Lobbying on Institutional investors' and asset managers' duties regarding sustainability

Institutional investors' and asset managers' duties regarding sustainability

Banking and financial services

In the context of the Commission work on sustainable finance, this initiative aims at strengthening financial stability and asset pricing by clarifying that institutional investors and investment managers have a duty to consider the materiality of sustainability factors.

Links

Public consultation

ID: 1185

Lobbying Activity

146 responses

Consultation response

WWF European Policy Programme, 23 Aug 2018

WWF European Policy Office welcomes the European Commission’s opportunity to give feedback on the proposal for a regulation on the establishment of a framework to facilitate sustainable investment. It is a positive step of the Commission, consistent with the EU Sustainable Finance Action Plan. We…

Consultation response

WWF European Policy Programme, 22 Aug 2018

WWF welcomes the European Commission’s opportunity to give feedback on proposal for a regulation on disclosures relating to sustainable investments and sustainability risks and amending Directive (EU)2016/2341. WWF welcomes the fact that the Commission is moving forward with many of the ‘key…

Consultation response

WWF European Policy Programme, 22 Aug 2018

WWF welcomes the European Commission’s opportunity to give feedback on the proposal for a regulation amending Regulation (EU) 2016/1011 on low carbon benchmarks and positive carbon impact benchmarks to create a new category of benchmarks which will provide investors with better information on the…

Consultation response

WWF European Policy Programme, 21 Jun 2018

WWF welcomes the European Commission’s opportunity to give feedback on amendments to delegated acts under the Markets in Financial Instruments Directive (MiFID II) and the Insurance Distribution Directive to include ESG considerations into the advice that investment firms and insurance distributors…

Consultation response

WWF European Policy Programme, 21 Jun 2018

Consultation response

Bundesverband der Deutschen Industrie e.V., 22 Aug 2018

The Federation of German Industries, the BDI, shares the opinion that there is a funding gap in sustainable investment. As outlined in the Action Plan for Financing Sustainable Growth, the capital markets can be stimulated to contribute to better reaching the EU’s climate and energy targets. For…

Consultation response

Deutsche Bank AG, 21 Jun 2018

Deutsche Bank response to the European Commission’s public consultation on Sustainable Finance Initiative – MiFID II suitability requirements Deutsche Bank welcomes the opportunity to provide comments on the European Commission’s initiative on Sustainable Finance and in particular the approach…

Consultation response

Eurelectric aisbl, 21 Jun 2018

Climate change should be the first priority when addressing long term sustainable development issues; therefore it is required for the financial sector to adopt a carbon neutral approach to achieve sustainable finance. Eurelectric welcome the Commission proposal that challenges the EU financial…

Consultation response

ELECTRICITE DE FRANCE, 10 Jul 2018

A LEADING ROLE FOR THE FINANCIAL SECTOR The financial sector financial must first recognize that the priority of sustainable finance is to harmonize financial flows with a pathway to lower greenhouse gases and more climate-resilient development, according to the Paris agreement and social…

Consultation response

Insurance Europe, 23 Aug 2018

Insurance Europe welcomes the opportunity to provide comments on the European Commission proposal for a regulation on disclosures relating to sustainable investments and sustainability risks. Please find enclosed the Insurance Europe position paper, which includes our general and detailed…

Consultation response

Insurance Europe, 23 Aug 2018

Insurance Europe welcomes the opportunity to provide comments on the European Commission proposal for a regulation on the establishment of a framework to facilitate sustainable investment. Please find enclosed the Insurance Europe position paper, which includes our general and detailed comments…

Consultation response

Insurance Europe, 21 Jun 2018

General comments Insurance Europe welcomes the opportunity to comment on the European Commission’s public consultation on its Sustainable Finance Initiative for the distribution of insurance-based investment products (IBIPs). Insurance Europe agrees that the existence of any customer ESG…

Consultation response

Wirtschaftskammer Österreich, 23 Aug 2018

The taxonomy has to be developed before new rules are being implemented. All relevant industries have to be involved in that process. The rules need sufficient time for implementation. An international approach is needed to avoid market distortions

Consultation response

Wirtschaftskammer Österreich, 23 Aug 2018

Financial industry urges gradual taxonomy approach before regulatory changes

Association for Financial Markets in Europe, 22 Aug 2018

AFME requests the Commission develop the taxonomy before amending other financial regulations like MiFID II. They want clarity that the taxonomy applies to economic activities rather than specific products, and seek flexibility to incorporate existing market frameworks like the Green Bond Principles. They emphasize the need for regular updates and warn against overly prescriptive requirements.

This would allow banks to avoid applying sustainability criteria across all offerings and maintain existing investment approaches.

Investors seeking broader sustainable strategies lose as narrow product scope limits diversification options.

Consultation response

Association for Financial Markets in Europe, 21 Jun 2018

The Association for Financial Markets in Europe (AFME) is the voice of all Europe’s wholesale financial markets, providing expertise across a broad range of regulatory and capital markets issues. We represent the leading global and European banks and other significant capital market…

Consultation response

Gesamtverband der Deutschen Versicherungswirtschaft e.V., 20 Jul 2018

Please see the attachment.

