EU Action Plan triggers sustainable consequences

Today’s TextileFuture Newsletter consists of one feature only and in its nucleus it is about sustainable investment, the new rules of the EU and the resulting consequences, based upon a paper of J. Safra Sarasin Bank.

Since everybody has to follow the trend to invest into sustainability as a company and also as a private investor, we feel that this reading of an experienced bank and their specialists will deliver the best answers.

Here starts the regarding expertise:

A new market standard signals the emergence of a distinct product class.

Jan Amrit Poser Chief Strategist and Head Sustainability at J.Safra Sarasin Bank

By guest author Jan Amrit Poser Chief Strategist and Head Sustainability at J.Safra Sarasin Bank

Dear Reader,

When we started to introduce the very first sustainable mandates 32 years ago,  this  was still a niche area of investment.  Back  then, there was plenty of freedom in configuring in- vestment portfolios. In the wake of the chemi- cal spill  at  Schweizerhalle  near  Basel,  which set the ball rolling for our sustainability jour-

ney, we put the emphasis initially on the «E» in ESG – the environment. To begin with,  exclud- ing controversial investments  from  portfolios was the preferred approach, as well  as screen- ing companies’ performance in the area of eco- efficiency. We then gradually expanded our analysis to include social (S) and corporate gov- ernance (G) factors. Climate data and the com- mitment to sustainable development  goals (SDGs) were subsequently incorporated aswell, until we had fully developed our current sophisticated invest- ment process combining our Sustainability Matrix©,  ESG  integra- tion and active ownership.

The need to finance the climate transition…

Since then, sustainable investments have seen explosive growth. At the start of the 2010s, discussions still centred on whether an approach based on ESG criteria was positive or negative for investment performance. Some of the confusion was created because many providers had a different understanding of sustainability and applied it in different ways to portfolios. By the end of the decade, however, it was clear not only that sustainability has no consistent negative impact on performance, but that ignoring ESG risks such as climate change could be extremely detrimental. It had also become obvious that the climate transition would require massive capital spending.

So regulators became involved. The European Union has passeda package of measures in the form of an Action Plan on Financing Sustainable Growth. This plan merits a number of superlatives. Itis probably the fastest adopted EU reform. It is also one of the most efficient. The reason is that it starts with the already highly regulated financial sector. So, instead of regulating every single sub-industry, it introduces only a few paragraphs into the regulationsgoverning the financial sector. As the financial sector is the owner of the economy and through its stewardship, it is the biggest lever that can be used to convince companies to report and consider ESG risks.

…has far-reaching consequences for sustainable investments

This has two far-reaching consequences: the first is that the time of «free-style» approaches to sustainable investments is over. Admittedly, the initial focus is only on the disclosure of sustainability risks and of the ESG approach for integration in the investment process. But nobody should have any illusions: self-assessment and the obligation to clarify client preferences will automaticallyincrease demand for external verification and ESG labels. A general market standardwill therefore soon be established. The second consequence is the emergence of a new product class.

With the introduction of a category of investment products with clear sustainability objectives, customers at last know what they are getting. Instead of nebulous ESG ratings, information is now provided on what percentage of portfolio companies’ earnings support the energy transition, for example, and how long it will take to reduce the portfolio’s carbon footprint to net zero. Substantial capital investment is required to achieve the climate transition. The emergence of a new class of financial products geared towards sustainability goals will support this objective and redefine sustainable investing.

Best wishes,

Jan Amrit Poser, Chief Strategist and Head Sustainability

Three pillars supporting sustainable investment: SFDR, MiFID II amendment and ESG labels

By guest author Nico Frey

Measures introduced under the EU Action Plan on Financing Sustainable Growth include the requirement to disclose sustainability risks and to clarify clients’ sustainability preferences. Although they are complimentary, these  measures  still need to be supported by ESG labels from the market.


The purpose of the Action Plan on Financing Sustainable Growth published by the EU Commission in March 2018 is  to reorient  cap- ital flows  towards a  sustainable economy,  place  greater emphasis on sustainability risks in financial analysis and improve the trans- parency of sustainable financial products. Two key components in- clude  the  Sustainable  Finance   Disclosure   Regulation   (SFDR), which recently came into force, and the amended of Markets in Fi- nancial Instruments Directive II (MiFID II), which introduces the ob- ligation to clarify clients’ sustainability preferences.

