejon.
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Equities
The war on bugs: Climate change contributes to growth in the pest-control industry
13 Mar 2024
Pest control has become a growing priority for city residents and authorities all year round, as rising temperatures and other factors boost the populations of many pest species. But in creating adaptation solutions, the sector could also represent a long-term investment opportunity.
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Fixed income
Credit spreads and climate solutions: The outlook for climate-focused bond investors
8 Feb 2024
For the first time in three years, interest rates should no longer be a headwind for credit markets in 2024, but other forms of uncertainty may affect climate-aware bond investors. Our credit experts discuss the key themes they expect to play out over the coming months.
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Responsible Investing
Common ground: Earning a social licence to operate in real asset investing
18 Jan 2024
Successful real asset investing requires acceptance of asset managers’ practices and procedures from a variety of stakeholders. We explore what this means for managers, their clients and investment outcomes.
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Pensions
Plus ça change…The outlook for infrastructure debt in 2024
11 Jan 2024
Infrastructure demonstrated characteristic resilience in 2023 in the face of significant macroeconomic headwinds. Darryl Murphy from our infrastructure team explains why he expects current themes to persist in 2024.
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Real Assets
Tech, trees and tailwinds: The outlook for climate transition real assets
9 Jan 2024
In this Q&A, James Tarry and Luke Layfield explore the themes shaping the landscape for real asset investors with a climate transition focus.