Principal Adverse Impact Statement (Article 4 - SFDR) 2.1 Purpose and scope of the Principal Adverse Impact Statement In line with the Article 4 of the SFDR, this Principal Adverse Impact Statement aims to describe the due diligence policies with respect to the principal adverse impact of investment decisions on sustainability risk factors . The SFDR creates expectation from every player in the real estate value chain to support the funds' product differentiation and sustainability strategies in their own policies and operating practices. Explanation of non-compliance with SFDR's principal adverse impacts regime Page 4 of 5 2.1 The integration of Environmental, Social and Governance ("ESG") factors into Merchant Banking investment processes and decision-making is amongst our top priorities as an investor. The ESAs have updated the list of indicators for principal adverse impacts. 2. The decisions taken for our discretionary clients and the investment advice provided to our advisory clients are drawn from the same underlying investment view on the relevant stocks. The ESAs have updated the list of indicators for principal adverse impacts. Triodos Investment Management B.V. has the following information available: Our approach to sustainability, describing the integration of sustainability risks in our investment decision-making process as required under article 3 SFDR per 10 March 2021.; A Principal Adverse Sustainability Impacts Statement as required under article 4 SFDR per 10 March 2021. SFDR requires us to make a "comply or explain" decision whether to consider the principal adverse sustainability impacts ("PASI") of investment decisions on sustainability factors in our investment advice. The scope of Article 8: a product which "promotes environmental or social characteristics". As noted earlier, two of the 18 principal adverse sustainability impact indicators We assume that this specifically relates to the ~50 5. The concept of Principal Adverse Impact (PAI) is as follows1: "Negative, material or likely to be material effects on sustainability factors that are caused, compounded by or directly linked to investment decisions and advice performed by the legal entity." SFDR Level 1 requires Managers, on a comply-or-explain basis, to assess and make website disclosure of the negative or adverse impacts of funds' investments on ESG factors. These negative impacts are also called adverse impacts, whereby the most significant adverse impacts are referred to as principal adverse impacts. impact the returns of funds under management and disclose the outcome of that assessment to investors both in the funds' prospectus documents and on the Manager's website. Methodologies and data used to assess each principal adverse impact are disclosed in the annex 1 of GAIF fund. MSCI SFDR Disclosure Report provides metrics and data on mandatory and voluntary adverse impact indicators for MSCI using the latest mapping MSCI ESG Research has developed following the release of the draft Regulatory Technical Standards (RTS) in August 2021. A flagship concept in SFDR is reporting the principal adverse impacts (PAIs) of your investment decisions 2. SFDR - Article 4 Principal Adverse Impacts Statement ASR Vermogensbeheer N.V. 1. Accounting for the principal adverse impacts of investment decisions on sustainability factors LAM and LIAM take into consideration the principal adverse impacts ("PAI") of their investment decisions on Principal adverse impact disclosure — Article 4(6) and 4(7) SFDR The draft RTS provides a specification for the content, methodology and presentation of the information required in respect of the sustainability indicators in relation to adverse impacts on the climate and other environment-related adverse impacts. The principal adverse impact reporting in the SFDR is based on the principle of proportionality - for companies with fewer than 500 employees, the entity-level principal adverse impact reporting applies on a comply-or-explain basis. In this statement, ASR Vermogensbeheer N.V. (AVB) explains how it takes into account the prevention of possible adverse effects on sustainability (or Principal Adverse Impacts) in its investment decisions. The ESA summary added the principal adverse impact reporting in the SFDR is based on the principle of proportionality - for companies with fewer than 500 employees, the entity-level principal adverse impact reporting applies on a comply-or-explain basis. for professional clients and qualified investors only. The application of SFDR to non-EU AIFMs and sub-threshold AIFMs. Systematica does not currently consider all the principal adverse impacts of its investment decisions on sustainability factors in accordance with Article 4 of the SFDR, as the detailed rules and guidance The SFDR regulations went into effect in March 2021, with the application of the RTS, drafted by Europe's three primary financial regulatory agencies, the European Supervisory Authorities (ESAs), originally anticipated for January 2022. Financial Market Participants [FMPs] can start considering principal adverse impacts. the Consideration of Principal Adverse Impacts of Investment Decisions on Sustainability Factors . "Principal adverse impacts" ("PAI") reporting is the requirement under the SFDR for larger firms to consider and report on a range of sustainability factors (framed as "externalities" because they may not be related to the value of the investment) across all their portfolios. Description of policies to assess principal adverse sustainability impacts The SFDR prescribes APG AM to describe the policies to assess, identify and prioritize principal adverse sustainability impacts on sustainability indicators. 