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Aviva Plc

Aviva

Aviva is a major insurance, wealth, and retirement business operating in the UK, Ireland, and Canada, offering life insurance, pensions, general insurance, and asset management.

Lobbying Activity

Meeting with Bernard Guetta (Member of the European Parliament) and BlackRock and

4 Jun 2025 · Discussion with global investors on the future of Europe

Aviva warns EU tax rules could disadvantage pension funds

18 Sept 2023
Topic — The initiative proposes a common, standardised, EU-wide system for withholding tax relief at source.
Message — Aviva requests the EU define tax residency proof, ideally including a list of third countries. Excluding funds from relief will add significant costs and impact customers directly. They also suggest data be submitted to a central portal to ensure standardisation.12
Why — Standardized digital procedures would help the company avoid time-consuming and expensive tax reclaim processes.3
Impact — Customers and pension holders face lower returns due to higher costs and delayed tax reclaims.4
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Aviva urges EU to include chemicals in environmental taxonomy

3 May 2023
Topic — This consultation establishes sustainability criteria for economic activities contributing to EU environmental goals.
Message — Aviva requests including chemical manufacturing and textiles to drive industry sustainability. They also demand that pollution prevention rules for harmful substances remain strict.12
Why — Including these sectors provides more opportunities for sustainable investment and risk management.3
Impact — Manufacturers of hazardous substances may lose access to green investment capital.4
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Aviva seeks director disqualification for corporate sustainability failures

21 May 2022
Topic — European Commission proposal for mandatory corporate environmental and human rights due diligence.
Message — Aviva recommends that directors face disqualification for serious due diligence failures to prevent penalties from simply being passed to shareholders. They also advocate for rules covering the entire value chain rather than just established business partners.12
Why — Personal sanctions for directors would protect Aviva's investment valuations from the financial impact of corporate fines.3
Impact — Corporate directors would lose their ability to treat legal breaches as a routine cost of doing business.45
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Meeting with Mairead McGuinness (Commissioner)

3 Jun 2021 · Introductory meeting. Insurance Matters

Meeting with Mairead McGuinness (Commissioner)

30 Mar 2021 · Solvency 11, Insurance

Response to Integration of sustainability risks and factors in relation to the business of insurance and reinsurance

6 Jul 2020

Aviva welcomes the publication of this suite of draft Delegated Acts, which implement important parts of the Sustainable Finance Action plan. We strongly support the policy intent to incorporate sustainability into suitability assessments, fiduciary duties and organisational requirements. Incorporation into the suitability assessments in particular is been seen by us as being a key gamechanger in investment behaviour. We are, however, concerned that the definition of “sustainability preferences” in this draft Act is too narrowly and may have the unintended consequence of undermining broader policy aims of using financing to help as wide a part of the economy transition into sustainable practices. We think that the amendments made to the draft definition from the earlier draft are an improvement. However, it remains the case that the likely effect of the definition will drive investors towards products that are already sustainable. It fails to engage the wider role that financing can play in the transition, through for example, stewardship, integration, or impact investments. The failure to engage client demand to finance that wider range of activities overlooks the importance of creating conditions that support investing to support the transition. Successfully challenging those that can transition to do so is arguably even more important than funding those that are pure play solutions providers. Sustainability preferences in investing should focus on a client led approach. There are a range of activities beyond investing in “sustainable investments” that clients may wish to engage in to make sure that their money works to achieve the sustainability outcomes they want to see, such as the activities mentioned in the paragraph above. These activities relate to products within the scope of Article 8 of the Disclosure Regulation (“Article 8 products”). The requirements imposed on Article 8 products in their incorporation into the “sustainability preference” definition will exclude activities that clients will want their money to be financing from a sustainability perspective. We ask that part (b) of the definition be removed. If there is a need for the definition of Article 8 products to be revisited then that should happen in the context of the Disclosure Regulation itself, where a proper analysis and consultation on that point can be had. It is, however, undesirable for there to be a misalignment between the disclosure requirements under the Disclosure Regulation and sustainability preferences for the purposes of client suitability assessments. This is important as to the extent there are concerns to avoid firms “greenwashing” we are of the view that this would be mitigated by the effect of having to make disclosures under the Disclosure Regulation. On a more technical note the draft definition of “sustainable preferences” also appears to inadvertently further narrow the range of Article 8 products which fall within its scope until late 2022. This is because the wider range of Article 8 products which might fall within part(b)(ii) of the definition, which are not within part (b)(i), will only be able to form part of the suitability preferences after 30 December 2022. It is expected, however, that the suitability preferences assessments will commence well in advance of that. We hope that the changes to the draft definition that we ask for in his response are made. It is important that the policies under the Sustainable Finance Action plan work in harmony to both champion the best in class and to fully support the wider range of activities that will see the transition of the whole economy. At the moment the risk of the draft suitability preferences provisions inadvertently misdirecting interest away from the latter is real.
Read full response

