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
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

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.
Turning talk into action
It is only through commitment, passion and genuine collaboration that we can bring our sustainable aspirations to life. In our “This is how” series, we profile some of the ways ESG helps us be better investors, for our clients, and for the world around us.

Responsible investment views

Responsible Investing
Levelling up: Investing towards a new social contract
17 May 2022
As we learn to live with COVID-19, focus is returning to delivering a just transition. This is important to secure long-term investment outcomes, but also presents direct opportunities.
Read more

Responsible Investing
Life force: Why nature matters
12 May 2022
Growing awareness that natural systems are stressed or even close to breakdown is prompting asset managers to look closely at nature-based risks and investee companies to understand their environmental impacts and dependencies.
Read more

Equities
Why investors must act now on the biodiversity crisis
26 Apr 2022
The concepts of biodiversity and ‘natural capital’ have been largely ignored by business and finance until recently. Investors are now starting to take the issue seriously and build it into their thinking.
Read more

Responsible Investing
Disney’s tales of diversity: Creative lessons on developing and identifying talent
13 Apr 2022
Middle managers need to up their diversity, equity and inclusion game. They must think harder about roles models, succession planning, psychological safety and team dynamics to harness untapped human potential, explains Apiramy Jeyarajah.
Read more

Responsible Investing
The challenge of delivering net zero
11 Apr 2022
Financial services businesses have begun the complex businesses of working out how to deliver on their net-zero ambitions and play their part in tackling climate change.
Read more

Responsible Investing
Facing up to the ESG backlash
6 Apr 2022
Asset managers must better explain how ESG can improve investment returns and make the world a better place. Clear guidance to help investors choose between funds is also required.
Read more

Equities
Back to nature: Why we must act now on the biodiversity crisis
31 Mar 2022
In an age of mass extinctions, policymakers, businesses and financial institutions are beginning to acknowledge the risks associated with biodiversity loss, along with the opportunities that arise from nature-positive solutions.
Read more

AIQ Feature
Power to the people: The moral and investment case for human rights
30 Mar 2022
Healthy and happy employees, consumers, and communities are all critical ingredients in a company’s long-term success. Investors have a key responsibility in ensuring the rights of these groups are respected.
Read more

Fixed income
Now for the hard part…..The challenge of delivering net zero
29 Mar 2022
More than one fifth of the world’s largest listed companies have committed to net-zero targets, but few have detailed roadmaps to get there. Mirza Baig considers the challenges for investors managing transition pathways.
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Responsible Investing
Change diets, not the planet: The link between food and sustainability
29 Mar 2022
We explore how shifting diets can help create a more sustainable world.
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AIQ Feature
Tough gig: How to improve the platform economy
28 Mar 2022
Companies operating in the gig economy have been subject to industrial action and legal challenges. Workers say they are being denied basic rights; platforms reply this is the price of flexibility. But there is a viable middle-ground which can be beneficial for all, including investors.
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Responsible Investing
Energy in focus: Part 2: The pivot to green
28 Mar 2022
How will the surge in the prices of oil, gas and coal impact the transition to low or zero carbon sources of fuel? In the second part of our Q&A on the energy sector, experts from our credit, equities and ESG teams contemplate the challenges and opportunities in the pivot to green.
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Responsible Investing
Thick skins and tin ears: Facing up to the ESG backlash
25 Mar 2022
Mark Versey goes on the offensive to dispel recent criticisms against ESG investing.
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Responsible Investing
Energy in focus: Part 1: The last hurrah for fossil fuels?
24 Mar 2022
The fallout from the conflict between Russia and Ukraine has highlighted the fragility of energy markets, with significant implications for the global economy.
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Responsible Investing
Why companies should do more to recruit from diverse socioeconomic backgrounds
22 Mar 2022
There is a strong case for finance and other elite professions to become more socially diverse and tap into a much larger pool of potential talent.
Read more

Responsible Investing
Hope for net zero: Systemic change is rarely linear
21 Mar 2022
Despite concern over the substance behind many national and corporate net-zero commitments, could the pace of change surprise on the upside? Tom Tayler assesses the state of play.
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Responsible investment
Responsible investment isn’t just the right thing to do, it makes sound financial sense.