4. The reporting period will cover 1 January 2022 - 31 December 2022. 1. Specifically, there had been some uncertainty as to whether principal adverse impact statements were required for Article 9 Products. Disclosure Regulation (SFDR). This policy is in line with the requirements set out in the EU Sustainable Finance Disclosure Regulation ('SFDR'), The description of principal adverse impacts must include the 32 minimum principal adverse impacts on sustainability factors set out in Table 1 of Annex I, plus at least one additional principal adverse impact on a climate or other environment-related sustainability factor that qualifies as principal as set out in Table 2 Description of actions taken to address principal adverse sustainability impacts Information about Policies on Identification and Prioritization of Principal Adverse Sustainability Impacts and Indicators As an active manager whose heritage is built on rigorous, fundamental analysis, ESG considerations have . Principal Adverse Impact Statement Managers must decide: (a) to implement a due diligence policy with respect to the principal adverse impacts of its investment decisions on sustainability factors; or (b) provide an explanation as to why the manager does not consider such adverse impacts. EU SFDR Solution: Disc losing Principal Adverse Impact Indicators In an effort to mitigate greenwashing and clarify how to integrate sustainability and environmental, soci al, and governance (ESG) factors into investments, the European Union (EU) is gradually implementing the Sustainable Finance Disclosure Regulation (SFDR). Principal Adverse Impact (PAI) is a key concept in the EU's Sustainable Finance Disclosure Regulation (SFDR), one of the EU Action Plan on Sustainable Finance's landmark regulations. Speed read The most innovative and challenging aspect of the EU's Sustainable Finance Disclosure Regulation (SFDR) is probably the new principal adverse impacts or PAI regime. The list identifies the mandatory PAIs as being: - Investments in companies: 14 mandatory PAIs plus a requirement to report on two further indicators: one environmental and one social/governance - The principal adverse impact reporting in the SFDR is based on the principle of proportionality - for companies with fewer than 500 employees, the entity-level principal adverse impact reporting applies on a comply-or-explain basis. sfdr: principal adverse impacts ('pai') statement june 2021 for issue in the uk and eu. PAI stands for Principal Adverse Impacts. It is noted that the regulatory technical standards ("RTS") to specify the details of the content, methodologies and . RTS on SFDR: Level 2 measures have been postponed, and mandatory Principal Adverse Impact (PAI) indicators were reviewed. While the concept is ill-defined in the regulation, it is generally interpreted as the negative impact that an investment has on climate change, the environment, social and employee matters, human rights and anti-bribery and anti-corruption. Principle adverse impacts: - The application of the "Comply or Explain" principle. PAI is defined as "Negative, material or likely to be material effects on sustainability factors that are caused, compounded by or directly linked to . Considering Principal Adverse Impacts Our approach for investments September 2021 The EU's Sustainable Finance Disclosure Regulations (SFDR) aim to provide transparency on sustainability within financial markets in a standardised way. New SFDR principal adverse impacts or PAI regime - key points 1. Purpose This is the Principal Adverse Sustainability Impacts Statement of Triodos Investment Management B.V. ('Statement'), effective as of 10 March 2021, as per SFDR article 4. Consideration (or not) of Principal Adverse Impacts. This is being introduced in stages, starting from 10 March 2021. The following is the Principal Adverse Impact (PAI) Statement of Storebrand Asset Management AS (SAM) and its subsidiaries, Delphi Funds, SPP Fonder, SKAGEN Funds and Cubera, collectively referred to as SAM Group. The entity-level disclosure of principal adverse impacts will apply from March 10, 2021 with an update to websites referencing the relevant policies according to the high level framework set out . BNP Paribas Asset Management considers principal adverse impacts of its investment decisions on sustainability factors. Principal Adverse Sustainability Impacts Statement (Article 4) EU Sustainable Finance Disclosure Regulation The Sustainable Finance Disclosure Regulation ("SFDR" or the "Regulation") applied from 10 March 2021. ("SFDR Regulation"). Information Classification: GENERAL Introduction •As part of the EU Financing Sustainable Growth Action Plan, the EU Sustainable Finance Disclosure Regulation (SFDR) was established to lay down harmonized rules for financial market participants and financial advisers on transparency with regard to the integration of sustainability risks and the consideration of adverse sustainability impacts . The Regulation requires financial market participants such as apital Dynamics (the "firm") to provide information . This should help investors to make better comparisons between asset managers A prescribed format of