Sustainability —

Sustainable Financial Disclosure Regulation (SFDR)

What is SFDR?

The EU regulation on sustainability-related disclosure in the financial services sector (EU/2019/2088) is a European regulation introduced to improve transparency in the market for sustainable investment products. The regulation imposes comprehensive sustainability disclosure requirements covering a wide range of environmental, social and governance (ESG) criteria at both company and product level.

Product classification

SFDR mandates financial market participants to categorize their investment products as Article 6, 8 or 9, depending on the level of sustainability they demonstrate.

• Article 6 products, represented by a grey label, do not have sustainability features and can consider sustainability risks.
• Article 8 products, which are labelled light green, promote environmental and/or social characteristics while maintaining a sustainable investment strategy.
• Article 9 products, labelled dark green, have sustainable investment as their primary objective, indicating that they prioritize environmental, social, and governance factors.

The information required under the SFDR Regulation is published on this website.

Integration of sustainability risks (Articles 3)

A sustainability risk is defined as an event or condition in the environmental, social or corporate governance (ESG) area, the occurrence of which could have a significant negative impact on the value of the investment. In the following document, we show how sustainability risks are considered at VP Bank and are incorporated into our investment decisions.

Sustainability risk integration in investment decisions and advice

Adverse sustainability impacts at entity level (Article 4)

Investment decisions and investment advice may cause, contribute to, or be directly linked to adverse - material or likely material - impacts on sustainability factors. In the following table, we disclose annually how we account for adverse impacts of investment decisions on sustainability factors at the company level.

Remuneration policy (Article 5)

In this section, we indicate how sustainability risks are reflected in our remuneration policy. VP Bank Group's remuneration policy and practices are simple, transparent and geared to sustainability, which include environmental, social and governance aspects. They are in line with the Group's business strategy, objectives and values as well as its long-term overall earnings and they take account of the Group's equity capital resources.

Remuneration Policy

Pre‐contractual disclosures (Articles 6, 8 and 9)

In the pre-contractual information in accordance with Articles 6, 8 and 9, we state how sustainability risks are incorporated into investment decisions, whether our asset management mandates target environmental and/or social characteristics and make sustainable investments, and whether a benchmark has been determined.

Sustainability-related product disclosure (Article 10)

Information in this section provides transparency of the promotion of environmental or social characteristics and of sustainable investments. The information are to be disclosed in a way that is clear, succinct and understandable to investors.

Periodic reports (Article 11)

For mandates classified under Article 8(1), we provide explanations on how the environmental and/or social characteristics have been met in regular reports. For clients with an asset management mandate under Article 8(1), a portfolio-specific periodic report is prepared and shared directly with clients.

Change log (Article 12)

We ensure that the information published is always up to date. If we make changes, we publish this below with a clear explanation of the changes concerned.