A central pillar of the European Union’s Sustainable Finance Action Plan is the Sustainable Finance Disclosure Regulation (SFDR), which applied from March 2021.
The SFDR requires asset managers to make sustainability related disclosures with respect to the financial products and services they offer. The broader suite of sustainable finance regulations aims to direct private capital into sustainable economic activities, reduce the risk of greenwashing and align the economy with the objectives of the Paris Agreement and the United Nations’ Sustainable Development Goals (SDGs).
SFDR requires asset managers to make disclosures at a product level and firm level. Financial products, including managed accounts, can fall into three categories under SFDR which determine the sustainability related disclosures to be made for such products.
An overview of product classifications
Although a disclosure regime, not a labelling regime, the regulation effectively establishes three product classifications, based on whether the disclosure obligations set out in Articles 6, 8, or 9 apply. We summarise these below.
Article 6
- Not subject to Articles 8 or 9.
- Still consider environmental, social and governance (ESG) risks and opportunities.
Article 8
- Promote environmental and/or social characteristics through binding investment criteria.
- May also be referred to as Light Green Products.
Article 9
- Have sustainable investment or a reduction in carbon emissions as their objective.
- May also be referred to as Dark Green Products.
Firm level disclosures
Asset managers in scope for SFDR must also make firm level disclosures about how they consider sustainability risks in their investment decision making process, how their remuneration policy is aligned with such an approach to sustainability risk management and whether they consider the ‘principal adverse impacts’ of their investment decisions on sustainability factors. Our Principal Adverse Sustainability Impacts statement and sustainability risk disclosures can be found here.
Implementing SFDR at Macquarie Asset Management
Macquarie Asset Management (MAM) is committed to responsible investment, as demonstrated by becoming a signatory to the United Nations’ Principles for Responsible Investment (PRI). MAM has been a signatory to the PRI since 2015. The public markets businesses of Macquarie Asset Management’s are committed to incorporating the principles into its investment activities.
The public markets businesses of Macquarie Asset Management have several European entities within the scope of the regulation, all of which were fully compliant by the 10 March 2021 deadline.
SFDR in action — Article 9 case studies
Macquarie Asset Management public markets products include funds with strategies that incorporate exclusion screening, positive screening, ESG integrated fundamental analysis, proprietary ESG ratings and SDG alignment analysis. Below we outline the investment strategies of two of our Article 9 funds.
Macquarie Sustainable Emerging Markets Local Currency Bond Fund
The Fund invests in supranational bonds that are aligned with the SDGs using an active investment strategy which incorporates both exclusion screening and ESG integrated fundamental analysis.
The team’s exclusion screen is based on ratings provided by an external ESG consultant whereby they exclude issuers of certain activities, sectors and practices that are incompatible with sustainability principles such as energy derived from fossil fuels, nuclear energy, business malpractice, or significant environmental damage. Fundamental analysis includes assessing the remaining issuers in the investment universe alongside the SDG’s and only investing where there is alignment.
Macquarie Sustainable Global Listed Infrastructure Fund
The Fund invests in listed infrastructure assets that contribute in a sustainable manner to the operation and growth of economies around the world. Infrastructure assets are well placed to deliver fundamental change to the sustainability of our communities.
The team incorporates both exclusion screening and integrated ESG fundamental analysis. The team’s exclusion screen is based on ratings provided by an external ESG consultant whereby issuers that do not achieve a minimum rating are excluded. Fundamental analysis involves assessing the remaining issuers in the investment universe on their commitment to sustainability and compliance with the sustainable investment objectives, which include climate change mitigation, climate change adaptation, and positive social impact.
SFDR requires firms to classify all their in-scope products and managed accounts. As mentioned in our introduction, although a disclosure regime, the regulation effectively establishes three product classifications, based on whether the disclosure obligations set out in Articles 6, 8, or 9 apply.
While we do have funds that are classified as Article 6, below we have specifically detailed our Article 8 and Article 9 funds which are available for investment.
Those products which promote environmental and/or social characteristics and have binding investment criteria to attain such characteristics —
Macquarie Global Listed Real Assets Fund
Multi-asset investment strategy
- The Fund seeks to provide investors with capital appreciation, income and diversification utilising securities which are deemed to provide exposure to real assets. It aims to protect purchasing power by providing risk-adjusted and inflation adjusted total returns over full market cycles and invests in minimum 75% securities which promote the environmental and social characteristics.
