Sustainability Policy

1. Guidelines on sustainability risks

In accordance with the Sustainable Finance Disclosure Regulation (SFDR), our firm takes sustainability risks into account when advising on insurance products with an investment component, to the extent that such information is provided by the insurance company.

The SFDR defines sustainability risks as “an environmental (E), social (S), or governance (G) event or condition that, if it occurs, could cause an actual or potential material negative impact on the value of an investment.”

Within the context of advising on investment-linked insurance products, our firm's remuneration policy does not encourage excessive risk-taking related to sustainability risks.

2. Adverse impacts on sustainability factors

The SFDR defines sustainability factors as “environmental, social, and employee matters, respect for human rights, and anti-corruption and anti-bribery matters.”

The legal framework regarding sustainability factors and the adverse impacts of investment decisions on these factors is currently incomplete and expected to evolve over the coming months and years.

Therefore, our firm does not currently consider the adverse impacts of investment decisions on sustainability factors in its advice regarding insurance products with an investment component.

We will revise this policy once the legal framework becomes more fully developed.