At the end of 2019, the Regulation on sustainability-related disclosures in the financial services sector (“SFDR”) was adopted by the European Union. The Regulation takes an all-encompassing and evolving approach to sustainable development, requiring banks to publish information on discretionary management and the advice that they provide, in particular:
These obligations require the Bank to publish information on its website, in its pre-contractual documents and in the discretionary management report.
Since August 2022, we have expanded the investor profile to take into account your sustainability preferences.
In the context of investment advice, your advisor is limited to selecting products from a list established by our specialists and validated by the Comité de Produits d’Investissement (« CPI »). However, a distinction is made between ESG and non-ESG products. Today, the Bank considers a product to be ESG when it is recognised as such by a recognised entity and/or on the basis of its SFDR classification.
Thus, we have a transparent process for classifying a product as ESG. These products are clearly highlighted on our selection lists, which your advisor uses as part of an investment advice, where you are informed about the ESG nature of the product.
As regards discretionary management, we are advised by an external provider; the selection of products is limited to investment funds.
Our external provider’s selection team integrates sustainability risks by selecting investment funds that have solid sustainability-risk integration processes, which include monitoring controversial issues and sustainability indicators. All of our directives integrate these sustainability risks. The directive categorised under Article 6 is not predominantly composed of funds with a sustainable investment objective or that promote environmental or social criteria.
For this directive, the underlying investments do not take into account the European Union criteria for environmentally sustainable economic activities.
The Bank does not take into consideration adverse sustainability impacts in its investment advice as of 10 March 2021. The underlying information required to identify and prioritise adverse sustainability impacts is not currently available to a sufficient degree of quality and quantity. The Bank is looking for a solution to check the availability and quality of this information, which is required under the recent legislation
Banque Raiffeisen’s remuneration policy has been updated, in particular to take sustainability risks into account. However, given the Bank’s prudent and conservative approach to risk management and the very limited level of variable remuneration, the consideration of sustainability risks, as required by the SFDR’s transparency obligations, has no impact on the Bank’s remuneration policy.
This category concerns financial products that promote Environmental/Social (E/S) characteristics but do not have as their objective sustainable investment. Please find the full sustainability-related disclosure here.
This category concerns financial products that have a sustainable investment objective. Please find the full sustainability-related disclosure here.
As of 2019, the European Union has introduced the Green Deal for Europe. This body of legislation is characterised by a regulation: the European taxonomy.
This European regulation aims to classify the economic activities of a company, or a portfolio held by a financial institution, according to the categories and criteria established by the European Commission. Thus, this text intends to increase and redirect capital flows towards green and sustainable investments and projects (in line with the European Union's 2030 climate and environmental objectives), in order to support the transition, promote sustainable and inclusive growth, and prevent greenwashing practices.
As banking institution activities are not included in the list of categories retained in the European taxonomy, none of Banque Raiffeisen’s activities are currently eligible under this regulation.
However, Banque Raiffeisen is concerned by the European taxonomy as a company. Due to its status as an institution not subject to the Non-Financial Reporting Directive (NFRD), the Bank will not be part of the first wave of European financial institutions to carry out a taxonomy analysis of their portfolios as of 2024. Indeed, the EU Taxonomy eligibility analysis on a portfolio level will be carried out by the Bank in the coming years and the results for the year 2025 will be published in 2026, as required by the regulation.
Additional information on the promotion of environmental or social characteristics and sustainable investments will be integrated into the periodic portfolio assessment report as soon as this becomes a legal or regulatory requirement.
With regard to insurance, you will find requirements for publishing sustainability information here
We are here to answer your questions and can put you in contact with the right people depending on your requirements.
