The identification of principal adverse sustainability impacts is embedded in the ESG scoring methodology. SFDR overall names 32 principal adverse impacts. The Principal Adverse Sustainability Impacts Statement SFDR Article 4 1. opportunities into the investment decision-making process and consider principal adverse impacts of investment decisions on sustainability factors. This Statement Schroder Real Estate Kapitalverwaltungsgesellschaft mbH ("SREK") considers the principal adverse impacts of its investment decisions on sustainability factors. These principal adverse impacts can occur in different areas, such as related to environmental, social and employee matters, human rights, corruption and bribery matters. This policy is in line with the requirements set out in the EU Sustainable Finance Disclosure Regulation ('SFDR'), 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. PAI is defined as "Negative, material or likely to be material effects on sustainability factors that are caused, compounded by or directly linked to . - The calculation of the "500 employee test". Specifically, there had been some uncertainty as to whether principal adverse impact statements were required for Article 9 Products. Principal Adverse Impacts Reporting (Article 4 of the SFDR). 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. not to be reproduced without prior written approval. 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 . 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). 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 . 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. 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. 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. New Irish Funds Research highlights Significant Data Challenges . Therefore, this document also sets outs Baillie Gifford's approach on the consideration of principal adverse impacts of investment advice. 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 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 . ("SFDR Regulation"). Introduction. 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. 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. A flagship concept in SFDR is reporting the principal adverse impacts (PAIs) of your investment decisions 2. 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. Principal adverse impacts (PAI) - footprint / active ownership and engagement. As part of its management activities, LAM and/or LIAM shall take into account the principal adverse impacts in the terms described below. 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 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. Assess and report on the Principal Adverse Impacts of your products and portfolios ISS ESG's SFDR Principal Adverse Impact Solution enables Financial Market Participants to measure the performance of their investments against the regulatory defined Principal Adverse Impact indicators and metrics in order to comply with the new disclosure obligations. PAI stands for Principal Adverse Impacts. 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 March 10, 2021: Effective date of the SFDR regulation. Principle adverse impacts: - The application of the "Comply or Explain" principle. This is being introduced in stages, starting from 10 March 2021. 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 . The Sub-Fund strives for economic results, while at the same The Regulation requires financial market participants such as apital Dynamics (the "firm") to provide information . The EU Sustainable Finance Disclosure Regulation (SFDR) has applied on a "Level 1" or high-level principles basis since 10 March 2021. 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. It is noted that the regulatory technical standards ("RTS") to specify the details of the content, methodologies and . O ne of the more novel elements of the Sustainable Finance Disclosures Regulation (SFDR) is the introduction of the concept of "principal adverse impact". Consideration (or not) of Principal Adverse Impacts. UK/EU impacts Disclosure measures, covering securities, supernationals, sovereigns and real estate, will 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. 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. June 30, 2021: Latest date by which FMPs (with more than 500 employees on group level) must start considering principal adverse impacts. 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. please refer to all risk disclosures at the back of this document. "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. About the EpisodeThe Sustainable Finance Disclosure Regulations (SFDR) is part of a suite of recent European Union regulations designed to redirect flows of . Earlier this year, the European Commission delayed implementation to July 2022 in order to bundle all of . 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 - 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; 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. 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 more details on how we integrate principal adverse impacts - including our policies and actions - in our investments please see the infographics below or read our SFDR Disclosure Statement. 1. SFDR - Article 4 Principal Adverse Impacts Statement ASR Vermogensbeheer N.V. 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. Version 10 March 2021 1. 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). The application of SFDR to non-EU AIFMs and sub-threshold AIFMs. 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. 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. Description of actions taken to address principal adverse sustainability impacts 1. 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 . Methodologies and data used to assess each principal adverse impact are disclosed in the annex 1 of GAIF fund. A prescribed format of this statement is set out in the RTS in Annex 1. 4. Article 11 SFDR periodic disclosures for Article 8 and Article 9 products . This statement is the principal adverse sustainability impact 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. 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. Article 10 SFDR website disclosures for Article 8 and Article 9 products. The reporting period will cover 1 January 2022 - 31 December 2022. 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 . This template consists of seven main elements: Summary Methodologies and data used to assess each principal adverse impact are disclosed in the annex 1 of GAIF fund. O ne of the more novel elements of the Sustainable Finance Disclosures Regulation (SFDR) is the introduction of the concept of "principal adverse impact". Some firms, on their own, may be using Adverse Sustainability Impact Statements as plans for how to meet ESG criteria.
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