this statement is set out in the RTS in Annex 1. These principal adverse impacts can occur in different areas, such as related to environmental, social and employee matters, human rights, corruption and bribery matters. Article 4 of SFDR requires managers (on a "comply or explain" basis) to publish on their websites a statement on the due diligence policies concerning principal adverse impacts of investment decisions on sustainability factors (the "PAI Statement"), taking into account the manager's size, nature, scale of activities and the types of . Some firms, on their own, may be using Adverse Sustainability Impact Statements as plans for how to meet ESG criteria. Under Article 7 SFDR, certain financial products (where the financial market participant considers principal adverse impacts (PAI) of its investments decisions on sustainability factors) are required to make pre-contractual disclosures, by 30 December 2022, whether, and if so how, the financial product considers PAI and refer to a PAI statement . AI intends to consider the principal adverse impacts of investment decisions on "sustainability factors", defined as environmental, social and employee matters, respect for human rights, anti‐corruption and anti‐bribery matters. C. Description of policies to identify and prioritize principal adverse sustainability impacts As part of the ESG framework and as set in the responsible investment strategy of the company, GAC has PAI is defined as "Negative, material or likely to be material effects on sustainability factors that are caused, compounded by or directly linked to . SFDR is a framework that provides a harmonised approach to the sustainability-related disclosures which financial market participants (FMPs) and financial advisors (FAs) must make to investors in the EU. C. Description of policies to identify and prioritize principal adverse sustainability impacts As part of the ESG framework and as set in the responsible investment strategy of the company, GAC has Principal Adverse Impacts Reporting (Article 4 of the SFDR). Article 11 SFDR periodic disclosures for Article 8 and Article 9 products . include an explanation on whether, and, if applicable, how, the principal adverse impacts of the investment decisions/portfolio on the sustainability factors are considered and that that information on the principal adverse impacts is included in the periodic reports (for funds, the annual report). Entity level principal adverse impact reporting The draft RTS for entity level principal adverse impact reporting provide a specification for the content, methodology and presentation of the information required by Article 4(1)-(5) SFDR in respect of the sustainability indicators in relation to (1) adverse impacts on the climate and other This statement is the principal adverse sustainability impact The entity-level disclosure of principal adverse impacts will apply from March 10, 2021 with an update to websites referencing the relevant policies according to the high level framework set out . The sustainability rating of the product is a robust basis allowing to identify principal adverse impacts on a product, and take into account the principal adverse impacts by classifying the product, or even, when relevant, excluding the product, and then informing the client. O ne of the more novel elements of the Sustainable Finance Disclosures Regulation (SFDR) is the introduction of the concept of "principal adverse impact". Article 10 SFDR website disclosures for Article 8 and Article 9 products. This list is part of the draft Regulatory Technical Standards (RTS), which are not yet binding and are currently expected to apply as of January 2022. policies. opportunities into the investment decision-making process and consider principal adverse impacts of investment decisions on sustainability factors. The European Supervisory Authorities (ESAs) have published the final draft of the Regulatory Technical Standards 1 (RTS) under the EU Sustainable Finance Disclosure Regulation 2 (SFDR), which set out the detailed disclosure requirements for the principal adverse impacts sustainability statements 3 and the disclosure requirements for Article 8 4 and Article 9 5 funds or . About the EpisodeThe Sustainable Finance Disclosure Regulations (SFDR) is part of a suite of recent European Union regulations designed to redirect flows of . SFDR Adverse Sustainability Impacts Statement Article 4 of the RTS on SFDR states that by 30 June of each year the FMP is required to publish the so-called "Adverse Sustainability Impacts Statement" on their website. As part of its management activities, LAM and/or LIAM shall take into account the principal adverse impacts in the terms described below. As part of SFDR, the European Supervisory Authorities have identified a potential list of principal adverse impact indicators that Financial Market Participants will need to report on annually. How Principal Adverse Impacts (PAI) on environmental and social matters resulting from an investment decision are considered must be disclosed by financial market participants on a "comply or explain" basis from 10 March 2021 and on a mandatory basis for entities subject to the Non-financial information Reporting Directive (NFRD) at entity . 