Arbeitskreis Kirchliche Investoren
AKI
The AKI coordinates and promotes sustainable investment for the protestant church in Germany.
ID: 439507546161-38
Lobbying Activity
Response to Revision of EU rules on sustainable finance disclosure
28 May 2025
As an working group of chruch investors we would like to make the following coments: SFDR 2/17 states: Sustainable investment means an investment in an economic activity that contributes to an environmental objective, () or an investment in an economic activity that contributes to a social objective, in particular an investment that contributes to tackling inequality or that fosters social cohesion, social integration and labour relations, or an investment in human capital or economically or socially disadvantaged communities, Advancing from this, investors need more guidance on how social investment are defined. We suggest building this definition on international documents like the universal declaration of human rights. Considering existing attempts to define social services in documents like the definition of services of general economic interest" in the EU treaty or the ICMA principles for social bonds we find a hight degree of agreement. Food security, Affordable housing, accessible healthcare and accessible education are mentioned in all applicable documents. We suggest that when revising the SFDR social objectives of sustainable investment are spelled out in this sense. On the question whether defence is sustainable we would like to quote Dwight D. Eisenhower, who in 1953 at the outset of the cold war where, defence was as necessary as it is today: Every gun that is made, every warship launched, every rocket fired signifies in the final sense, a theft from those who hunger and are not fed, those who are cold and are not clothed. This world in arms is not spending money alone. It is spending the sweat of its laborers, the genius of its scientists, the hopes of its children. This is not a way of life at all in any true sense. Under the clouds of war, it is humanity hanging on a cross of iron. Yes, Europe has to invest in its defence there is no question about this fact, however defence must not be framed as sustainable but as a deplorable necessity which cannot be avoided in this historical situation. The goal remains to ensure that urgently needed funds for housing, education, healthcare and innovation do not flow into equipment which destroys lives, maims soldiers, traumatises children, ruins the future of generations.
Read full responseResponse to Initiative on EU taxonomy - environmental objective
11 Apr 2023
The draft act is highly welcome as it shows that there is progress in the implementation of the EU Taxonomy, on top the issue of water is of high importance especially in a situation of climate related draughts in Europe and elsewhere. It is also welcome that the criteria relate to EU standards and legislation however always offer an alternative for their international application. However, there is something missing. Access to clean drinking water is a human right. This is not and cannot be addressed in the environmental criteria. There is a link to this social dimension in Article 18 of the REGULATION (EU) 2020/852 (Taxonomy regulation). This article might and should prevent that an activity listed in Draft delegated regulation Ares (2023)2481554 (Taxo 4) is called sustainable by at the same time deteriorating the access to safe drinking water for certain groups. However, there is no guarantee for it as there is no FAQ or level 2 interpretation of this article. The report published by platform 1.0 does not mention the right to access to water. In this situation it is very well possible that the activity 2.1 mentioned in the draft regulation of Construction, extension, operation, and renewal of water collection, treatment and supply systems intended for human consumption leads to higher tariffs and by this deteriorates the access to drinking water for certain populations. This is not a theoretical hypothesis. This has happened in third countries and may happen in Europe as well. On top of this the example shows that while we need investments into sustainable use of water, we also need investments in affordable drinking water. This problem will arise even in Europe where the provision of drinking water will become more expensive in a situation where draughts will become the new normal in certain regions. The suggested criteria for environmentally beneficial activities for water show very clearly that by creating solely an environmental taxonomy the social perspective is neglected and runs contrary to the aspiration that the EU serves the people of Europe.
Read full responseMeeting with Katherine Power (Cabinet of Commissioner Mairead Mcguinness)
28 Nov 2022 · Social taxonomy