Consultation response

Gesamtverband der Deutschen Versicherungswirtschaft e.V., 20 Jul 2018

Please see the attachment.

Consultation response

Gesamtverband der Deutschen Versicherungswirtschaft e.V., 20 Jul 2018

Please see the attachment

Consultation response

Gesamtverband der Deutschen Versicherungswirtschaft e.V., 20 Jun 2018

The German Insurance Association (GDV) welcomes the opportunity to comment on the European Commission’s public consultation on its Sustainable Finance Initiative for the distribution of insurance-based investment products. Mandatory inclusion of ESG in the advice is not necessary Article 30(1)…

Consultation response

Finance Watch, 3 Aug 2018

Finance Watch welcomes the proposal for a Regulation on the establishment of a framework to facilitate sustainable investment. We would like to point out that the message in the recital number 28 should be further clarified. It is important for the Commission to clarify how the consideration of…

Consultation response

Finance Watch, 3 Aug 2018

Finance Watch welcomes the EC proposal for a Regulation on disclosure relating to sustainable investments and sustainability risks and amending Directive (EU) 2016/2341. Climate change is the greatest threat to the global financial stability, given its double nature as idiosyncratic and systematic…

Consultation response

Finance Watch, 3 Aug 2018

Finance Watch is glad to provide the following contribution to the public consultation on the EC proposal for a regulation amending Regulation (EU) 2016/1011 aimed at defining low carbon benchmarks and positive carbon impact benchmarks.  First and foremost, we consider that the proposed review of…

Consultation response

Finance Watch, 21 Jun 2018

The concept of “best interest” should be defined at the EU level to include both financial and non-financial benefits. In other words, we believe that it should be made clear that the utility of investors can depend on both financial and non-financial returns. This is particularly critical if we…

Consultation response

Finance Watch, 21 Jun 2018

The concept of “best interest” - as mentioned in the art. 24 (paragraph 1) of MIFID II and art. 54 of Delegated Regulation (EU) 2017/565, should be defined at the EU level to include both financial and non-financial benefits. In other words, we believe that it should be made clear that the utility…

Consultation response

International Association of Oil Gas Producers Europe, 22 Aug 2018

The International Association of Oil & Gas Producers (IOGP) is following with great interest developments in the area of sustainable finance and appreciates the opportunity to provide our input at this stage. We are convinced that the following recommendations will contribute to the establishment…

Consultation response

International Association of Oil Gas Producers Europe, 22 Aug 2018

Consultation response

International Association of Oil Gas Producers Europe, 22 Aug 2018

Consultation response

Invest Europe, 11 Dec 2017

Invest Europe supports the Commission’s (EC) work to ensure that material sustainability factors are assessed, consistently taken into account and disclosed by institutional investors and asset managers. However, it is crucial that an accepted definition of “sustainability” (eg Brundtland report)…

Consultation response

Associazione Bancaria Italiana, 21 Jun 2018

Please find enclosed ABI’s remarks on the EUROPEAN COMMISSION on the Draft Delegated Regulation amending Regulation (EU) 2017/565 supplementing Directive 2014/65/EU as regards organisational requirements and operating conditions for investment firms and defined terms for the purposes of that…

Consultation response

NASDAQ, 10 Aug 2018

Please see attached document.

Consultation response

NASDAQ, 10 Aug 2018

Please see attached document.

Consultation response

Asociación Española de Banca, 21 Jun 2018

See the attached document

Consultation response

London Stock Exchange Group, 22 Aug 2018

· We support the Commission’s view that sustainability and the transition to a low carbon economy is key to ensuring the long term competitiveness of the EU economy. · LSEG is a thought leader in sustainable finance working closely with issuers and investors as a market infrastructure…

Consultation response

Finance Denmark, 21 Jun 2018

Finance Denmark strongly supports the proposals of sustainable finance and we think The European Commission’s proposals overall are a positive step towards a sustainable economy. The Commission´s initiative is an important part of the steps to achieve the necessary funding for the transition to a…

Consultation response

Federation of European Securities Exchanges, 22 Aug 2018

FESE members organise markets dedicated to sustainable finance and offer products that contribute to sustainable development, facilitate management of climate risk and incorporate carbon reduction in investment strategies, as well as allow the tracking of sustainable companies’ performance.…

Consultation response

Federation of European Securities Exchanges, 22 Aug 2018

Consultation response

Insurance Ireland, 21 Jun 2018

Feedback set out in PDF

ICI Global Demands Sequencing EU Taxonomy Before New Disclosure Rules

Investment Company Institute, 23 Aug 2018

The organization recommends completing the EU sustainability taxonomy before implementing disclosure rules and extending implementation to 24 months. They also request more detail in primary legislation to avoid market uncertainty.

