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)

Sustainability risk refers to an event or condition relating to environmental, social or governance (ESG) issues. The realisation of a financially material sustainability risk can have a negative impact on the value of an investment and thus on the return of the financial product. VP Bank has implemented a systematic approach to taking sustainability risks into account in its investment decisions. In the following, we will show how sustainability risks are taken into account at VP Bank and 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) & sustainability-related product disclosure (Article 10)

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.

Information on sustainability-related product disclosure according to Article 10 provide transparency on the promotion of environmental or social (E/S) characteristics and on sustainable investments. The information is to be disclosed clearly, 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.