SFDR – disclosure is not the same as rating

Obligations regarding the reporting of sustainability risks  came into force in March 2020. They require financial institutions to dis- close and explain – both at the company and product level – whether, and how, sustainability criteria are considered in invest- ment decisions and how the incentive structures are set. The goal is to ensure investors have access to transparent information.

At the product level, SFDR proposes three possible variants, based on the relevant articles in the regulation:

Article 6: Products without a sustainability promise do not have to include any sustainability criteria.  However,  an  explanation  must be provided why financial sustainability risks are not considered. Article 8: Products with a sustainability commitment must disclose exactly how the sustainability  risks  and  characteristics  are  in- cluded and how they compare to the benchmark (if relevant).

Both the fulfilment of the sustainability criteria in Article 8 products and the fulfilment of the sustainability objectives of Article 9 prod- ucts must be reported regularly. It is important to understand that the distinction made in  the  SFDR only  provides a limited explana- tion of the  sustainability quality  of the underlying products. Nor is this the objective of the regulation. The sole purpose is to create greater transparency by introducing the obligation of disclosure. Article 8 financial products, for example, may have very different sustainability qualities and  risks.  Nor  is  there  any  guarantee  that an Article 9 product has more of a sustainability impact in the real world than an Article 8 product.

MiFID II – client’s sustainability preferences are paramount

The amendments to MiFID II proposed by  the  European  Commis- sion focus on the clients’ sustainability preferences  and  how  they can be accommodated. The aim is to extend the high standard of investor  protection  to  sustainability  in  investment  strategies  and to encourage demand for sustainable investments.  In  concrete terms, the amendment requires financial service providers to ask customers about their sustainability preferences  and  to  recom- mend suitable products on this basis. Although they can still rec- ommend products with no sustainability promise, it must be  clear that these do not satisfy the client’s sustainability preferences.

However, the  regulations  do  not  specify  exactly  what  the  phrase «suitable from a sustainability perspective» means. Although the amendments to MiFID II refer to the  EU taxonomy  and  SFDR, they are only references to suitable instruments, not to how the result is to be interpreted. Scope for interpretation is therefore  deliber- ately left open for national players. This is also known as «target market compatibility», which needs to be defined. This requires the involvement of national regulatory authorities  and  associations which define target market compatibility and thereby provide a framework for sustainability quality. We expect this in turn to in- crease the importance of sustainability labels, which  are  presum- ably the simplest way for financial service providers to meet the different  national  standards  for  sustainability  quality.   Because they allow the investor straightforward comparability, we think sus- tainability regulations will significantly boost demand  for  ESG  la- bels.

Article 9: Products must explicitly pursue a sustainability goal. In addition to the integration of sustainability risks, the objective and the adaptation path must also be presented (if relevant, also com- pared to a benchmark).

Sustainable Investment Objectives – What do  clients get

By guest author Robin Rouger

The world of sustainable finance is evolving and growing fast. More and more investors are looking to add an extra-financial dimension to their investments by going beyond the search for yield and focusing on strategies that have an impact. The EU Action Plan has created a new product class.

ESG approaches have mostly focused on operational excellence… Sustainable investments have significantly evolved in recent years. Starting  with  simple  exclusion  criteria,  responsible  investor  used to select investments according to their personal  values  and  be- liefs. The  development  of  best-in-class ESG  approaches helped  to tilt portfolios towards companies that are better equipped to deal with sustainability risks, while the integration of ESG factors into financial models has helped investors to spot the hidden opportu- nities and the additional upside for share prices.  In  the  last  ten years, active ownership approaches have been added  to  ESG-re- lated strategies in order to lead a constructive dialogue with companies and to encourage them to improve their environmental and social key performance indicators. In recent years, clients have in- creasingly asked asset managers to fulfil a purpose with their investments. While the emergence of ESG and sustainability report- ing has helped to lay out the characteristics  of portfolios,  ESG rat- ings are increasingly perceived as a black box. Instead of numbers, investors strive to understand the positive impact they have on promoting a path to a more sustainable future.