Coordinated implementation reduces compliance risks and avoids an inconsistent patchwork of legislative requirements.

Non-EU investors may lose interest in European funds if mandatory sustainability rules ignore their preferences.

Consultation response

AMUNDI AM, 27 Jul 2018

(1) Amundi agrees that we need to have, at least at the EU level, a common language and understanding of what sustainable investment means. Otherwise national regulators may develop various approaches using different concepts and priorities that would make it impossible for investors to understand…

Consultation response

AMUNDI AM, 27 Jul 2018

(1) In Amundi’s view, the more general aim of introducing ESG references in Benchmarks Regulation (BMR) should appear in the title of the proposed regulation. We suggest the : “…amending Regulation (EU) 2016/11 on low carbon benchmarks, positive carbon impact benchmarks and disclosure by…

Consultation response

AMUNDI AM, 21 Jun 2018

Sustainable finance is a clear priority within Amundi. Amundi offers a large range of funds incorporating ESG criteria, with a particular focus on Environmental factors and low carbon portfolios. For example Amundi founded with EDF a management company, Amundi energy transition, dedicated to…

Consultation response

BVI Bundesverband Investment und Asset Management e.V., 23 Aug 2018

Encouraging investments in sustainable products is a core element in the strive towards a more sustainable environment. Therefore, BVI is supportive of the European Commission’s Action Plan and the legislative proposals on Financing Sustainable Growth. A coherent disclosure how market participants…

Consultation response

BVI Bundesverband Investment und Asset Management e.V., 23 Aug 2018

Encouraging investments in sustainable products is a core element in the strive towards a more sustainable environment. BVI therefore welcomes the European Commission’s Action Plan and in particular the aim to build a classification for sustainability (“Taxonomy”). A common language and disclosure…

Consultation response

BVI Bundesverband Investment und Asset Management e.V., 22 Aug 2018

Encouraging investments in sustainable products is a core element in the strive towards a more sustainable environment. BVI (BVI represents the interests of the German fund industry at national and international level. The association promotes sensible regulation of the fund business as well as…

Consultation response

BVI Bundesverband Investment und Asset Management e.V., 21 Jun 2018

Encouraging investments in sustainable products is a core element to move towards a more sustaina-ble environment. BVI (BVI represents the interests of the German fund industry at national and international level. The association promotes sensible regulation of the fund business as well as fair…

Consultation response

BVI Bundesverband Investment und Asset Management e.V., 11 Dec 2017

BVI’s view on responsible investment Responsible and long-term considerations play an increasingly important role in investment decisions. Many investors feel a responsibility to address environmental, social and governance (ESG) issues by being more selective in their investments. The asset…

Consultation response

Association Française de la Gestion financière, 22 Aug 2018

AFG decided very early on to fully support the development of responsible investment in France. French asset management companies are fully committed to this approach and are adapting their offering to the concerns of their institutional and private investors by proposing products that entail…

Consultation response

Association Française de la Gestion financière, 22 Aug 2018

Consultation response

Association Française de la Gestion financière, 20 Aug 2018

The French Asset Management Association (Association Française de la Gestion financière, AFG) is grateful for the opportunity to comment on the Commission’s proposal for a Regulation amending regulation (EU) 2016/20111 (hereinafter the ‘BMR’). Our members wish to draw the attention of the…

Consultation response

Association Française de la Gestion financière, 21 Jun 2018

Consultation response

European Association of Co-operative Banks, 21 Jun 2018

The European Association of Co-operative Banks (EACB) is closely following the European Commission work on sustainable finance as this is a very important workstream for the EACB members due to the fact that co-operative banks, being local and regional banks, play a key role in sustainable…

Consultation response

Norsk Hydro, 23 Aug 2018

Norsk Hydro welcomes the initiatives and legislative proposals aimed at a more coordinated approach to ESG factors in the finance sector. More transparency and harmonization of sustainability evaluations in investments can be a contributor for driving the EU towards a low-carbon economy. Norsk…

Consultation response

Fairshare Educational Foundation (ShareAction), 21 Jun 2018

"ESG preferences” should be amended clarify both the financial and non-financial nature of ESG preferences. Confusion around this terminology abounds, and we recommend a recognition that ESG preferences may be financially material, or may have no/negative financial impact on the risk profile of…

Consultation response

European Fund and Asset Management Association, 23 Aug 2018

Please find attached EFAMA's feedback. EFAMA is the representative association for the European investment management industry. EFAMA represents through its 28 member associations and 62 corporate members close to EUR 23 trillion in assets under management of which EUR 15.6 trillion managed by…

Consultation response

European Fund and Asset Management Association, 22 Aug 2018

Consultation response

European Fund and Asset Management Association, 21 Aug 2018

Please find attached our feedback. EFAMA is the representative association for the European investment management industry. EFAMA represents through its 28 member associations and 62 corporate members close to EUR 23 trillion in assets under management of which EUR 15.6 trillion managed by more…