2021 SFDR Erklärung zu den wichtigsten nachteiligen Auswirkungen auf Nachhaltigkeit (PAI) | 5 Wesentliche Risiken werden von den Portfoliogruppen im Rahmen des Risikomanagements bei den regelmäßigen Risiko- und Portfolio-Überprüfungen mit den Chief Investment Officers (CIO) diskutiert. Version 10 March 2021 1. Regulation ("SFDR"). . Consideration of principal adverse impacts on sustainability factors For the purposes of disclosure in accordance with the EU Sustainable Finance Disclosure Regulation (SFDR), this document explains how State Street Global Advisors considers principal adverse impacts of its investment decisions on sustainability factors ("PAIs" or Principal adverse impacts (PAI) - footprint / active ownership and engagement. Principal adverse impacts (PAI) (Article 4, SFDR) - Direct vs indirect holdings A principal adverse impacts disclosure must be done on a "look through" basis where the investee company is a holding company, fund or SPV - ie looking through to the underlying assets (recital 4, RTS). Article 8 SFDR ("light green") and Article 9 SFDR ("dark green") product pre-contractual disclosure requirements, including templates. Principal Adverse Impact (PAI) is a key concept in the EU's Sustainable Finance Disclosure Regulation (SFDR), one of the EU Action Plan on Sustainable Finance's landmark regulations. 4 of SFDR, that is, specifically, the disclosure requirements applicable to us as a firm with regard to whether and how we consider principal adverse impacts of investment decisions on sustainability factors. Preparing for Principal Adverse Impacts Reporting under the SFDR. SFDR seeks to ensure investors of all kinds are given more transparency about the sustainability‐related impacts of their investments in . 2021, Refinitiv has analyzed the three tables provided in the report concerning Principal adverse sustainability impacts statement and carried out a coverage exercise, further details can be found below. Table 1 of the draft RTS sets out the proposed final list of principal adverse impacts ('PAIs'). Sustainability factors under SFDR are defined as environmental, social and employee matters, respect for human rights, anti . The EU SFDR outlines specific definitions for Sustainability Risks and Principal Adverse Impacts: Sustainability Risks refer to environmental, social or governance events, or conditions, such as climate change, which could cause a material negative impact on the value of an investment. Earlier this year, the European Commission delayed implementation to July 2022 in order to bundle all of . there are three distinct areas that fall under the sfdr's general principles of sustainability-related disclosures: the integration of sustainability risks in investment decision-making processes; the consideration of adverse sustainability impacts in their processes, and the provision of sustainability‐related information with respect to … While the concept is ill-defined in the regulation, it is generally interpreted as the negative impact that an investment has on climate change, the environment, social and employee matters, human rights and anti-bribery and anti-corruption. Generally, firms will be expected to report on sustainability risks and factors that will be affected by their business decisions, as detailed in an informational paper by global . For all funds and mandates with an ESG approach (Article 9 or Article 8 of SFDR), BIL defines ESG characteristics which must be followed. ('SFDR'). Template principal adverse sustainability impacts statement For the purposes of this Annex, the following definitions shall apply: (1) 'scope 1, 2 and 3 GHG emissions' means the scope of greenhouse gas emissions referred to in subpoints (i) to (iii) of point (1)(e) of Annex III of Regulation (EU) 2016/1011; 1. - The calculation of the "500 employee test". 12 Where the manager does consider the The SFDR also requires asset managers to disclose their policies regarding the consideration of principal adverse impacts (PAI) of investment decisions on sustainability factors on a "comply or explain" basis. Article 4 SFDR Principal Adverse Impact (PAI) reporting. June 30, 2021: Latest date by which FMPs (with more than 500 employees on group level) must start considering principal adverse impacts. O ne of the more novel elements of the Sustainable Finance Disclosures Regulation (SFDR) is the introduction of the concept of "principal adverse impact". please refer to all risk disclosures at the back of this document. The EU Sustainable Finance Disclosure Regulation (SFDR) has applied on a "Level 1" or high-level principles basis since 10 March 2021. While the requirements in the SFDR relating to the entity-level disclosure of principal adverse impacts apply from 10 March 2021 (Level 1) on a comply or explain basis, the additional detailed entity and product level 2 disclosures, which includes the 'principal adverse sustainability impacts statement' will apply from 1 January 2022. As with many EU Regulations, the SFDR requires a detailed Regulatory Technical Standard (RTS) - Level 2, to be published before market participants have a complete picture of how the legislation is intended to be applied. This content is intended to provide transparency on offerings for investors of selected UBS Legal entities in the scope of the Sustainable Finance Disclosure Regulation (SFDR), as well as on the integration of sustainability risks, the consideration of principal adverse sustainability impacts, sustainable products that promote environmental or social characteristics and on products that have .
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