…but investors have begun to ask what they are achieving

Tilting portfolios towards ESG is insufficient at a  time when human- ity faces planetary boundaries. This concept, invented by Johan Rockström at the Stockholm Environment Institute, implies that humanity has to bend the temperature curve and biodiversity loss drastically to avoid trespassing these boundaries with catastrophic consequences. Policy-makers are therefore rushing to derive science-based targets for the global economy to ensure sustainable development. The recent announcements by the G7 regarding cli- mate targets and the  UN  Conference  in  Kunming  on  Biodiversity are  documenting  these  endeavors.  Science-based   targets   can then be broken down to each sector and defined for individual com- panies. For their part, investors can set sustainability objectives at a portfolio level in order to redirect financing from polluting to less polluting activities and companies. The EU Action  Plan  foresees «sustainable  objectives»  for  funds The European Commission has shown its determination to become the world’s leader in sustainable finance by proposing the EU Ac- tion Plan for Financing Sustainable Growth. The plan includes con- crete measures and proposes major regulatory changes to redirect financial flows towards the transition to a low-carbon and sustain- able economy. Moreover, it aims to encourage investors to integrate sustainability factors into risk management in order to promote a stable financial system. Asset managers and banks are pivotal for transition finance as they invest the capital of institutional and private clients. In order to promote sustainable development, the EU Sustainable Finance Disclosure Regulation (SFDR)  has  created a completely new product class.

«Sustainable investments» re-defined

Strategies, which are classified under SFDR Article 9, must have a pre- defined sustainability objective. The objective should be clear and measurable, building a track record over time. To ensure that strategies are aligned with the objectives of Article 9, there are several pos- sible ways. One objective we have set for certain funds is to decarbon- ize portfolios over time by reducing the carbon footprint by 7% on an annual basis to achieve carbon neutrality by 2035. Another set of ob- jectives is to target a certain level of sustainable investments in the funds to promote the climate transition, biodiversity or the UN Sustain- able Development Goals (SDG). To this effect, the EU has also rede- fined what it sees as a sustainable investment in Article 2(17) SFDR. Sustainable investments refer to the share of a company’s revenues and capital expenditures aligned with a pre-defined Taxonomy of green and social activities. A fund complying with Article 9 should tar- get a certain level of sustainable activities embedded in the companies it invests in.

Rising demand for funds with sustainable objectives

The creation of this  new  product  class  of  outcome-oriented  funds is meant to spur financing for companies,  which  provide  solutions for the energy transition and which avoid significant harm to other sustainability goals. While  only a minority  of all  funds worldwide  is in line with the new Article 9 requirements, it is already clear that investors have a heightened interest in funds where they can un- derstand and see «what they get». We expect this new product class to thrive in the next years not least because the opportunities of the climate transition provide attractive returns as well.

The true meaning of the principal adverse impacts in the EU Finance Disclosure Regulation

By guest author Sebastian Wiesel

The EU’s Sustainable Finance Disclosure Regulation (SFDR) imposes a series of demanding obligations on investors. What at first sight may seem to represent ex- cessive reporting requirements, actually make sense on closer inspection. The new obligations simply reflect what we, as pioneers of sustainable investments, have been practising already for a long time.

Sustainable asset managers must disclose more data… The first parts of the European Sustainable Finance Disclosure Regulation (SFDR) came into force on 10 March  2021.  SFDR  im- poses extensive transparency obligations on asset managers who classify their products as sustainable.  The  Principal  Adverse  Im- pacts (PAIs) of investment decisions on  the  environment and  soci- ety play a key role within the SFDR. The SFDR obliges investors to disclose these impacts. After very intensive political  discussions within the EU, the relevant technical regulatory standards were published at the beginning of this year. They specify in detail which sustainability indicators are to be used in an annual PAI report. The report is due for the first time on 30 June 2022 and is then to be delivered on an annual basis. The report is to be prepared at the organisational level and  must  present  the  PAIs  of  all  investments in aggregate form. A distinction is made between a core of 18 man- datory and  30  additional  voluntary  sustainability  indicators.  At least 2 of the 30 voluntary indicators must be selected. The 18 mandatory indicators are roughly subdivided into the areas of cli- mate, biodiversity, water, waste, social affairs, employees, human rights and corruption. The reporting format is specified in detail.

…but does that entail a lot of extra work?