Consultation response

European Fund and Asset Management Association, 20 Jun 2018

Please see our feedback attached. EFAMA is the representative association for the European investment management industry. EFAMA represents through its 28 member associations and 62 corporate members close to EUR 23 trillion in assets under management of which EUR 14.1 trillion managed by 58,400…

Consultation response

European Fund and Asset Management Association, 11 Dec 2017

We agree that the European asset management industry has a role to play in contributing to the sustainability agenda. We see this role in 3 distinctive parts: • First, the asset management industry provides its clients, institutional investors and other asset owners, investment solutions that…

European retail banks urge clear criteria for sustainable investments

European Savings and Retail Banking Group, 23 Aug 2018

First, establish a clear, binding definition for what constitutes a sustainable investment. Avoid creating new laws by instead supplementing existing sectoral financial regulations. The general application date should be extended from 12 to 24 months.

This approach would reduce legal liability risks and lower technical implementation costs.

Individual investors face confusing information floods that delay advisory and order processes.

ESBG warns against premature sustainability rules for retail banks

European Savings and Retail Banking Group, 21 Jun 2018

ESBG recommends developing a complete taxonomy before implementing concrete regulatory measures. They urge the Commission to avoid putting the industry under unnecessary pressure. Sustainability preferences should not be prioritized over other client investment objectives.

Banks would avoid the high costs of modifying existing investment advice processes.

Potential investors may have fewer sustainable options as banks limit their offerings.

Consultation response

European Federation of Investors and Financial Services Users, 23 Aug 2018

BETTER FINANCE welcomes this opportunity to comment on the European Commission proposal on the establishment of a framework to facilitate sustainable investment. EU citizens as savers and individual investors are the main provider of long term funding to the EU economy and are mostly by nature…

Consultation response

European Federation of Investors and Financial Services Users, 23 Aug 2018

BETTER FINANCE welcomes this opportunity to comment on the European Commission’s regulation proposal on disclosure relating to sustainable investment and sustainability risks (amending Directive (EU) 2016/2341). EU citizens as savers and individual investors are the main provider of long term…

Consultation response

European Federation of Investors and Financial Services Users, 22 Aug 2018

BETTER FINANCE welcomes this opportunity to comment on the Commission proposal on low carbon benchmarks and positive carbon impact benchmarks released as part of the Sustainable Finance Action Plan of the European Commission. EU citizens as savers and individual investors are the main provider…

Consultation response

European Federation of Investors and Financial Services Users, 21 Jun 2018

BETTER FINANCE welcomes this opportunity to comment on the proposal amending Delegated Regulation (EU) 2017/565 supplementing MiFID II as regards organizational requirements and operating conditions for investment firms and defined terms for the purpose of that directive. Investment firms shall…

Consultation response

European Federation of Investors and Financial Services Users, 21 Jun 2018

BETTER FINANCE welcomes this opportunity to comment on the proposal amending Delegated Regulation (EU) 2017/2359 to include the customer’s ESG preferences in the criteria and practical details to be taken into account by insurance intermediaries and insurance undertakings when assessing the…

Consultation response

European Federation of Investors and Financial Services Users, 11 Dec 2017

BETTER FINANCE welcomes this impact assessment aiming at ensuring that material sustainability factors are consistently taken into account and disclosed by institutional investors and asset managers. BETTER FINANCE agrees with the European Commission on the fact that increasing the transparency of…

Consultation response

Managed Funds Association, 21 Jun 2018

Managed Funds Association (“MFA”) welcomes the opportunity to provide comments to the European Commission (the “Commission”) on its proposal for a delegated regulation as regards organisational requirements and operating conditions for investment firms (the “Draft Delegated Regulation”). MFA…

Consultation response

Nederlandse Vereniging van Banken / Dutch Banking Association, 21 Jun 2018

The Dutch Banking Association (Nederlandse Vereniging van Banken, or ‘NVB’) welcomes the opportunity to comment on the amendments to MiFID II delegated act, which is part of the Commission proposals on financing sustainable growth (‘Commissions package’). In essence, the NVB endorses the…

Consultation response

The Alternative Investment Management Association Limited, 21 Jun 2018

The Alternative Investment Management Association Limited (AIMA) welcomes the opportunity to respond to the proposal for a delegated regulation amending Regulation (EU) 2017/565 (‘MiFIR’) supplementing Directive 2014/65/EU (‘MiFID II’) as regards organisational requirements and operating…

Consultation response

Institutional Investors Group on Climate Change, 21 Aug 2018

See attached document for full policy position. In summary, in its core recommendations IIGCC urges the EU to: 1. Set out a clear, long-term policy framework for the real economy – encompassing energy, transport and industry – backed up by concrete targets and objectives, as a priority issue, to…

PKEE: Sustainable finance rules must recognize national energy realities

Polish Electricity Association, 7 Aug 2018

The PKEE requests that sustainability criteria consider individual national energy profiles. They advocate for including low-emission gas capacities in the green classification. They also suggest prioritizing large-scale renewable projects for their higher efficiency.

