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.
Responsible investment views
Patterns, partnerships and a Marshall Plan for the planet: An interview with Nigel Topping
21 Sep 2022
The UN Climate Change High-Level Champion for the COP26 summit in the UK sets out how the private and public sectors can work together to tackle the climate crisis and other systemic threats. Words by Miles Costello.
Ring the changes: An interview with Kate Raworth
16 Sep 2022
The influential academic speaks to AIQ about the flaws in traditional economic thinking and how her revolutionary “Doughnut” offers a fresh approach to solving the world’s greatest problems.
Moving mountains and markets: A new way to approach systematic risk
14 Sep 2022
A series of market failures have brutally exposed the shortcomings of Modern Portfolio Theory. However, market participants play an active role in markets; they are not mere bystanders. Understanding this could provide a better way to think about and deal with systematic risk.
The levers of change: A systems approach to reconcile finance with planetary boundaries
13 Sep 2022
Financial services underpin all economic activity, which itself depends on Earth’s natural capital. Resolving their interconnected issues to bring about a just transition will require a holistic, systems-thinking approach.
Inflation, volatility and net zero: The outlook for real estate equity
12 Sep 2022
Ben Sanderson and James Stevens from our real estate team discuss risks and opportunities for property investors amid changing work patterns, rising inflation and the race to net zero.
Conflict, inflation and energy security: An updated outlook for infrastructure investors
6 Sep 2022
Darryl Murphy and Sean McLachlan from our infrastructure team assess how Russia’s war on Ukraine, fears over energy security and surging inflation have changed the prospects for infrastructure investors.
Redefining stewardship: Why stakeholder capitalism needs to wake up
31 Aug 2022
Asset managers and other financial institutions have a duty to act in the best interests of their customers and society. Macro stewardship will be crucial to meeting these responsibilities, argues Mark Versey.
Know your limits: An interview with Nafeez Ahmed
29 Aug 2022
Warnings that natural systems are close to breaking point are not new – but how will we respond? Combining what we know with existing technologies could offer a remarkable opportunity to rethink our world, as Nafeez Ahmed explains.
What does the data say? Real Assets in focus
26 Aug 2022
In this month’s instalment of our visual series on topical themes, we look at some of the key recent trends in the real asset universe.
The burning issue: Avoiding ESG fatigue
25 Aug 2022
How can we face existential problems and stay positive? Abigail Herron contemplates simple steps to protect momentum and avoid burnout.
Strategies to change the financial system: An interview with Natalie Mangondo
16 Aug 2022
Can society reform the system that has enabled growth but simultaneously brought the long-term health of the planet into question? UN Climate Change High Level Champions Finance Youth Fellow Natalie Mangondo contemplates choices and change with AIQ.
Global equity income Q&A: Richard Saldanha on the outlook for dividends and growth
3 Aug 2022
The lead manager of our Global Equity Income strategy discusses risks and opportunities for income-seeking investors in a turbulent time for markets.
Long income, short ESG windows: Matching real estate long income and responsible investing timelines
2 Aug 2022
Luke Layfield looks at how real estate long income can help address clients’ ESG responsible investing objectives and how respective timelines for implementing change can be best aligned.
The AIQ Podcast: Taking stock of nature risk
15 Jul 2022
The idea that human actions are bringing natural systems close to breakdown, threatening livelihoods and financial stability, is making asset managers think harder about nature risk and the environmental dependencies in investee companies.
Investing in a just transition to net zero: A Q&A with Nick Robins
30 Jun 2022
Reaching net zero by 2050 will require significant injections of capital. But it is also an opportunity to rethink social relationships, as Professor Nick Robins explains.
Supply chains, painkillers and gene editing: ESG risks in pharma
29 Jun 2022
Reflecting on ESG risks in the pharmaceutical industry, Sora Utzinger discusses supply chains and counterfeit medicines, access to painkillers, and the ethics of gene editing.