Sustainable Finance Disclosure Regulation (SFDR)
The SFDR is a European regulation which introduces the requirement for consistent and transparent disclosure relating to how environmental, social and governance (ESG) risks are integrated into investment processes and how the adverse impacts that investments may have on ESG factors are considered.
This transparency across the industry will facilitate fair comparison and evaluation of financial products’ varying degrees of sustainability.
Phased implementation for affected financial market participants (FMPs) began on 10 March 2021. In order to help our clients and investors better understand the SFDR and its consequences, we have compiled a list of frequently asked questions.
Frequently asked questions
In response to the 2015 Paris Agreement on climate change, the European Union (EU) made clear commitments to transition to a low carbon sustainable economy. In support of this ambition, the European Commission (EC) has put together a Sustainable Action Plan consisting of several regulations targeting ESG goals. EU Regulation 2019/2088 on sustainability-related disclosures in the financial services sector, referred to as the ‘Sustainable Financial Disclosure Regulation’ or ‘SFDR’ is one of these.
The SFDR enforces new transparency and disclosure obligations (with a phased implementation which began on 10 March 2021) on EU firms, as well as products sold in the EU. The disclosures include information on whether an entity, as well as its products, considers sustainability risks, and if they do, how the entities and products incorporate these risks in their investment processes. Periodic reporting requirements will be enforced with a later deadline.
The SFDR aims to increase the transparency with which affected financial market participants and financial advisers integrate sustainability risks in their investment decisions and investment or insurance advice and products.
- It will aim to introduce a common way for asset managers to inform investors about ESG related risks.
- It will aim to help prevent ‘greenwashing’ – that is marketing products as having an ESG component/components when in fact ESG considerations are not substantively taken into account in the investment process.
- It will aim to increase comparability between sustainable financial products and investment processes across the financial markets.
The SFDR will require certain firms, including private banks, wealth managers, asset managers and advisers, to comply with new rules on disclosure regarding sustainable investments and sustainability risks.
The SFDR applies to all EU FMPs, requiring investment products marketed to the EU to be categorised as one of the following:
Article 9 Products
Products that have sustainable investment as their objective
Article 8 Products
Products that promote environmental or social characteristics
Products that do not purport to promote any kind of ESG objective
These categories are decided based on the extent to which ESG or sustainability characteristics are integrated. Disclosure requirements will apply across all categories of products; however the level and type of disclosure required will depend on the classification of the product. All disclosures to an extent will need to detail how risks are incorporated in to the investment management process, as well as the likely impact on returns.
At RLAM, we think that environmental, social and governance issues are increasingly affecting asset prices. We believe that it is in the best interest of our clients for RLAM, where appropriate, to integrate these issues in our investment process with the aim of improving standards, reducing risk and enhancing returns.
However, many of our funds do not have explicit sustainable or ESG targets or objectives and therefore are categorised as ‘Other’ under the SDFR.
RLAM has a long-standing ‘Sustainable Investment’ range of funds dating back to 1990. These funds look to invest in companies that provide a net benefit to society and that we believe have strong environmental, social and governance credentials. This investment process takes our own assessment of a company’s suitability for inclusion and ratifies this using an External Advisory Committee.
Our nine (Irish domiciled) funds that are affected by the SFDR are as follows:
|Royal London Absolute Return Government Bond Fund||Royal London Asset Management Bond Funds plc||Other|
|Royal London Global Bond Opportunities Fund||Royal London Asset Management Bond Funds plc||Other|
|Royal London Global High Yield Bond Fund||Royal London Asset Management Bond Funds plc||Other|
|Royal London Multi-Asset Credit Fund||Royal London Asset Management Investment Funds ICAV||Other|
|Royal London Short Duration Global High Yield Bond Fund||Royal London Asset Management Bond Funds plc||Other|
|Royal London Short Duration Plus Fund||Royal London Asset Management Investment Funds ICAV||Other|
|Royal London Sterling Extra Yield Bond Fund||Royal London Asset Management Bond Funds plc||Other|
|Royal London Sterling Liquidity Money Market Fund||Royal London Asset Management Bond Funds plc||Other|
|Royal London Global Sustainable Credit Fund||Royal London Asset Management
Bond Funds plc
Due to Brexit, the SFDR does not directly apply in the UK. It does not apply to UK advisers (so long as those advisers are solely giving advice in the UK) and does not apply to UK domiciled funds (so long as those UK domiciled funds are not marketed in the EU).
The SFDR does however apply to our Irish domiciled funds. The nine funds affected by the SFDR are outlined above.
The SFDR will have a phased implementation from 10 March 2021.
Though the SFDR does not directly apply in the UK, it is expected that the FCA will introduce similar requirements on UK entities in the near future. If and when new regulations are imposed, RLAM will comply, delivering any requirements by the recognised deadline.
At financial product level
- For all of the funds affected, we now have written policies on our website about how sustainability is integrated in to the investment decision making process and the risks associated with this. Where we do not consider principal adverse impacts (PAIs) we will indicate clear reasons about why impacts are not considered.
At entity level
- We disclose whether we consider PAIs within our investment decision making process (these are impacts of investment decisions that result in negative effects on sustainability factors).
When PAIs are considered, we give:
- Information on identification
- Description of these impacts and any action taken
- A summary of engagement policies
- A reference to responsible business conduct codes and internationally recognised standards for due diligence
When PAIs are not considered, we give:- Clear reasons about why impacts are not considered
- We publish on our website information about our policies on the integration of sustainability risks in our investment decision making process.
- In our remuneration policy, we include information on how the policies are consistent with the integration of risk management (which includes sustainability risks).
- We ensure our ESG messaging across all our sales and marketing materials is consistent.
The Royal London Absolute Return Government Bond Fund, Royal London Global Bond Opportunities Fund, Royal London Global High Yield Bond Fund, Royal London Short Duration Global High Yield Bond Fund, Royal London Sterling Extra Yield Bond Fund, Royal London Sterling Liquidity Money Market Fund and Royal London Global Sustainable Credit Fund are subfunds of Royal London Asset Management Bond Funds plc, an open-ended investment company with variable capital (ICVC), with segregated liability between sub-funds. Incorporated with limited liability under the laws of Ireland and authorised by the Central Bank of Ireland as a UCITS Fund. It is a recognised scheme under section 264 of the Financial Services and Markets Act 2000. The Investment Manager is Royal London Asset Management Limited. Most of the protections provided by the UK regulatory system, and the compensation under the Financial Services Compensation Scheme, will not be available.
The Royal London Multi-Asset Credit Fund and Royal London Short Duration Plus Fund are sub-funds of Royal London Asset Management Investment Funds ICAV, an Irish collective asset management vehicle authorised by the Central Bank of Ireland pursuant to the Irish Collective Asset-management Vehicles Act 2015 and the AIFM Regulations, and has been established as an umbrella fund with segregated liability between Funds. It is not a recognised scheme under the Financial Services and Markets Act 2000. The Investment Manager is Royal London Asset Management Limited. Most of the protections provided by the UK regulatory system, and the compensation under the Financial Services Compensation Scheme, will not be available.