Disclosure

pursuant to Regulation (EU) 2019/2088 on sustainability‐related disclosures in the financial services sector (Sustainable Finance Disclosure Regulation, SFDR)

Climate change is one of the greatest global challenges, and it can be overcome only through joint action. In 2015, as part of the Paris Agreement, the world’s nations agreed to limit the rise in global temperatures to well below 2°C – and if possible even to at most 1.5°C – above pre-industrial levels. To achieve this goal and minimise the negative impacts of climate change, the European Commission launched the European Green Deal, which includes a comprehensive plan to promote sustainable growth and combat climate change.

A key objective of this plan is to create more transparency in the financial sector with regard to sustainability. The European Union especially wants to reduce information asymmetries that often exist between financial market participants (such as banks and funds) and end consumers (investors). This applies in particular to:

• the consideration of sustainability risks in investment decisions,
• the assessment and disclosure of negative impacts on the environment and society (adverse sustainability impacts),
• the promotion of environmental and social characteristics in financial products, and
• the clear communication of sustainable investment strategies.

These asymmetries are to be made transparent to end clients through mandatory pre-contractual information and continuous disclosures by financial market participants. Regulation (EU) 2019/2088 on sustainability-related disclosures in the financial services sector, referred to as the Sustainable Finance Disclosure Regulation (SFDR), obliges financial market participants and financial advisers to publish written policies on the integration of sustainability risks.

In light of the services we offer (investment advice and portfolio management), the Bank acts both as a financial market participant and as a financial adviser within the meaning of the SFDR, which is why the corresponding disclosure obligations – at both entity and product level – apply.
In light of the services we offer (investment advice and portfolio management), the Bank acts both as a financial market participant and as a financial adviser within the meaning of the SFDR, which is why the corresponding disclosure obligations – at both entity and product level – apply.

Entity-level disclosure (Articles 3, 4 and 5 SFDR)

Product-level disclosure
Product classification

The SFDR requires financial market participants to classify their investment products as Article 6, 8 or 9, depending on the degree of sustainability they exhibit.

• Article 6 products, labelled grey, have no sustainability characteristics and may take sustainability risks into account.
• Article 8 products, labelled light green, promote environmental and/or social characteristics while pursuing a sustainable investment strategy.
• Article 9 products, labelled dark green, have sustainable investments as their main objective, which means that they prioritise environmental, social, and governance factors.

Pre-contractual disclosures (Articles 6, 8 and 9 SFDR)

In the pre-contractual disclosures pursuant to Articles 6, 8 and 9 SFDR, the Bank states how sustainability risks are integrated into investment decisions, whether our asset management mandates target environmental and/or social characteristics and make sustainable investments, and whether a reference benchmark has been designated.

*Transparency in pre-contractual disclosures for products according to Article 6 SFDR

Statement of the Bank pursuant to Article 7 of Regulation (EU) 2020/852 of 18 June 2020 on the establishment of a framework to facilitate sustainable investment, and amending Regulation (EU) 2019/2088 (EU  taxonomy): “The investments underlying this financial product do not take into account the EU criteria for environmentally sustainable economic activities.”

The Bank ensures that the information provided on this website is regularly reviewed and updated.