Feedback (9)

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  • Invest Europe (Belgium)
    11 December 2017 Other
    Invest Europe (Belgium)

    Invest Europe supports the Commission’s (EC) work to ensure that material sustainability factors are assessed, consistently taken into account and disclosed by institutional investors and asset managers. However, it is crucial that an accepted definition of “sustainability” (eg Brundtland report) is used and the scope captures all aspects of sustainability (climate change, environment, social & governance). We should be careful not to...

  • INVERCO (Spain)
    11 December 2017 Business association
    INVERCO (Spain)

    INVERCO supports the need to improve undertakings' disclosure of social and environmental information, as well as, developing positions towards considering ESG aspects and integrate them on a voluntarily basis in their asset allocation decisions. Nevertheless, “comply or explain” should be the fundamental transparency principle. From our point of view, there should not be any compulsory ESG rules in the investment strategy/asset allocation,...

  • Anonymous (Spain)
    11 December 2017 Business association
    Anonymous (Spain)

    INVERCO supports the need to improve undertakings' disclosure of social and environmental information, as well as, developing positions towards considering ESG aspects and integrate them on a voluntarily basis in their asset allocation decisions. Nevertheless, “comply or explain” should be the fundamental transparency principle. From our point of view, there should not be any compulsory ESG rules in the investment strategy/asset allocation,...

  • BVI (Germany)
    11 December 2017 Business association
    BVI (Germany)

    BVI’s view on responsible investment Responsible and long-term considerations play an increasingly important role in investment decisions. Many investors feel a responsibility to address environmental, social and governance (ESG) issues by being more selective in their investments. The asset management industry plays a crucial role in facili-tating this trend. BVI therefore gladly takes the opportunity to present its views on responsible...

  • BETTER FINANCE (Belgium)
    11 December 2017 Non-governmental organisation (NGO)
    BETTER FINANCE (Belgium)

    BETTER FINANCE welcomes this impact assessment aiming at ensuring that material sustainability factors are consistently taken into account and disclosed by institutional investors and asset managers. BETTER FINANCE agrees with the European Commission on the fact that increasing the transparency of the integration of sustainability in the investment process of asset managers and institutional investors will lead to reduced search costs for end...

  • BCSD Portugal (Portugal)
    11 December 2017 Business association
    BCSD Portugal (Portugal)

    Conselho Empresarial para o Desenvolvimento Sustentável (BCSD Portugal) welcomes the initiative “Institutional investors’ and asset managers’ duties regarding sustainability” and the opportunity given to stakeholders to comment on the Inception Impact Assessment. The European Union (EU) has committed to achieving a net zero economy by 2050 and has accepted the UN’s Agenda 2030 and the Sustainable Development Goals (SDGs). Attaining these...

  • European Fund and Asset Management Association (Belgium)
    11 December 2017 Business association
    European Fund and Asset Management Association (Belgium)

    We agree that the European asset management industry has a role to play in contributing to the sustainability agenda. We see this role in 3 distinctive parts: • First, the asset management industry provides its clients, institutional investors and other asset owners, investment solutions that respond to their investment as well as ESG / impact demands; • Secondly, asset managers can give institutional investors the tools and advice for...

  • Association of the Luxembourg Fund Industry (Luxembourg)
    11 December 2017 Business association
    Association of the Luxembourg Fund Industry (Luxembourg)

    Introduction The Association of the Luxembourg Fund Industry (ALFI) is the representative body of the Luxembourg investment fund community. Created in 1988, the Association today represents over 1,400 Luxembourg domiciled investment funds, asset management companies and a wide range of service providers such as depositary banks, fund administrators, transfer agents, distributors, legal firms, consultants, tax experts, auditors and accountants,...

  • Austrian Federal Economic Chamber, Division Bank and Insurance (Austria)
    7 Dezember 2017 Other
    Austrian Federal Economic Chamber, Division Bank and Insurance (Austria)

    Grundsätzlich wird die Integration von materiellen ESG (environmental, social and governance) Faktoren und die Vereinheitlichung von Begrifflichkeiten als auch die Einführung von allgemein gültigen Definitionen begrüßt. Auch die erhöhte Transparenz unter den Asset Managern, wie sie diese Faktoren berücksichtigen, ist zu unterstützen. Jedoch den Schluss zu ziehen, dass eine vermehrte Transparenz die Suchkosten für den End-Investor/Konsumenten...