New regulations often trigger a type of Pavlov’s reflex. Critics grum- ble that collating data points apparently selected at random, the production of detailed reports and the extra burden on portfolio managers having to perform additional analyses all require far too much extra work. Viewed dispassionately, however, these new ob- ligations are not only necessary, but also self-evident. On the one hand they are necessary because the SFDR is nothing more than a disclosure  regulation.  It  allows  asset  managers  to   self-classify their sustainable products and they can use any approach without verification. Therefore, the reporting of  certain data points in line with ESG market standards is needed  to get a basic  picture of  the ESG quality of the portfolios. On the other hand  the disclosure  of PAIs is self-evident because they present something  that  sustain- able asset managers have always done (or should have done). For more than 30 years, J. Safra Sarasin has consistently integrated sustainability into every step of the investment process. Many in- dicators have already been a direct or indirect part of our analysis, portfolio construction, active ownership and  reporting  for  quite some time.

PAIs are an integral component of the JSS SAM investment process Exclusion criteria: The PAI report must show various mandatory sustainability indicators, including  the  percentage  of  companies with controversial weapons and  the  proportion of  companies that do not adhere to the principles of the UN Global Compact. These investments are principally excluded in the context of our  invest- ment policy.

Positive ESG screening: J. Safra Sarasin’s ESG  rating  lies  at  the heart of the sustainable investment process. This comprises a host of key indicators, partly encompassing the PAIs. They include, for example, the share of non-renewable energy consumption by com- panies or the amount of toxic waste produced, as well as the num- ber of production sites in biodiversity-sensitive areas.

Active ownership: The three themes  that  J.  Safra  Sarasin  focuses on in dialogue with investee companies and in the proxy voting are climate change, biodiversity and human rights. All three factors are part of the PAIs.

ESG client reporting: As an integral step of the investment process, the carbon footprint and CO2 intensity  are  routinely  reported, among other things.

In preparation for the SFDR, J. Safra Sarasin will comfortably meet its disclosure obligations and welcomes the additional reporting required.

Transparency at Bank J. Safra Sarasin

Sustainable investment becomes even more transparent

By guest author Benjamin Gränicher

J. Safra Sarasin Sustainable Asset Management follows SFDR transparency requirements for its investment funds. The following overview offers some guidance through the regulatory maze.

As a pioneer in the field of sustainable investments, J. Safra Sara- sin Sustainable Asset Management fully supports the transpar- ency initiatives introduced under the SFDR.  For over 30 years now, our investment approach has embraced ESG  criteria. We  welcome the provision of additional standardised information for our inves- tors that enable more efficient decision-making for sustainable in- vestments.

All JSS sustainable funds are classified as Article 8 Our diverse range of sustainable funds with a strong track record over many years has already been classified as Article 8 funds. This means we promise our investors that our funds «promote environ- mental and social characteristics»,  as the  technical  jargon puts it. This will come as no surprise to our long-term investors. For some time now we have been pursuing an investment approach that in- tegrates sustainability criteria in every stage of the investment pro- cess: exclusion criteria for controversial business practices and activities, our tried and tested Bank J. Safra Sarasin Sustainability Matrix for rating of

ESG risks, the  identification of  ESG  opportuni- ties by our  portfolio  managers  during  the  investment  analysis stage, and  active  ownerships  through  shareholder  engagement with companies and voting.

This involves over thirty strategies in total, including funds from all asset classes and with different characteristics. Examples include the broadly diversified equity fund JSS Sustainable Equity – Global Dividend, specific bond funds such as JSS Sustainable Bond – Emerging Markets Corporate IG, or thematic funds such as JSS Sustainable Equity – Future Heath.

More strategies reoriented towards sustainability

We are working to incorporate our sustainable  investment  exper- tise in more and more of our products. With this in mind, we have decided to apply our sustainability philosophy to more funds  and align them with Article 8. This step further expands the selection of sustainable products. It  gives  sustainably  minded  investors  access to niche strategies that are difficult to access, such as emerging- market or subordinate bonds. This extension of potential portfolio components helps broadly diversified, sustainable investors to im- plement the same strategies as in conventional portfolios.