- In portfolio construction, the Fund applies an exclusion screen to identify securities which may harm environmental or social objectives and utilises a scoring process used to measure alignment with the United Nations’ Sustainable Development Goals (SDGs) and, where applicable, a qualitative assessment of the SDG alignment.
- Environmental, social and governance integrated fundamental analysis is applied to provide a qualitative overlay which assesses both financial and non-financial criteria.
Macquarie ValueInvest LUX Global Fund
Equity investment strategy
- The Fund primarily invests in global equities listed on stock exchanges in developed countries.
- The Fund aims to deliver strong long term returns by investing in a concentrated portfolio of quality businesses with mispriced earnings power.The Fund invests with the intention of promoting the environmental and social characteristics outlined by the Ten Principles of the UN Global Compact. The Ten Principles primarily cover human rights, labour, environment, and anti-corruption.
- Read more about the UN Global Compact.
Macquarie Euro Government Bond Fund
Fixed income investment strategy
- The Fund invests in corporate and/or sovereign issuers which make a net positive contribution to sustainability by virtue of their environmental, social, and economic characteristics. Social criteria may include indicators such as corporate citizenship, human rights, employee health and safety and equal opportunities.
- The Fund also aims to provide shareholders with a robust ongoing performance while at the same time giving due consideration to the liquidity of the underlying assets.
Macquarie Corporate Bond Fund
Fixed income investment strategy
- The Fund invests in corporate bonds which align with the United Nations’ Sustainable Development Goals (SDGs). The 17 SDGs recognise the need for urgent action by all countries; that ending poverty and other deprivations must go together with strategies that improve health and education, reduce inequality, and spur economic growth — all while tackling climate change and working to preserve the world’s oceans and forests.
- Read more
Macquarie Emerging Markets Debt Select Opportunities Fund
Fixed income investment strategy
- The Fund invests in emerging market corporate and sovereign issuers which contribute to certain positive environmental and social characteristics.
- Environmental characteristics include positive indicators across climate change and carbon emissions, environmental health and ecosystem vitality, energy management, water and wastewater management, waste and hazardous materials management, and ecological impacts.
- Social characteristics include positive indicators across human rights, political rights and civil liberties, customer privacy and data security, product quality and safety, and employee health and safety.
Macquarie Emerging Markets Debt Sovereign Fund
Fixed income investment strategy
- The Fund invests in emerging markets debt sovereign and quasi-sovereign bonds which display positive environmental and social (as well as governance) characteristics.
- Using a proprietary model to create ESG composite scores, the team adjusts social and governance scores for the level of development of the country and excludes sovereigns falling into the bottom quartile based upon this proprietary framework.
Those products which have sustainable investment as their objective, and which integrate sustainability into the investment process in a binding manner.
Macquarie Sustainable Global Listed Infrastructure Fund
Equity investment strategy
- The Fund invests in listed infrastructure assets that contribute in a sustainable manner to the operation and growth of economies around the world.
- The Fund maximises this potential benefit through investing in a concise portfolio of high-quality infrastructure assets which provide exposure to capital expenditure that is expected to mitigate the impacts of, and adapt to, the effects of climate change.
Macquarie Sustainable Emerging Markets LC Bond Fund
Fixed income investment strategy
- The Fund invests in bonds and/or securitised debt instruments that are issued or guaranteed by supranational agencies which are aligned with the United Nations’ Sustainable Development Goals (SDGs).
- The 17 SDGs recognise the need for urgent action by all countries. That ending poverty and other deprivations must go together with strategies that improve health and education, reduce inequality, and spur economic growth — all while tackling climate change and working to preserve the world’s oceans and forests.
- Read more
Macquarie Emerging Markets Debt Sustainable Opportunities Fund
Fixed income investment strategy
- The Fund invests in a diversified portfolio of hard currency-denominated or local currency-denominated emerging markets bonds that contribute substantially to an environmental and/or a social objective. The Fund also aims for as much alignment as practically possible with the EU taxonomy.
- Environmental contributions include climate change mitigation, climate change adaptation, the sustainable use and protection of water and marine resources, the transition to a circular economy, pollution prevention and control, and the protection and restoration of biodiversity and ecosystems.
