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.
Responsible investment views
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.
Alpha, asset stranding and action: The state of play in Climate Transition Credit
6 Oct 2022
Will new climate legislation accelerate the transition, or will the energy crisis hamper it? Thomas Chinery and Justine Vroman assess the implications for strategically positioned bondholders.
Reframe and reclaim: How to win the ESG argument
6 Oct 2022
To restore trust in ESG, we need to be much clearer on its limitations as well as its strengths, argues Mirza Baig.
Resilience and selectivity: The outlook for real estate long income
5 Oct 2022
Renos Booth, Isabel Gossling and Kris McPhail from our real estate long income team discuss the strengths of long-income strategies in a period of high inflation and rising rates.
So, you’ve set your net-zero target: What next? Practical considerations for asset owners on achieving net zero
27 Sep 2022
Asset owners are increasingly committing to net-zero emissions in their portfolios by or before 2050, but it is a huge and complex undertaking. What do asset owners need to consider as they start on their decarbonisation journey?
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.