The sector would avoid higher financing costs associated with investments being labeled unsustainable.

Small-scale green energy projects could face a disadvantage compared to large-scale infrastructure.

Consultation response

Enagás S.A., 20 Aug 2018

Enagás welcomes this Commission’s initiative and its invitation to provide our opinion on the proposal for a Regulation of the European Parliament and of the Council amending Regulation (EU) 2016/1011 on low carbon benchmarks and positive carbon impact benchmarks. In general Enagás supports the…

Consultation response

Aviva Plc, 10 Aug 2018

Please see PDF attached.

Consultation response

Aviva Plc, 10 Aug 2018

Please see PDF attached.

Consultation response

Aviva Plc, 21 Jun 2018

Feedback is in PDF attached.

Consultation response

Aviva Plc, 21 Jun 2018

Feedback is in the pdf attached.

Consultation response

Association Luxembourgeoise des Fonds d'Investissement, 21 Aug 2018

ALFI has been at the forefront of actively promoting sustainable finance opportunities for asset managers. ‘Responsible Investing’ is a major pillar of the Luxembourg investment fund industry and ALFI firmly believes that asset managers can play a key role in this area. Market growth has…

Consultation response

Association Luxembourgeoise des Fonds d'Investissement, 21 Aug 2018

Consultation response

Fédération Française de l'Assurance, 16 Aug 2018

Please find the PDF attached

Consultation response

Fédération Française de l'Assurance, 16 Aug 2018

Please find the PDF attached

Consultation response

Fédération Française de l'Assurance, 16 Aug 2018

Please find the PDF attached

Consultation response

Swedbank AB (publ), 19 Jul 2018

Please see the attached file for Swedbank's comments on the key themes relevant to the Commission proposal. Swedbank welcomes the Commission’s proposal for a regulation on the establishment of a framework to facilitate sustainable investment and sees that such a framework could create a solid…

Consultation response

Unipol Assicurazioni S.p.A:, 21 Jun 2018

Please see the pdf attached for the Unipol Group's contribution.

Consultation response

Unipol Assicurazioni S.p.A:, 21 Jun 2018

Please see the pdf attached for the Unipol Group's contribution.

Consultation response

Association Luxembourgeoise des Fonds d'Investissement, 11 Dec 2017

Introduction The Association of the Luxembourg Fund Industry (ALFI) is the representative body of the Luxembourg investment fund community. Created in 1988, the Association today represents over 1,400 Luxembourg domiciled investment funds, asset management companies and a wide range of service…

Consultation response

OMV Aktiengesellschaft, 21 Aug 2018

On 24 May 2018, the European Commission presented a package of measures as a follow-up to its Action Plan on financing sustainable growth. OMV appreciates the opportunity to comment on the proposals. This is a first assessment of these proposals, which will have to be discussed extensively in the…

Consultation response

OMV Aktiengesellschaft, 21 Aug 2018

Consultation response

OMV Aktiengesellschaft, 21 Aug 2018

OMV key-priorities for EC consultation on the Sustainable Finance Initiative On 24 May 2018, the European Commission presented a package of measures as a follow-up to its Action Plan on financing sustainable growth. OMV appreciates the opportunity to comment on the proposals. This is a…

Consultation response

The Investment Association, 23 Aug 2018

The Investment Association (“the IA”) welcomes the opportunity to respond to the European Commission’s proposed Sustainable Finance Package, which is of key importance in the promotion and development of sustainable finance throughout Europe and across the globe. The IA represents 250 UK-based…

Consultation response

The Investment Association, 23 Aug 2018

The Investment Association (“the IA”) welcomes the opportunity to respond to the European Commission’s proposed Sustainable Finance Package, which will be of key importance in the promotion and development of sustainable finance throughout Europe and across the globe. The IA represents 250…

Consultation response

The Investment Association, 21 Jun 2018

The Investment Association (IA) thanks the Commission for the opportunity to comment on proposed changes to the MiFID II Suitability Assessment. Asset managers are increasingly seeking to integrate an assessment of environmental, social and governance (ESG) factors in their investment process…

Consultation response

Principles for Responsible Investment, 22 Aug 2018

TAXONOMY The PRI welcomes the proposal to establish a framework to facilitate sustainable investment. We believe the taxonomy will create additional demand for and supply of sustainable financial products by simplifying, and as such, enabling, the investment of private capital in economic…

Consultation response

Principles for Responsible Investment, 22 Aug 2018

REGULATION ON DUTIES AND DISCLOSURES RELATING TO SUSTAINABLE INVESTMENTS The PRI considers the Commission’s Investor Duties and Disclosures proposal (2016/2341) critical for the success of its sustainability objectives. We agree that it “lays the foundation for an EU framework which puts ESG…

Consultation response

Principles for Responsible Investment, 22 Aug 2018

The PRI is a membership organisation of over 2000 global institutional investors, (including insurers, investment managers and advisors) with approximately US $82 trillion in assets under management. Over 1000 of these signatories are based in the Europe. The PRI strongly supports all four of…

Consultation response

Principles for Responsible Investment, 21 Jun 2018

The Principles for Responsible Investment (PRI) believes that dialogue between investors and clients on ESG interests and preferences is a necessary to a sustainable financial system and we welcome policy initiatives to encourage this dialogue. The PRI has traditionally focussed on ESG in…

Schroders Urges Integrated ESG Definitions to Protect Choice

Schroders Investment Management (Europe) SA, 21 Jun 2018

Schroders argues for an integrated approach to ESG factors instead of separating them into individual silos. They request adding "where relevant" to requirements to ensure they only apply when pertinent to investment advice. They also propose broadening the definition of good governance.

