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Integration of sustainability risks and factors for undertakings for collective investment in transferable securities

Banking and financial services

In the Action Plan on Sustainable Finance the Commission expressed intention to clarify fiduciary duties and increase transparency in the field of sustainability risks and sustainable investment opportunities with the aim to - reorient capital flows towards sustainable investment; - degradation and social issues; and - foster transparency and long-termism in financial and economic activity.

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Public consultation

ID: 11959

Lobbying Activity

17 responses

Consultation response

WWF European Policy Programme, 6 Jul 2020

As mentioned in several NGO briefings on the next steps for the Sustainable Finance Action Plan, completing Action 7 ‘Clarifying institutional investors’ and asset managers’ duties still requires significant improvements, in particular on the following three issues: • It is necessary to develop an…

ICI Global urges EU to drop adverse impact rules

Investment Company Institute, 6 Jul 2020

ICI Global urges the Commission to remove requirements regarding adverse sustainability impacts. They also oppose changes to organizational, risk management, and senior management rules.
This avoids new reporting burdens and potential conflicts with legal duties to clients.
Environmental groups lose transparency regarding the negative societal effects of investment decisions.

Consultation response

BVI Bundesverband Investment und Asset Management e.V., 3 Jul 2020

In order to create an enabling environment, it is essential to keep the right balance in terms of regulation and to achieve consistency in terms of both outcomes and timing. Against this background, we have the following requests with regard to the proposed Level 2 measures for UCITS and AIFM: 1.…

Consultation response

European Association of Co-operative Banks, 6 Jul 2020

The EACB welcomes the opportunity to provide its feedback on the draft delegated acts to MiFID II, UCITS Directive, AIFMD, and IDD stemming from the goals of the European Commission’s ‘Action Plan: Financing Sustainable Growth’ to (i) integrate sustainability within investment advice (Action 4);…

Consultation response

Association Française de la Gestion financière, 6 Jul 2020

Please find attached a detailed document regarding the following positions. The French Asset Management Association (Association Française de la Gestion financière, AFG) welcomes the opportunity to share views on the EC draft Delegated Acts on the obligation for mutual funds and alternative…

Consultation response

Fairshare Educational Foundation (ShareAction), 6 Jul 2020

ShareAction welcomes the provisions introduced by this Delegated Directive to clarify requirements for management companies to better integrate sustainability risks and factors, by amending Directive 2010/43/EU that implements the UCITS Directive. The integrations set out in art. 1(4) and 1(5) to…

Consultation response

European Fund and Asset Management Association, 6 Jul 2020

EFAMA welcomes the opportunity to share views on the EC draft Delegated Acts on the obligation for mutual funds and alternative investment funds to advise clients on social and environmental aspects. Since the outset, EFAMA has been a strong supporter of creating a solid framework for sustainable…

Consultation response

The Alternative Investment Management Association Limited, 6 Jul 2020

AIMA and MFA have been actively engaging on the topic of sustainable finance with the European Commission and European policy-makers to contribute to the development of an effective and impactful sustainable finance environment. Our engagement seeks to ensure that investors and market players have…

Consultation response

International Capital Market Association, 6 Jul 2020

The Asset Management and Investors Council of ICMA supports the integration of sustainability risks among other risks to be considered by fund managers (i.e. risk management policy under article 38 of the Commission Directive 2010/43/EU) but is opposed to other amendments singling out…

Consultation response

Association Luxembourgeoise des Fonds d'Investissement, 6 Jul 2020

The Association of the Luxembourg Fund Industry (ALFI) represents the face and voice of the Luxembourg asset management and investment fund community. Created in 1988, the Association today represents over 1,500 Luxembourg domiciled investment funds, asset management companies and a wide range of…

Consultation response

The Investment Association, 6 Jul 2020

Overarching Comment: As investment managers, we seek to deliver on our clients’ investment goals, including the generation of long-term sustainable returns and, where appropriate to the investor, allocation of capital to investment strategies with environmental or social characteristics or in the…

Consultation response

Principles for Responsible Investment, 6 Jul 2020

The proposed amendments to the delegated acts underpinning UCITS state that sustainability risks should be considered in risk management, conflict of interest and governance. However, they do not directly address the need to integrate sustainability risks when determining how to act in the best…

Schroders seeks alignment of investment rules with sustainability disclosures

Schroders Investment Management (Europe) SA, 6 Jul 2020

The firm requests aligning the directive with existing disclosure regulations, focusing on materiality. They advocate for qualitative reports until standardized data is available.
This prevents conflicts with legal duties and avoids reliance on low-quality information.
Groups seeking immediate transparency lose access to hard numbers regarding environmental impacts.

Consultation response

Invesco Management SA, 6 Jul 2020

Invesco is committed to the integration of financially material ESG factors (hereafter referred to as sustainability risks integration) into its investment decision-making, a journey we have been on as a business for over 20 years. Views on what constitutes a financially material ESG factor and…

Consultation response

Irish Funds Industry Association CLG, 6 Jul 2020

We broadly welcome the draft Delegated Act on integrating sustainability risks and factors into the UCITS Directive and in particular the fact that the general principles-based approach has been maintained. We note that the revised text is broadly aligned with ESMA’s technical advice. As the…

Consultation response

Novamont SpA, 3 Jul 2020

Novamont welcomes the EU’s action plan on sustainable finance. To further improve the initiative we recommend to address, within the activities that provide genuine long-term benefits for society, those that allow to protect and restore natural resources from a systemic perspective. The use of…

Consultation response

Dutch Fund and Asset Management Association, 3 Jul 2020

The Dutch Fund and Asset Management Association (DUFAS) welcomes the opportunity to respond to the draft amendments of the UCITS and AIFMD Delegated Acts. Please find enclosed our full response, where we have consolidated our comments to the proposed amendments regarding UCITS and AIFMD in one…