Even more impact – Article 9

Any investor keen to focus on more pronounced long-term trends should take a look at Article 9 funds, which have an explicit sus- tainability goal. At Bank J. Safra Sarasin these include:

•             JSS Sustainable Green Bond – Global

•             JSS Sustainable Equity – Global Climate 2035

•             JSS Sustainable Equity – Green Planet

•             JSS Sustainable Equity – SDG Opportunities

The common characteristic of all these funds is that the underlying trend requires enormous capital investment. To mitigate climate change or achieve the Sustainable Development Goals, it is essen- tial to reorient existing companies and invest in businesses that offer sustainable solutions.

Climate promise only for Article 8 funds initially

In 2020 the Asset Management  arm  of  Bank  J.  Safra  Sarasin pledged to make all its portfolios carbon neutral by 2035. By sign- ing up to the Net-Zero Asset Managers Initiative this year, we have underscored our commitment to climate protection.  The  integra- tion of net-zero targets automatically imposes climate goals on vir- tually all funds concerned. To provide clear guidance for our inves- tors, however, we make a distinction between funds explicitly ori- ented to long-term trends aligned with the SFDR and «normal» ESG funds. Our climate  promise  is  therefore  independent  from  the SFDR goals of our funds. Investors can find out more about the growing number of strategies that have a  climate goal in  our Cli- mate Policy published on the Bank’s website.

News from the Sustainable Investment Research:

Sustainability Rating Reviews in the 2nd Quarter 2021

Lerøy – reducing the footprint on ocean ecosystems

Lerøy is a Norwegian seafood producer. The Group’s core business is the  production  of  salmon  in  fish farms. Fish plays a key role for food security. It is a primary source of protein and essential nutrients and

a low-carbon-emitting alternative compared to meat. Already many years ago, Lerøy has phased out the use of all antibiotics in their fish farms for their third-party certified salmon (96% of revenue). Furthermore, the company is reducing the dependency  on fish in their feedstock. While Lerøy is currently mainly replacing fish feed- stock by soy from deforestation-free sources, they are also consid- ering more innovative ingredients like microalgae or insects to fur- ther alleviate the pressure on the ocean ecosystem. Lerøy has an above-average sustainability rating and is thus part of our Best-in- Class ESG universe.

Stantec – ESG leader with enhanced SDG revenue focus

Stantec is an American service provider in infrastruc- ture and facilities with services such as engineering, architecture, environmental sciences, project man- agement and design, commissioning, maintenance and remediation. The  company  operates  through  five  business units (Infrastructure, Water, Buildings, Environmental Services and Energy & Resources) with revenue shares  between  28 %  and  13 % per unit. Stantec has 22’000  employees,  350  offices  and  is  globally active with over 80 % in revenues from North America. The com- pany is one of the global leaders in sustainability both from an operational risk and an opportunity perspective. The company has positioned itself in the very centre of many sustainability-linked megatrends such as urbanisation, climate change and water. The recently published sustainability report shows not only an encom- passing,  science-based  net-zero  carbon  target  for  2030,  but  also a technically advanced revenue mapping to the UN Sustainable Development Goals, resulting in a revenue share of 49% (conser- vatively mapped). Therefore, Stantec deserves not only a JSS ESG A-Rating and  is part of  the Best-in-Class ESG universe,  but we also see the company as a green leader with its high share of EU Tax- onomy aligned Green revenues.

 TSMC – Leadership in Water Stress Management

Taiwan Semiconductor Manufacturing  (TSMC)  is  one of about ten Taiwanese companies that dominate the global computer chip industry. 90% of all  microchips are running dangerously low. In this context we highlight TSMC’s global and regional leadership in water stress management. The company ranks 2nd (out of 13) locally and 4th (out of 80) globally. In 2020, TSMC launched a program to build a plant capable of treating industrial water for reuse in chip making. This would be the world’s first. The plan is to ultimately meet half of the company’s daily need for water for chip output. TSMC has a top-notch sustainability rating and is part of our Best-in-Class ESG universe.

