Sustainability-related disclosure in the financial services sector
The European Union (EU) aims to pursue environmentally and socio-economically sustainable development. To progress in this direction, it has adopted an Action Plan on financing sustainable growth and has recognised the financial sector as having a crucial role in guiding resources within the economic system towards sustainable development.
On 9 December 2019, Regulation (EU) 2019/2088 of the European Parliament and of the Council on sustainability-related disclosure in the financial services sector (a.k.a. the SFDR) was published.
The SFDR requires financial market participants and financial advisers to provide clients with information regarding their policies on the integration of sustainability risks in investment decision-making and investment and insurance advisory processes; sustainability risk is defined as an environmental, social or governance (ESG) event or condition that, if it occurs, could cause an actual or potential material negative impact on the value of an investment. Investors will, therefore, have at their disposal a more comprehensive set of information, which will enable them to make more informed “sustainable investment” decisions.
On 22 June 2020, Regulation (EU) 2020/852 of the European Parliament and of the Council of 18 June 2020 (a.k.a. the Taxonomy Regulation) on environmentally sustainable economic activities was published in the Official Journal of the European Union, with the aim of introducing a harmonised definition and system of classification of economic activities that can be considered sustainable.
The SDFR and the Taxonomy Regulation are the main regulations aimed at implementing the goals of the Action Plan on financing sustainable growth. They are also designed to:
- orient financial market participants towards sustainability risk management and identifying the financial impact of such risks;
- identify sustainable economic activities underlying investment decisions and financial products;
- promote transparency with investors and enable them to make the most informed decisions possible.
- The new regulations will come into force in several steps, starting from 10 March 2021. This first step includes:
- the integration of sustainability risks in investment decision-making and in investment and insurance advisory processes;
- information on how a financial product takes into account the main negative effects on sustainability factors;
- customer disclosure.
The subsequent requirements will need to be complied with by the later date of 2022.
The Bank will take sustainability factors into account in its investment process. In order to analyse its product catalogue, the Bank uses the information provided by the companies whose products and financial instruments it places, the information made available by external companies specialised in analysing products and financial instruments (info-providers), as well as any international certifications obtained by individual products or financial instruments. Consequently, the Bank will enrich its commercial offering by selecting financial products and instruments that truly adhere to sustainability criteria, avoiding the inclusion of financial products and instruments which may claim to pursue sustainability goals but fail to do so in substance (greenwashing).
As of 10 March 2021, sustainability risks in investment decisions will be communicated in the pre-contractual information (the “Information Note”) of investment services agreements, including the Portfolio Management Service Agreement. Customers who, on the date the regulations come into force, have signed one of the two contracts impacted by the integration will receive a notification.
In this section, the Bank publishes the main changes in sustainability regulations that may impact the provision of advisory services to its clients, thereby ensuring that customers are provided with appropriate and ongoing information.
The Bank has therefore set itself the aim of designing a remuneration policy that does not focus exclusively on profit and loss, cash flow and balance sheet results, but that reflects a fundamental awareness of values and principles that include the environment, gender neutrality, inclusivity, the promotion of equal opportunities as well as the listening, engagement and participation of employees.