Disclosure

Sustainability disclosure

Foreword

Regulation (EU) No. 2088/2019 (hereinafter the ‘SFDR‘) on sustainability transparency requirements in the financial services industry requires entities providing investment advice and on insurance investment products to publish on their websites:

  • information on policies on the integration of sustainability risks into their advice;
  • information on how their remuneration policies are consistent with the integration of sustainability risks;
  • whether or not they take the main negative effects on sustainability factors into account when providing their advice.

The Bank is an addressee of these obligations in its capacity as “financial advisor” as defined by the SFDR insofar as it provides investment advice to its clients on investment and insurance investment products.

The Bank considers the consideration of sustainability risks and the main negative effects on sustainability factors to be of relevant importance in the area of investment advice and insurance investment products. Due to the Bank’s focus on ESG issues and with a view to introducing them in a more complete and organic way in its distribution model, Sparkasse has launched a project aimed at introducing and assessing the Bank’s preferences regarding sustainable investments and the consequent risks in the provision of investment advice and insurance investment products.

 

Policy Information on the Integration of Sustainability Risks (Art. 3 of the SFDR)

At present, the Bank does not have specific indicators to represent and quantify the sustainability risks of the financial instruments and insurance investment products it advises on. Aware of the importance of assessing this new type of risk, the Bank, as part of the above-mentioned project, has initiated a series of internal assessments and analyses in order to acquire, in the near future, reliable and accurate indicators through which it will be able to assess the sustainability risks of the financial instruments and insurance investment products it recommends. Upon completion of this process, the Bank will be able to integrate sustainability risks within the advisory service provided on the basis of metrics made available to it by data providers that will be integrated into its systems.

It should be noted, however, that as of today, sustainability risks are partially and indirectly considered within the risk metrics used by the Bank in relation to credit risk and market risk, which to a certain extent incorporate them. This means that although the Bank has not adopted specific indicators to classify financial instruments and insurance investment products from the point of view of sustainability risks, it does assess, albeit indirectly and partially, this type of risk within the other risks considered to date.

In the first application phase of the requirements of the SFDR, therefore, the Bank relies on the indicators it already has in its possession, also with a view to considering sustainability risks. However, as part of the ESG project that has been initiated, the Bank will in the near future integrate sustainability risks into its risk management policies.

 

Transparency on the integration of sustainability risks in remuneration policies (Art. 5 SFDR)

The Bank is sensitive to and recognises the importance of sustainability issues and the consideration of sustainability risks also in the provision of investment advice as required by the SFDR.

It should be noted that the qualitative objectives, as set out in the Supervisory Provisions, e.g. compliance with legal and supervisory regulations, together with the entry criteria related to capital strength and liquidity, are generally within the scope of sustainability.

In order to integrate sustainability risks in a more punctual manner within business and management strategies, defining, where appropriate, also quantitative indicators, the Bank is preparing a specific plan of action, following which the relative aspects will be declined at all levels (investment services, credit policies, etc.). In this perspective, the remuneration policies for the year 2022 may also be reviewed.

 

No consideration of negative impacts on sustainability (Art. 4 of the Regulation)

The Bank does not consider the negative impacts of investment decisions on sustainability factors in its recommendations on investment advice and insurance investment products.

This choice is motivated by a number of reasons such as:

  • the absence of definitive specific sustainability risk indicators;
  • the incompleteness of the regulatory framework implementing the SFDR.

These circumstances prevent the Bank from making an adequate assessment of the negative impacts of the advice given on sustainability factors.

However, the Bank is aware of the need to provide the advisory service with due consideration for environmental, social and governance factors, and, as part of its ongoing ESG project, has initiated a process aimed at updating its systems and acquiring data in order to be able in the near future to make the assessment of negative effects on sustainability factors an additional component of the service provided.