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.
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 - 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
Private Markets Responsible Investment and Sustainability Risk Policy
This policy describes how we integrate our responsible investment philosophy into each asset class investment process. Private Markets covers traditional real estate products and our alternatives business including infrastructure equity and commercial property/private market debt.
Public Markets Responsible Investment and Sustainability Risk Policy
This policy describes how we integrate our responsible investment philosophy into each asset class investment process across Public Markets, which includes Credit & Equities (funds managed by Aviva Investors that primarily invest in equities and bonds and includes money market funds) and Multi Assets (including Multi-Strategy, Multi-Asset ranges, Fund of Funds, Liability Driven Investment, Global Convertibles).
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.
Luxembourg SICAV funds with SFDR ESG characteristics (Article 8 and 9)
Aviva Investors has a wide range of sub-funds with Article 8 status as well as some Article 9 funds.
The investment process includes binding ESG characteristics (ESG screens and sector exclusions), and integration of ESG considerations and the investment manager’s transition philosophy into investment decisions.
This approach aligns with Aviva Investors’ long-standing investment philosophy and commitment to responsible investing.
For further information regarding these funds, please see the below documentation which includes the SICAV Impact Assessment Matrix and an outline of Aviva Investors’ approach to Article 9. The detailed pre-contractual information is within the prospectus and also in the website disclosure section of this webpage.
Article 9 Client Facing Summary
For further details of the Aviva Investors' approach to Article 9, please follow the below link.
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
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Fixed income
40 years of lending lessons: How four decades in real estate debt has shaped Aviva Investors’ approach
12 Dec 2024
From navigating market crashes to embracing ESG and technology, Adrian Poole and Gregor Bamert reveal how 40 years of real estate debt investing have moulded Aviva Investors’ strategy – and what it takes to stay ahead in a rapidly changing market.
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Fixed income
Buy-and-maintain credit: Taking the road to net zero
10 Dec 2024
Long-term trends like climate change are particularly important for buy-and-maintain investors. How can they integrate climate objectives, such as net zero by 2050, into their portfolios?
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Economic Research
Decarbonising transport: Five key challenges and how to overcome them
26 Nov 2024
Creating sustainable transport solutions is vital to meet net-zero pledges, but progress has been patchy. To encourage mobilisation across value chains, we brought together a range of sector experts to identify key blockers and potential solutions.
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Economic Research
Building bridges to net zero: Mobilising value chains for decarbonisation
25 Nov 2024
From aviation to heavy industry, achieving net zero requires a collective unlocking of entire ecosystems. This is what our sector roundtables aim to do, by bringing together stakeholders from across the value chain of high-impact sectors.
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Economic Research
Striking a balance: Key themes from the first eight months of 2024 AGMs
21 Oct 2024
Annual general meetings (AGMs) are an opportunity for responsible investors to share their priorities with companies and express their views on key elements of strategy and governance. Our Stewardship team reviews our 2024 AGM engagement and voting activity.
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Economic Research
Navigating nature: Opportunities for the investor of tomorrow
16 Oct 2024
Our society, economies and financial systems are embedded in nature, not external to it. This paper sets out the actions we are taking to understand nature-related risks and opportunities to deliver outcomes that meet our clients’ needs, and to support nature-related global goals.
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Economic Research
Only connect: How a holistic approach to investment stewardship can enhance client outcomes
27 Sep 2024
From direct investments and engagement with companies to dialogue with governments and regulators, we believe stewardship efforts can deliver better outcomes for clients.
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Real Assets
Get networking: Will the next decade be a golden age for UK infrastructure?
3 Sep 2024
While there are obstacles to overcome, the coming years could see new opportunities for the UK government and the private sector to work together on infrastructure projects, says Darryl Murphy.
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Economic Research
Boosting low-carbon investment in the UK: A Policy Roadmap
16 Jul 2024
Our in-depth Roadmap for the UK’s journey towards a low-carbon economy contains policy recommendations to unlock private investment in the transition.
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Responsible Investing
The future of green premia in real estate, part two: Searching for value and resilience
8 Jul 2024
Do energy-efficient buildings have more pricing power, and what could that mean for those investing in the built environment? We bring together the views of leading capital markets researchers, a valuer and an asset manager for the second part of our deep dive into green premia, analysing the investment implications.
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Responsible Investing
Avoid, reduce, remove, align: Finding climate transition investment opportunities in real assets
3 Jul 2024
In this article, Luke Layfield and Zoe Austin explain four key pillars that can help real asset investors align their strategies with the climate transition and uncover opportunities to deliver attractive returns.
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Responsible Investing
The future of green premia in real estate, part one: The view from the ground
27 Jun 2024
Do greener buildings have more pricing power, and if so, how much? We bring together the views of leading capital markets researchers, a valuer and an asset manager for a two-part deep dive on the latest market dynamics.
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Economic Research
Blueprints for a greener economy: Creating a transition planning ecosystem
25 Jun 2024
National transition plans can give investors support, confidence and direction to accelerate the flow of finance to bring about a low-carbon economy. As such, they should be seen as a strategic opportunity.
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Economic Research
Nothing to fear: Sustainable investing trade-offs
19 Jun 2024
Sustainable investing, and the supposed trade-offs involved, have been a topic of heated debate. But trade-offs are a fundamental part of all types of investment; the key is to be clear about your objectives, as Mirza Baig explains.
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Fixed income
See the wood, not just the trees: How climate-focused credit investors can help drive real-world change
14 May 2024
Green bond funds and Paris-aligned benchmarks are aimed at climate-focused credit investors who also want the simplicity of passive investing. But while they decarbonise portfolios, they exclude the companies in the real economy that need to transition if the world is to meet the Paris Agreement goals. This is why an active approach can be beneficial.
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Real Assets
Building better: Opportunities for DC schemes to invest in the climate transition through real assets
22 Mar 2024
By investing in climate-aligned real assets, defined-contribution pension schemes can help propel the transition while also benefiting from portfolio diversification and attractive risk-adjusted returns, says Mark Meiklejon.