OpenLobby.EU
Explore

Integration of sustainability risks and factors related to alternative investment fund managers

Banking and financial services

In the Action Plan 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; -assess and manage relevant financial risks stemming from climate change, resource depletion, environmental degradation and social issues; and -foster transparency and long-termism in financial and economic activity.

Links

Public consultation

ID: 11960

Lobbying Activity

16 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’ More is definitely needed in these three aspects: • It is necessary to develop an overarching vision for what these…

Consultation response

Invest Europe, 6 Jul 2020

Invest Europe welcomes the Commission’s principles-based, non-prescriptive approach. Allowing for a level of discretion is key to strike a proper balance between the need for harmonisation and the need for flexibility, as such avoiding imposing unnecessary, additional burden on AIFMs, in particular…

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

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) but is opposed to other amendments singling out sustainability risks in several general articles. We believe the…

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…

Schroders urges alignment and flexibility in sustainability reporting

Schroders Investment Management (Europe) SA, 6 Jul 2020

Schroders wants the rules to follow principles of materiality and proportionality. They request permission to use qualitative descriptions instead of numbers due to a lack of reliable data.
These changes would lower compliance costs and prevent conflicts with their fiduciary duties to clients.
Investors and watchdogs might receive less precise, non-standardized information about environmental and social 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 AIFMD 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 industry…

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

Associação Portuguesa para a Defesa do Consumidor, 6 Jul 2020

DECO – the Portuguese Consumer protection Association, welcomes and supports the amendments proposed. These measures are necessary in order to foster the implementation of the Green Deal, the promotion of sustainability, and in particular sustainable finance. It is crucial to have mandatory…

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…