Broadening definitions prevents Schroders from being forced into restrictive, narrowly defined investment categories.

Providers of specialized thematic funds may face competition from mainstream funds using broader definitions.

Consultation response

Federatie Nederlandse Vakbeweging, 23 Aug 2018

The text mentions that there should be a minimal compliance with social and governance norms. The eight basic principles of the ILO are included in article 13 and this is positive. Governance standards should include the fiscal responsibility – i.e.: responsible tax practices - of the issuers which…

Consultation response

Federatie Nederlandse Vakbeweging, 23 Aug 2018

We believe that it would be of interest to link the platform to monitor and exchange good practices on the application of the SDGs created by the EC with the good practices of socially responsible investors who follow the SDGs (pension funds, etc.). For finance to contribute to sustainable and…

Consultation response

Die Deutsche Kreditwirtschaft, 23 Aug 2018

The German Banking Industry Committee (GBIC) would like to give feedback on the proposal for a regulation on the establishment of a framework to facilitate sustainable investment. Please see the PDF attached.

Consultation response

Die Deutsche Kreditwirtschaft, 22 Aug 2018

The GBIC welcomes the opportunity to comment on the European Commission's legislative proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL amending Regulation (EU) 2016/1011 on low carbon benchmarks and positive carbon impact benchmarks as regards organisational requirements and…

Consultation response

Die Deutsche Kreditwirtschaft, 21 Jun 2018

The German Banking Industry Committee (GBIC) welcomes the opportunity to comment on the European Commission's legislative proposal for amending Regulation (EU) 2017/565 supplementing Directive 2014/65/EU of the European Parliament and of the Council as regards organisational requirements and…

Consultation response

Association Française des Marchés Financiers, 9 Aug 2018

Association française des marchés financiers (AMAFI) is the trade organisation working at national, European and international levels to represent financial market participants in France. It mainly acts on behalf of credit institutions, investment firms and trading and post-trade infrastructures,…

Consultation response

Association Française des Marchés Financiers, 20 Jun 2018

AMAFI welcomes the opportunity to give feedbacks on European Commission proposed amendments to delegated acts under MiFID 2 to include ESG considerations into Suitability requirements. Indeed, AMAFI pays particular attention to the development of ESG criteria in the financial markets and welcomes…

Consultation response

European Association of Paritarian Institutions of Social Protection, 23 Aug 2018

AEIP supports a balanced approach between the disclosure obligations of market participants and the objectives of the EC Proposal for a Regulation on disclosures relating to sustainable investments Paritarian funds are natural long-term investors, due to the match between the long duration of…

Consultation response

European Association of Paritarian Institutions of Social Protection, 23 Aug 2018

Sustainable finance is the cornerstone for the success of the Capital Markets Union. The European Association of Paritarian Institutions embraces the EC action and legislative proposals to facilitate sustainable investments and the new standards for an EU green bond. Paritarian funds invest with…

Consultation response

Nordic Securities Association, 22 Aug 2018

Taxonomy: The Nordic Securities Association (NSA) supports the European Commission’s objective to integrate sustainability targets into the European financial markets. The aim of creating an EU taxonomy is to help investors to direct their investments towards economic activities which contribute…

Consultation response

Nordic Securities Association, 21 Jun 2018

The Nordic Securities Association (NSA) supports the European Commission's (EC) sustainable finance agenda. We regret the short period of time allowed to give feedback to this draft delegated act, despite its substantial impact on companies' investment advisory processes. Providing clients with…

Consultation response

Nordic Financial Unions, 19 Jun 2018

Nordic Financial Unions (NFU) supports the Commission’s aim of including ESG considerations in the advisory process under IDD (Directive EU/2016/97 and Delegated Regulation EU/2017/2359), both in the customer profiling and product selection. NFU believes that finance employees are key levers to…

Consultation response

Nordic Financial Unions, 19 Jun 2018

Nordic Financial Unions (NFU) supports the Commission’s aim of including ESG considerations in the investment and advisory process under Mifid II, as part of the duties towards clients. NFU believes that finance employees are key levers to facilitate the transition to green finance. It is…