Response to Integration of sustainability risks and factors in relation to insurance undertakings and insurance distributors

6 Jul 2020

Aviva welcomes the publication of this suite of draft Delegated Acts, which implement important parts of the Sustainable Finance Action plan. We strongly support the policy intent to incorporate sustainability into suitability assessments, fiduciary duties and organisational requirements. Incorporation into the suitability assessments in particular is been seen by us as being a key gamechanger in investment behaviour. We are, however, concerned that the definition of “sustainability preferences” in this draft Act is too narrowly and may have the unintended consequence of undermining broader policy aims of using financing to help as wide a part of the economy transition into sustainable practices. We think that the amendments made to the draft definition from the earlier draft are an improvement. However, it remains the case that the likely effect of the definition will drive investors towards products that are already sustainable. It fails to engage the wider role that financing can play in the transition, through for example, stewardship, integration, or impact investments. The failure to engage client demand to finance that wider range of activities overlooks the importance of creating conditions that support investing to support the transition. Successfully challenging those that can transition to do so is arguably even more important than funding those that are pure play solutions providers. Sustainability preferences in investing should focus on a client led approach. There are a range of activities beyond investing in “sustainable investments” that clients may wish to engage in to make sure that their money works to achieve the sustainability outcomes they want to see, such as the activities mentioned in the paragraph above. These activities relate to products within the scope of Article 8 of the Disclosure Regulation (“Article 8 products”). The requirements imposed on Article 8 products in their incorporation into the “sustainability preference” definition will exclude activities that clients will want their money to be financing from a sustainability perspective. We ask that part (b) of the definition be removed. If there is a need for the definition of Article 8 products to be revisited then that should happen in the context of the Disclosure Regulation itself, where a proper analysis and consultation on that point can be had. It is, however, undesirable for there to be a misalignment between the disclosure requirements under the Disclosure Regulation and sustainability preferences for the purposes of client suitability assessments. This is important as to the extent there are concerns to avoid firms “greenwashing” we are of the view that this would be mitigated by the effect of having to make disclosures under the Disclosure Regulation. On a more technical note the draft definition of “sustainable preferences” also appears to inadvertently further narrow the range of Article 8 products which fall within its scope until late 2022. This is because the wider range of Article 8 products which might fall within part(b)(ii) of the definition, which are not within part (b)(i), will only be able to form part of the suitability preferences after 30 December 2022. It is expected, however, that the suitability preferences assessments will commence well in advance of that. We hope that the changes to the draft definition that we ask for in his response are made. It is important that the policies under the Sustainable Finance Action plan work in harmony to both champion the best in class and to fully support the wider range of activities that will see the transition of the whole economy. At the moment the risk of the draft suitability preferences provisions inadvertently misdirecting interest away from the latter is real.
Read full response

Response to Strengthening the consideration of sustainability risks and factors for financial products (Regulation (EU) 2017/565)

