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The Sustainable Finance Disclosure Regulation (SFDR) requires three types of disclosure at product level:
Retail investors must be provided with comprehensive information on the sustainability profile of a financial product before making an investment decision: the general sustainability risks, the principal adverse impact on sustainability (PAI), the investment strategy, the asset allocation (sustainable vs. other), % taxonomy aligned positions and last but not least – a comparison to a designated sustainable benchmark index (if available).
Further information is to be provided to clients on a regular basis, after the contract has been concluded: the performance of the sustainability indicators, taxonomy alignment, top investments, asset allocations, etc., a current comparison with the sustainability benchmark and current PAI data at portfolio level.
In addition, the SFDR requires the maintenance of sustainability disclosures, for example environmental and social characteristics, on product websites.
Comprehensive information must also be provided on the individual companies in which a financial product is invested: periodical disclosures (as per the template in the draft RTS), calculations using various data points at company level, as well as “adescription of the principal adverse sustainability impacts (PASI) and of any actions in relation thereto taken or, where relevant, planned”
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