Consultation response

EUROSIF A.I.S.B.L (EUROPEAN SUSTAINABLE INVESTMENT FORUM), 14 Aug 2018

• Reformulating Indices is of capital importance in a financial system where the 'benchmark' is the investment reference. Therefore embedding 'ESG considerations in benchmark methodologies could do much to fast-forward towards mobilising the climate investment required to meet the Paris…

Consultation response

EUROSIF A.I.S.B.L (EUROPEAN SUSTAINABLE INVESTMENT FORUM), 21 Jun 2018

Demanding the inclusion of ESG considerations in the provision of investment advice, represents an important step in the sustainable finance equation. If well defined, the recommended delegated acts amendments can truly unlock the growth potential of sustainable finance. But, in order to maximise…

Consultation response

EUROSIF A.I.S.B.L (EUROPEAN SUSTAINABLE INVESTMENT FORUM), 21 Jun 2018

Demanding the inclusion of ESG preferences in Distribution of insurance-based investment products, could further contribute to the mainstreaming of sustainable and responsible investment for retail clients. This initiative will certainly increase the level of involvement in sustainability of…

Consultation response

CDP Worldwide (Europe) gemeinnützige GmbH, 23 Aug 2018

Please see attached file with CDP Europe's feedback. CDP Europe is a subsidiary and part of CDP Worldwide, an international non-profit that drives companies and governments to reduce their greenhouse gas emissions, safeguard water resources and protect forests. Voted number one climate research…

Consultation response

CDP Worldwide (Europe) gemeinnützige GmbH, 21 Jun 2018

Please see attached file for CDP Europe's feedback. CDP Europe is a subsidiary and part of CDP Worldwide, an international non-profit that drives companies and governments to reduce their greenhouse gas emissions, safeguard water resources and protect forests. Voted number one climate research…

Consultation response

CDP Worldwide (Europe) gemeinnützige GmbH, 21 Jun 2018

Consultation response

Triodos Bank, 20 Jun 2018

We sincerely support the Commission’s initiative to consult upon possible amendments to Regulation 2017/565 resp. Reg. 2017/2359. We appreciate the scope of the amendments, i.e. all investments and all investors. This will enable true choices between sustainable and non-sustainable causes. The…

Consultation response

Federated Hermes Limited, 21 Jun 2018

Hermes MIFID II consultation response It is a long-held belief of Hermes Investment Management that the environmental and social impacts of investments cannot be considered separately to financial considerations - since these impacts will fundamentally affect the conditions into which Hermes’…

Consultation response

Wildlife Conservation Society, 19 Jun 2018

Recommend bringing Article 11 into line with best or good practice for financial investment and development projects by aligning with International Finance Corporation Performance Standard 6 and its Guidance Notes, the Equator Principles and the World Bank Environmental and Social Safeguard 6.…

Consultation response

Asociación de Instituciones de Inversión Colectiva y Fondos de Pensiones, 31 Jul 2018

In INVERCO´s view, the purpose of these proposals is valued very positively, since to the extent that the capital flows are directed more easily towards activities that positively impact on the fulfillment of environmental, social and governance objectives, the recipients of said financing will…

Consultation response

Asociación de Instituciones de Inversión Colectiva y Fondos de Pensiones, 31 Jul 2018

Consultation response

Asociación de Instituciones de Inversión Colectiva y Fondos de Pensiones, 31 Jul 2018

The purpose of these proposals is valued very positively, since to the extent that the capital flows are directed more easily towards activities that positively impact on the fulfillment of environmental, social and governance objectives, the recipients of said financing will conduct their model of…

Consultation response

Asociación de Instituciones de Inversión Colectiva y Fondos de Pensiones, 11 Dec 2017

INVERCO supports the need to improve undertakings' disclosure of social and environmental information, as well as, developing positions towards considering ESG aspects and integrate them on a voluntarily basis in their asset allocation decisions. Nevertheless, “comply or explain” should be the…

Consultation response

Personal Investment Management & Financial Advice Association, 22 Aug 2018

Please see PIMFA's submission in the attached pdf

Consultation response

Personal Investment Management & Financial Advice Association, 22 Aug 2018

Please see PIMFA's submission in the attached pdf.

Consultation response

Personal Investment Management & Financial Advice Association, 15 Jun 2018

With reference to the Sustainable Finance Initiative - MiFID II suitability requirements, please find attached the response from the Personal Investment Management and Financial Advice Association (PIMFA), the trade association for firms that provide investment management and financial advice to…

Consultation response

Kommuninvest i Sverige AB, 12 Jun 2018

I provide these comments as Head of Sustainability for Kommuninvest, Sweden's largest issuer of green bonds. Kommuninvest proposest that Article 9.1 (i): “ avoiding incineration and disposal of waste” (see Chapter II - Environmentally sustainable economic activities) is amended, to read: ”…

Consultation response

Fédération Européenne des Conseils et Intermédiaires Financiers, 21 Aug 2018

FECIF agrees with the general aim of this proposal, i.e. the integration of ESG in disclosures to end-investors. In particular, we appreciate the integration of sustainability risks and sustainable investment objectives both in the decision-making processes by institutional investors and asset…

Consultation response

Forum pour l'Investissement Responsable - French SIF, 21 Jun 2018

Le FIR - French SIF soutient pleinement l’idée de permettre l’engagement des épargnants en les questionnant sur leur préférence environnementale, sociale, sociétale et de bonne gouvernance. Afin de répondre à leurs aspirations, les épargnants français peuvent choisir des produits labellisés…

Consultation response

2° Investing Initiative, 21 Jun 2018

For our feedback please see the attached file.

