Aim is to prevent greenwashing

Legislation has come into force from the EU regarding disclosure requirements on sustainable investments, the Sustainable Finance Disclosure Regulation (SFDR). Primary aim of this legislation is to prevent greenwashing.

This legislation imposes obligations that pension funds must meet in providing sustainability information on existing policies. The pension fund can lean on the information provided by the asset manager or data provider for this, but policy making and monitoring lies with the pension fund.

SFDR looks at how sustainability risks are factored into “own” investment decisions, how this fits within the fund’s risk appetite and what possible effect sustainability risks have on investment returns. Financial parties offering sustainable products must be extra transparent about how sustainability aspects are put into practice.

Pension funds must therefore make a choice here as to whether they classify themselves as a “product that promotes ecological or social characteristics” (Article 8). If they do not fall into this category, under Article 6 the policy around financial sustainability risks in investment decisions and the effect on returns must still be named.

Effective January 1, 2023, the pension fund board classifies the current CDC plan as Article 8. This is consistent with our MVB policy, in which we state that MVB is an important part of the pension fund’s investment beliefs. The fund believes that SRI contributes positively to the risk-return profile of the pension fund’s investments and to society.

In addition, SFDR entails several requirements. Below we walk through these requirements and discuss how the fund currently complies with them.

1st requirement:
Publication information integration sustainability risks

The way the fund incorporates sustainability risks is described in the fund’s SRI policy. The fund distinguishes two types of sustainability risks. The first type of risks are linked to SRI events or circumstances that, if they occur, could cause an actual or potentially material adverse effect on the value of investments. The second type of risks are reputational in nature: failure to comply with the established SRI policy and/or a mismatch between the fund’s SRI policy and participant expectations.

2nd requirement:
Precontractual information on how ecological and social characteristics will be met

Starting January 1, 2023, the pension fund is required to post the SRI features in a prescribed Precontractual Disclosure Template (PCD) on its website. This statement from the fund can be found here: PCD.

In the PCD, we describe how the fund meets environmental and social characteristics. We describe the ESG methodologies used, ESG indicators, data sources and screening criteria.

3rd requirement:
Account for achievement of goals in prescribed Periodic Template (PD)

We account for achievement of objectives in the prescribed periodic template (PD) retrospectively in the annual report. The first reporting date is the 2023 annual report.

4th requirement:
Description of major adverse effects and actions taken or planned (e.g., engagement or exclusion

In the so-called Principal Adverse Indicator Statement, the fund indicates whether and how the adverse indicators (Principal Adverse Indicators or PAIs) prescribed by the regulator and the 2 voluntary indicators are taken into account in the investment policy. This statement of the fund can be found here: statement of adverse effects.

In addition to the 18 mandatory indicators, two voluntary indicators must be chosen; one covering Environmental aspects and one covering Social aspects. The fund has chosen:

  • Investments in companies without carbon emission reduction initiatives’; this indicator fits with the desire for the manager to have a Net Zero ambition for investment categories in scope.
  • Number of observed cases of serious human rights problems and violations of investments in companies’; this indicator fits with the exclusion policy.

5th requirement:
Publish periodic reporting on ‘adverse effects’

A Principal Adverse Impact (PAI) report will report on an annual basis on the quantitative realization of these adverse impacts as well as a qualitative description of these magnitudes, a comparison against the previous period and an explanation of the management actions the fund has taken/will take. This report will be posted on the website for the first time in 2024, with average realization over the four quarters of 2023.