The queries concern the following profiles:
- definition of “sustainable investment” within the meaning of Article 2(17) SFDR, with particular regard to
1. investments that do not specify the use of the proceeds. For example, where the company receiving the investment has, among other things, an economic activity that contributes to an environmental or social objective, can this be considered a ‘sustainable investment’ in whole or in part?
2. the concept of an investment in an economic activity that contributes to an environmental objective or a social objective, i.e. what are the characteristics that make an economic activity suitable for meeting this definition - financial product has the objective of reducing the carbon emissions under Art. 9(3) SFDR
1.can products with a passive and an active investment strategy be included in such products? Are there specific requirements they should meet when they have designated an index as a benchmark?
2.can a financial product “promote” carbon emissions reduction as an “environmental characteristic”, as opposed to having it as an “objective”?
3.can financial products with a passive investment strategy which designate as a reference benchmark either a Paris Aligned Benchmark or (from 1 January 2023) a Climate Transition Benchmark automatically be deemed to fulfil the conditions of Article 9(3) SFDR? - what is meant, according to Article 7(1)(a) SFDR, by the consideration of major adverse effects (PAI) on sustainability factors by a financial product?
- regarding the transparency of negative sustainability effects at the entity level, for the purposes of Articles 4(3)-4(4) SFDR how is the “average number of 500 employees” to be determined?
- clarification on the frequency of periodic reporting for portfolio management services under Article 11(2)(i) SFDR.