Avangrid – sustainability role model with a high SDG exposure Avangrid is a renewable energy and utility company. The Company operates through two segments: Net- works and Renewables. The Networks segment in- cludes all the energy transmission and distribution ac- tivities, and any other regulated activity originating in New York and Maine,  and  regulated  electric  distribution,  electric  transmission and gas distribution activities originating in Connecticut and Mas- sachusetts. The Renewables segment  owns,  develops,  constructs and operates electricity generation, including renewable and  ther- mal generators, and associated transmission facilities. The Re- newables segment includes activities relating to clean energy gen- eration, mainly wind energy, and trading of electric power from re- newable sources. Given its energy mix, the company has a low en- vironmental risk exposure (electric and gas network and renewable power generation). The company will benefit from growing demand for sustainable energy and is well positioned to achieve the objec- tives of the Paris Alignment. Avangrid is well exposed on SDG 13 Climate action and has a significant EU Taxonomy aligned green revenue share. With its high sustainability rating, it is also part of our Best-in-Class ESG universe.

Important legal information

This publication has been prepared by the Sustainable Investment Research Department of Bank J. Safra Sarasin Ltd, Switzerland, (hereafter«Bank») for information purposes only. It is not the result of financial research conducted by the Bank’s research department. Although it may contain quotes of research analysts or quote research publications, this publication cannot be considered as investment research or a research recommendation for regulatory purposes as it does not constitute of substantive research or analysis. Therefore the «Directives on the Inde- pendence of Financial Research» of the Swiss Bankers Association do not apply to this document. Any views, opinions and commentaries in this publication (together the «Views») are the views of the Sustainable Investment Research Department and may differ from those of the Bank’s research or other departments. The Bank may make investment decisions or take proprietary positions that are inconsistent with the Views expressed herein. It may also provide advisory or other services to companies mentioned in this document resulting in a conflict of interest that could affect the Bank’s objectivity. While the Bank has taken steps to avoid or disclose, respectively, such conflicts, it cannot make any representation in such regard.

Important Legal Information

The Views contained in this document are those of the Sustainable Investment Research Department as per the date of writing and may be subject to change without notice. This publication is based on publicly available information and data («the Information»). While the Bank makes every effort to use reliable and comprehensive Information, it cannot make any representation that it is actually accurate or complete. Possible errors or incompleteness of the Information do not constitute legal grounds (contractual or tacit) for liability, either with regard to direct, indirect or consequential damages. In particular, neither the Bank nor its shareholders and employees shall be liable for the Views contained in this document. This document constitutes marketing material. If it refers to a financial instrument for which a prospectus and/or a key investor/in- formation document exists, these are available free of charge from Bank J. Safra Sarasin Ltd, Elisabethenstrasse 62, P.O. Box, CH-4002 Basel, Switzerland.

Sustainability Rating Methodology
The environmental, social and governance (ESG) analysis of companies is based on a proprietary assessment methodology developed by the Sustainable Investment Research Department of BJSS. All ratings are conducted by in-house sustainability analysts. The sustainability rating incorporates two dimensions which are combined in the Sarasin Sustainability-Matrix®:
Sector Rating: Comparative assessment of industries based upon their impacts on environment and society.
Company Rating: Comparative assessment of companies within their industry based upon their performance to manage their environmental, social and governance risks and opportunities.
Investment Universe: Only companies with a sufficiently high Company Rating (shaded area) qualify for Bank J. Safra Sarasin sustainability funds.
Key issues
When doing a sustainability rating, the analysts in the Sustainable Investment Research Department assess how well companies manage the main stakeholders’ expectations (e.g. employees, suppliers, customers) and how well they manage related general and industry-specific environmental, social and governance risks and opportunities. The company’s management quality with respect to ESG risks and opportunities is compared with its industry peers.
Controversial activities (exclusions)
Certain business activities which are not deemed to be compatible with sustainable development (e.g. armaments, nuclear power, tobacco, pornography) can lead to the exclusion of companies from the Bank J. Safra Sarasin sustainable investment universe.
Data sources
The Sustainable Investment Research Department uses a variety of data sources which are publicly available (e.g. company reports, press, internet search) and data/information provided by service providers which are collecting financial, environmental, social, governance and reputational risk data on behalf of the Sustainable Investment Research Department.
The entire content of this publication is protected by copyright law (all rights reserved). The use, modification or duplication in whole or part of this document is only permitted for private, non-commercial purposes by the interested party. When doing so, copyright notices and branding must neither be altered nor removed. Any usage over and above this requires the prior written approval of the Bank. The same applies to the circulation of this publication. Third party data providers make no warranties or representations of any kind relating to the accuracy, completeness or timeliness of the data provided and shall have no liability for any damages of any kind relating to such data.

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