- Social contributions include poverty reduction, hunger elimination, good health and well-being, education, gender equality, and social inequality reduction.
Macquarie Asset Management FY23 Sustainability Report
At Macquarie Asset Management, we view sustainability as part of our fiduciary duty to protect and grow our clients’ assets. This focus also helps us generate positive outcomes for our investee companies and the communities they serve. Our latest Sustainability Report outlines the progress we have made over the past financial year.
SFDR requires firms to classify all their in-scope products and managed accounts. As mentioned in our introduction, although a disclosure regime, the regulation effectively establishes three product classifications, based on whether the disclosure obligations set out in Articles 6, 8, or 9 apply.
While we do have funds that are classified as Article 6, below we have specifically detailed our Article 8 and Article 9 funds which are available for investment.
What is SFDR? Why is it important?
SFDR is part of the European Union’s Sustainable Finance Action Plan. It introduces mandatory sustainability disclosures which will help to increase the amount of sustainability related information available to investors. Such transparency will enable investors to make greater comparisons between ‘green’ products and will help to bring standardisation to the industry. Investors have found the lack of agreed definitions or concepts of what is ‘green’ a challenge and it is hoped that SFDR will enable investors to make more informed decisions which will in turn increase investment into sustainable activities.
Who does SFDR apply to?
SFDR applies to “financial market participants” including alternative investment fund managers, management companies, and MIFID investment firms, amongst others, which offer products to investors in the EU.
Where can I find further information about MAM's Article 8 and Article 9 Funds?
MAM offers financial products across all three classifications, including a range of Article 8 and Article 9 funds.
SFDR product disclosures are available on the website for the relevant fund. High level disclosures can be found in the prospectus of the relevant fund, with more detailed website disclosures available for financial products which are classified as Article 8 or Article 9. Disclosures for a particular fund can be found within the ‘Information’ tab under the heading ‘Sustainability-related disclosures’.
What are the Ten Principles of the UN Global Compact?
Corporate sustainability starts with a company’s value system and a principles-based approach to doing business. In doing so firms need to operate in ways that, at a minimum, meet fundamental responsibilities in the areas of human rights, labour, environment, and anti-corruption. Responsible businesses enact the same values and principles wherever they have a presence and know that good practices in one area do not offset harm in another. The Ten Principles of the United Nations Global Compact primarily cover human rights, labour, environment, and anti-corruption.
What are the UN SDGs?
The 2030 Agenda for Sustainable Development, adopted by all United Nations Member States in 2015, provides a shared blueprint for peace and prosperity for people and the planet.
Core to this is the 17 Sustainable Development Goals (SDGs), which are an urgent call for action by all countries. They recognize that ending poverty and other deprivations must go together with strategies that improve health and education, reduce inequality, and spur economic growth — all while tackling climate change and working to preserve the world’s oceans and forests. Examples of the SDGs include Climate Action, Affordable and Clean Energy, No Poverty, Gender Equality and Decent Work, and Economic Growth. Details of all 17 SDGs can be found online at the UN’s dedicated site.
How can I find out what classification my fund is?
If you need assistance with determining the classification of a particular financial product, please reach out to us using the contact details listed below.
Will you be making disclosures regarding the alignment of portfolios to the EU Taxonomy?
Yes. The EU Taxonomy is a classification system for determining whether economic activities are environmentally sustainable. MAM is required to make disclosures regarding the Taxonomy alignment of its portfolios and was compliant with the 1 January 2022 deadline for all in-scope products.
What is greenwashing?
Greenwashing is the process of conveying a false impression or providing misleading information about how a company’s products are more environmentally sound. Greenwashing is considered an unsubstantiated claim to present the view that a company’s products are environmentally friendly. SFDR aims to prevent greenwashing by increasing transparency about the sustainability of financial products through detailed disclosures.
We invest in sustainability today for a better tomorrow
We seek to invest sustainably because we believe it leads to better long term outcomes fro our clients, investee companies and the communities they serve. By supporting businesses to reduce their greenhouse gas emissions and transition to a low-carbon economy, we believe our efforts can help to preserve and create value, while delivering positive outcomes for communities and the environment.
Do you have questions about SFDR? If you would like to find out more about our Article 8 and Article 9 funds or learn more about our responsible investing approach, please contact us.
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