6 Jul 2020

Aviva welcomes the publication of this suite of draft Delegated Acts, which implement important parts of the Sustainable Finance Action plan. We strongly support the policy intent to incorporate sustainability into suitability assessments, fiduciary duties and organisational requirements. Incorporation into the suitability assessments in particular is been seen by us as being a key gamechanger in investment behaviour. We are, however, concerned that the definition of “sustainability preferences” in this draft Act is too narrowly and may have the unintended consequence of undermining broader policy aims of using financing to help as wide a part of the economy transition into sustainable practices. We think that the amendments made to the draft definition from the earlier draft are an improvement. However, it remains the case that the likely effect of the definition will drive investors towards products that are already sustainable. It fails to engage the wider role that financing can play in the transition, through for example, stewardship, integration, or impact investments. The failure to engage client demand to finance that wider range of activities overlooks the importance of creating conditions that support investing to support the transition. Successfully challenging those that can transition to do so is arguably even more important than funding those that are pure play solutions providers. Sustainability preferences in investing should focus on a client led approach. There are a range of activities beyond investing in “sustainable investments” that clients may wish to engage in to make sure that their money works to achieve the sustainability outcomes they want to see, such as the activities mentioned in the paragraph above. These activities relate to products within the scope of Article 8 of the Disclosure Regulation (“Article 8 products”). The requirements imposed on Article 8 products in their incorporation into the “sustainability preference” definition will exclude activities that clients will want their money to be financing from a sustainability perspective. We ask that part (b) of the definition be removed. If there is a need for the definition of Article 8 products to be revisited then that should happen in the context of the Disclosure Regulation itself, where a proper analysis and consultation on that point can be had. It is, however, undesirable for there to be a misalignment between the disclosure requirements under the Disclosure Regulation and sustainability preferences for the purposes of client suitability assessments. This is important as to the extent there are concerns to avoid firms “greenwashing” we are of the view that this would be mitigated by the effect of having to make disclosures under the Disclosure Regulation. On a more technical note the draft definition of “sustainable preferences” also appears to inadvertently further narrow the range of Article 8 products which fall within its scope until late 2022. This is because the wider range of Article 8 products which might fall within part(b)(ii) of the definition, which are not within part (b)(i), will only be able to form part of the suitability preferences after 30 December 2022. It is expected, however, that the suitability preferences assessments will commence well in advance of that. We hope that the changes to the draft definition that we ask for in his response are made. It is important that the policies under the Sustainable Finance Action plan work in harmony to both champion the best in class and to fully support the wider range of activities that will see the transition of the whole economy. At the moment the risk of the draft suitability preferences provisions inadvertently misdirecting interest away from the latter is real.
Read full response

Response to Strengthening the consideration of sustainability risks and factors for financial products (Directive (EU) 2017/593)

6 Jul 2020

Aviva welcomes the publication of this suite of draft Delegated Acts, which implement important parts of the Sustainable Finance Action plan. We strongly support the policy intent to incorporate sustainability into suitability assessments, fiduciary duties and organisational requirements. Incorporation into the suitability assessments in particular is been seen by us as being a key gamechanger in investment behaviour. We are, however, concerned that the definition of “sustainability preferences” in this draft Act is too narrowly and may have the unintended consequence of undermining broader policy aims of using financing to help as wide a part of the economy transition into sustainable practices. We think that the amendments made to the draft definition from the earlier draft are an improvement. However, it remains the case that the likely effect of the definition will drive investors towards products that are already sustainable. It fails to engage the wider role that financing can play in the transition, through for example, stewardship, integration, or impact investments. The failure to engage client demand to finance that wider range of activities overlooks the importance of creating conditions that support investing to support the transition. Successfully challenging those that can transition to do so is arguably even more important than funding those that are pure play solutions providers. Sustainability preferences in investing should focus on a client led approach. There are a range of activities beyond investing in “sustainable investments” that clients may wish to engage in to make sure that their money works to achieve the sustainability outcomes they want to see, such as the activities mentioned in the paragraph above. These activities relate to products within the scope of Article 8 of the Disclosure Regulation (“Article 8 products”). The requirements imposed on Article 8 products in their incorporation into the “sustainability preference” definition will exclude activities that clients will want their money to be financing from a sustainability perspective. We ask that part (b) of the definition be removed. If there is a need for the definition of Article 8 products to be revisited then that should happen in the context of the Disclosure Regulation itself, where a proper analysis and consultation on that point can be had. It is, however, undesirable for there to be a misalignment between the disclosure requirements under the Disclosure Regulation and sustainability preferences for the purposes of client suitability assessments. This is important as to the extent there are concerns to avoid firms “greenwashing” we are of the view that this would be mitigated by the effect of having to make disclosures under the Disclosure Regulation. On a more technical note the draft definition of “sustainable preferences” also appears to inadvertently further narrow the range of Article 8 products which fall within its scope until late 2022. This is because the wider range of Article 8 products which might fall within part(b)(ii) of the definition, which are not within part (b)(i), will only be able to form part of the suitability preferences after 30 December 2022. It is expected, however, that the suitability preferences assessments will commence well in advance of that. We hope that the changes to the draft definition that we ask for in his response are made. It is important that the policies under the Sustainable Finance Action plan work in harmony to both champion the best in class and to fully support the wider range of activities that will see the transition of the whole economy. At the moment the risk of the draft suitability preferences provisions inadvertently misdirecting interest away from the latter is real.
Read full response

Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis)

17 Feb 2020 · sustainable finance

Meeting with Andrea Beltramello (Cabinet of Vice-President Valdis Dombrovskis) and Aviva Investors

13 Nov 2019 · Sustainable finance

Meeting with Helena Braun (Cabinet of First Vice-President Frans Timmermans)

26 Jun 2019 · Discussion on Sustainable development and finance

Meeting with Helena Braun (Cabinet of First Vice-President Frans Timmermans)

29 Apr 2019 · discussion on gender equality's policies and practise

Meeting with Paulina Dejmek Hack (Cabinet of President Jean-Claude Juncker)

4 Dec 2018 · Women in Europe Dinner

Meeting with Helena Braun (Cabinet of First Vice-President Frans Timmermans)

19 Apr 2018 · discussion on sustainable development and on sustainable finance

Meeting with Helena Braun (Cabinet of First Vice-President Frans Timmermans), Michelle Sutton (Cabinet of First Vice-President Frans Timmermans) and Aviva Investors

23 Feb 2018 · Sustainable finance

Meeting with Joachim Balke (Cabinet of Vice-President Miguel Arias Cañete)

23 Feb 2018 · Market design

Meeting with Elina Melngaile (Cabinet of Vice-President Valdis Dombrovskis)

16 Nov 2017 · sustainable finance

Meeting with Paulina Dejmek Hack (Cabinet of President Jean-Claude Juncker) and Barclays PLC and

21 Jun 2017 · Concluding remarks on sustainable finance at the joint Acca, Aviva, Barclays, IIRC Conference

Meeting with Paulina Dejmek Hack (Cabinet of President Jean-Claude Juncker)

24 Apr 2017 · Sustainable Finance

Meeting with Paulina Dejmek Hack (Cabinet of President Jean-Claude Juncker)

6 Mar 2017 · Sustainable finance

Meeting with Valdis Dombrovskis (Vice-President) and

17 Nov 2016 · sustainable/green finance

Meeting with Elina Melngaile (Cabinet of Vice-President Valdis Dombrovskis)

28 Sept 2016 · Sustainable Finance

Meeting with Paulina Dejmek Hack (Cabinet of President Jean-Claude Juncker)

27 Sept 2016 · High-Level Dinner on sustainable finance

Meeting with Hilde Hardeman (Cabinet of Vice-President Jyrki Katainen), Juho Romakkaniemi (Cabinet of Vice-President Jyrki Katainen)

15 Jun 2016 · Sustainable financing

Meeting with Aurore Maillet (Cabinet of Vice-President Karmenu Vella)

15 Jun 2016 · Green Finance

Meeting with Eric Mamer (Digital Economy)

18 Jan 2016 · DSM

Meeting with Heidi Jern (Cabinet of Vice-President Jyrki Katainen) and EUROSIF A.I.S.B.L (EUROPEAN SUSTAINABLE INVESTMENT FORUM)

10 Jul 2015 · Sustainable investments

Meeting with Edward Bannerman (Cabinet of Vice-President Jyrki Katainen)

10 Jul 2015 · Sustainable capital markets

Meeting with Jonathan Hill (Commissioner)

12 Jun 2015 · Financial Services Policy

Meeting with Lee Foulger (Cabinet of Vice-President Valdis Dombrovskis)

19 Mar 2015 · Capital Markets Union

Meeting with Kevin O'Connell (Cabinet of Commissioner Věra Jourová)

18 Mar 2015 · Next steps on data protection

Meeting with Edward Bannerman (Cabinet of Vice-President Jyrki Katainen)

12 Mar 2015 · Investment plan

Meeting with Paulina Dejmek Hack (Cabinet of President Jean-Claude Juncker)

30 Jan 2015 · Capital Markets Union

Meeting with Jonathan Faull (Director-General Financial Stability, Financial Services and Capital Markets Union)

30 Jan 2015 · Capital Markets Union

Meeting with Sarah Nelen (Cabinet of First Vice-President Frans Timmermans)

3 Dec 2014 · Sustainable capital markets

Meeting with Edward Bannerman (Cabinet of Vice-President Jyrki Katainen)

2 Dec 2014 · Investment Initiative

Meeting with Edward Bannerman (Cabinet of Vice-President Jyrki Katainen)

2 Dec 2014 · Investment initiative