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.
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)
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
The AIQ Podcast: Embracing neurodiversity at work
12 Jan 2022
Employers have considerable room for improvement when it comes to the working experience for neurodivergent individuals. But a little more understanding and some fairly simple adjustments could make a world of difference.
Investing for climate action: Easy as SBTs?
11 Jan 2022
With governments struggling to turn words into action on climate change, investors can ensure the private sector plays its part by pushing firms to adopt science-based targets, argues Rick Stathers.
Lessons from tech and military: Why asset managers need to be agile to stay effective and relevant
22 Dec 2021
Asset managers must promote diversity of thought if they are to future-proof their businesses and provide clients with great service. They can learn valuable lessons on how to do this from tech companies, military leaders and ancient philosophers, writes Apiramy Jeyarajah, head of UK wholesale at Aviva Investors.
A tough job: Decarbonising heavy industry
20 Dec 2021
Heavy industry and heavy-duty transport are responsible for nearly a third of global carbon dioxide emissions. While reducing emissions from these sectors will be difficult, the transformation will create opportunities for investors.
The social transition: Investing for a more equitable world
14 Dec 2021
Recognising that being a good corporate citizen is the right thing to do and pays off is something investors and the financial community need to think harder about, argue Vaidehee Sachdev and Matt Kirby.
Where the wild things are: Why investors should care about natural capital
14 Dec 2021
Finance must wake up to the risks associated with biodiversity loss and the opportunities that arise from nature-friendly solutions, argue Eugenie Mathieu, Julie Zhuang and Jonathan Toub.
No more lip-service on diversity and inclusion – three principles for financial institutions to follow
13 Dec 2021
In part two of our series on intersectionality, Apiramy Jeyarajah, head of UK wholesale at Aviva Investors, and Mitesh Sheth, outgoing CEO of Redington, explain what investment organisations can do to maximise the return on their most important assets – their people.
Waste not, want not: An investor’s guide to the circular economy
10 Dec 2021
Using the examples of electronics, food, autos and fashion, we explore the benefits of, and challenges to achieving, a more circular economy.
Restoring and caring for the natural world: An interview with John Willis
9 Dec 2021
Scientists around the world have highlighted the need to tread more lightly on the planet, halting then reversing the decline of the natural world. But the financial community, including investors, has been slow to respond.
The future of pharma: Increased returns or the age of biotech?
8 Dec 2021
After decades of low returns on research and development (R&D), the healthcare sector is producing a slew of innovations, from drugs to diagnostics. But with many coming from new entrants, will big pharmaceutical companies manage to keep up with the times?
The cost of climate change: A big threat to sovereign debt?
3 Dec 2021
Governments around the world are struggling to avert a climate catastrophe. Regardless of whether they succeed, climate change threatens adverse consequences for government bonds, although market impacts are likely to vary.
Thinking outside the box: Embracing neurodiversity at work
30 Nov 2021
Enabling neuroinclusion in the workplace still has a long way to go, although better understanding and simple adjustments could make a world of difference.
What does the data say? Parcels, the (other) Amazon and COVID-19
26 Nov 2021
In this month’s instalment of our visual series on topical data themes, we look at the steep increase in deliveries, the continued deforestation of the Amazon rainforest and the rise of COVID-19 in Europe.
Credit: The long and short of ESG investing
25 Nov 2021
Credit is an asymmetric asset class. The upside is a coupon payment and limited capital appreciation; the downside is a default to zero. For all maturities and bond types, ESG integration can play a crucial role in mitigating risk.
The tyranny of “fit”: If businesses want to maximise their potential, they need to be intersectional
24 Nov 2021
Employees are a company’s greatest asset. Leaders must take an inclusive, intersectional approach to enable them to give their best, argues Apiramy Jeyarajah.
Beyond borders: Reflections on a historic COP meeting
19 Nov 2021
COP26 was billed as ‘the most important meeting in history’. Steve Waygood had a front row seat and shares his thoughts on the climate conference.