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Information about sustainability



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:


the transparency of the integration of sustainability risks
Article 6
the transparency of the promotion of environmental or social characteristics
Article 8
the transparency of sustainable investments
Article 9

These obligations require the Bank to publish information on its website, in its pre-contractual documents and in the discretionary management report.

Information about the policies and processes for integrating sustainability risks

Investment advice

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.

  • ESG investment funds and ETFs (Exchange Traded Funds) :
    • Funds classified as «Article 9» (with a defined sustainability objective) under the SFDR regulation.
    • Funds classified as «article 8» (promoting ESG characteristics) in the sense of the SFDR regulation and having a label issued by LuxFlag (ESG, Environment) or Febelfin (Towards Sustainability).
  • Bonds : Specific label for green and social bonds: ICMA Green Bond Principles / ICMA Social Bonds Principles.
  • Structured products: The Bank has currently decided not to classify structured products as ESG.
  • Equities: N/A (the Bank does not provide investment advice on equities)

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.

Discretionary management

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.

No consideration of adverse sustainability impacts

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


Information on remuneration policies in relation to the integration of sustainability risks

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.


Transparency of the promotion of environmental or social characteristics and of sustainable investments (discretionary management)

Promotion of environmental or social characteristics as part of discretionary management (Article 8)

The majority of funds selected under the directives promoting environmental and social criteria must meet extremely strict standards. Our external provider’s selection team takes this into account by integrating environmental, social and governance (ESG) considerations into the selection process for these financial products, thus guiding investments into investment funds that promote environmental or social characteristics or themselves have sustainable investment objectives.

Choosen approach to respecting the environmental or social characteristics as part of discretionary management (Article 8)

The ESG criteria are an integral part of the selection process for investment funds. The financial products selected are the result of close collaboration between investment specialists and sustainability experts at our external provider. Through this procedure, neither financial performance nor sustainability performance are compromised.

How is adherence to these characteristics guaranteed?
When is selecting investment funds, particular attention is paid to the traceability and transparency of the sustainability processes, for instance by documenting processes and drawing up ESG reports by the funds. The concept of integrating sustainability risks, including controversial issues, must be a key component of the strategies of the investment funds selected.

To be selected as a product, the investment funds must exclude from their investments:

  • companies involved in the controversial arms trade;
  • companies that generate more than a specific percentage of their revenues from either arms and tobacco, or nuclear or coal-based energy (unless these companies can demonstrate that they have an exit strategy towards more sustainable energy sources).

Companies involved in gambling and the alcohol trade shall be scrutinised very closely.

In addition to these exclusion criteria, our external provider’s team supports and appreciates proactive attempts by the fund managers to engage in dialogue with the companies involved in critical sectors. An additional requirement for the funds selected is that they invest in companies that comply with the UN Global Compact Principles.

Our external provider’s selection team obtains information on ESG metrics from fund managers and third-party data suppliers. This information is compiled at the level of the directive to verify that the funds selected adhere to the ESG pillars (e.g. having E, S and G ratings or contributing to sustainable development causes).
Furthermore, our external provider’s team works alongside the fund managers in order to accept, implement and improve ESG themes and processes.

Sustainable investments as part of discretionary management (Article 9)

In accordance with the sustainable directive, our external provider’s selection team chooses investment funds with a strong ESG focus, thus prioritising investments in funds that have sustainable investment as an objective.

The distinguishing feature of these investment funds is their pursuit of unambiguous, sustainable objectives. Typical examples are:

  • green and social bonds forming part of the fixed income; and
  • initiatives relating to thematic funds that invest in companies proposing solutions to environmental and social problems.

The sustainable directive primarily draws from funds that have a sustainable investment objective.
Although such an objective may not be specifically targeted, it forms part of the sustainable directive due to its strong alignment with the United Nations’ Sustainable Development Goals (SDGs) and a carbon intensity well below the index.

Periodic portfolio assessment report

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