Consultation response

2° Investing Initiative, 21 Jun 2018

For our feedback please see the attached file.

Consultation response

Fédération Européenne des Conseils et Intermédiaires Financiers, 18 Jun 2018

FECIF appreciates the publication of the Action Plan on Financing Sustainable Growth. We agree with the proposal aimed at amending the delegated act under IDD to ensure that sustainability considerations are taken into account in the advisory process, both in the customer profiling and subsequent…

Consultation response

Fédération Européenne des Conseils et Intermédiaires Financiers, 18 Jun 2018

FECIF appreciates the publication of the Action Plan on Financing Sustainable Growth. We agree with the proposal aimed at amending the delegated act under MiFID II to ensure that sustainability considerations are taken into account in the advisory process, both in the customer profiling and…

Consultation response

Eumedion, 21 Aug 2018

Eumedion´s response to the proposal for a regulation on the establishment of a framework to facilitate sustainable investment (COM(2018) 353 final) Eumedion, representing the interests of 65 Dutch and non-Dutch institutional investors who have more than € 5 trillion assets under management, is…

Consultation response

Eumedion, 21 Aug 2018

Please find the PDF attached.

Consultation response

Eumedion, 21 Aug 2018

Please find the PDF attached.

Consultation response

aba Arbeitsgemeinschaft für betriebliche Altersversorgung e.V., 21 Aug 2018

The aba (Arbeitsgemeinschaft für betriebliche Altersversorgung e.V., German Association for Occupational Pensions) is the German association for all matters regarding supplementary pensions. Please find our comments on the Commission’s Proposal for a Regulation on disclosures relating to…

Consultation response

Österreichischer Verband Financial Planners, 21 Aug 2018

Österreichischer Verband Financial Planners is pleased to comment on the proposed Regulation on disclosures relating to sustainable investments and sustainability risks COM (2018) 354 final. Please find our considerations in the attached document.

Consultation response

Österreichischer Verband Financial Planners, 21 Aug 2018

Österreichischer Verband Financial Planners is pleased to comment on the proposed Regulation on the establishment of a framework to facilitate sustainable investment COM (2018) 353 final. Please find our considerations in the attached document.

Consultation response

, 27 Jul 2018

Please find below the general comments of Amundi and read the attached document for further detail. (1) The application date of the proposed regulation is foreseen 1 year after the date of publication in the OJ. But some RTS and delegated acts are due to be drafted by ESAs within 18 months of…

Consultation response

UK Sustainable Investment and Finance Association, 21 Jun 2018

UKSIF supports the EC Action Plan and the intention behind this legislation. We have consistently called for clients’ sustainability preferences to be discussed in the suitability assessment and this has the full support of our members including over 50 financial advisers specialising in ESG.…

Consultation response

Forum Nachhaltige Geldanlagen, 21 Jun 2018

With reference to the additional input of our umbrella organisation Eurosif the Forum Nachhaltige Geldanlagen (FNG) is pleased to submit its input. FNG welcomes the mandatory integration and documentation of customer preferences on sustainability and their implementation in the client advisory…

Consultation response

BIPAR - European Federation of Insurance Intermediaries, 20 Jun 2018

Following the European Commission’s Action Plan for Sustainable Growth launched in March 2018 and the HLEG recommendations in January 2018, BIPAR welcomes the opportunity provided by the European Commission to comment on its proposed Delegated Regulation amending Regulation (EU) 2017/565…

Consultation response

BIPAR - European Federation of Insurance Intermediaries, 20 Jun 2018

BIPAR welcomes the opportunity provided by the European Commission to comment on its proposed Delegated Regulation amending Delegated Regulation (EU) 2017/2359 with regard to environmental, social and governance (ESG) preferences in the distribution of insurance-based investment products, following…

Consultation response

SRI Consultants Ltd T/A sriServices, 20 Jun 2018

SRI Services is devoted to advancing retail (individual investor) Sustainable and Responsible Investment (SRI). This includes offering a free online fund tool www.FundEcoMarket.co.uk designed to help financial services intermediaries meet their clients SRI/ESG needs. SRI Services is run by Julia…

Consultation response

Conselho Empresarial para o Desenvolvimento Sustentável, 11 Dec 2017

Conselho Empresarial para o Desenvolvimento Sustentável (BCSD Portugal) welcomes the initiative “Institutional investors’ and asset managers’ duties regarding sustainability” and the opportunity given to stakeholders to comment on the Inception Impact Assessment. The European Union (EU) has…