Sustainable Finance Lobbying Overview: abrdn, formerly Standard Life Aberdeen, appears to have been fairly actively engaged on sustainable finance policy during 2018-2021, with mixed positions. A significant proportion of this engagement has been via subsidiary Aberdeen Standard Investments.

Top-line Messaging on Sustainable Finance Policy: abrdn has stated support for the “goals of the Paris Agreement to limit global warming to well below 2°C, ideally 1.5°C, by 2050”, with subsidiary Aberdeen Standard Investments calling for action to achieve net-zero by 2050 in the UK. abrdn has also offered broad support for sustainable finance regulations to “scale up flows of low carbon finance”. In 2019, Aberdeen Standard Investments stated support for the EU's Action Plan on sustainable finance on its website.

Position on Regulated Corporate ESG Disclosure: Aberdeen Standard Investments supported the mandatory implementation of the TCFD recommendations into reporting frameworks in response to the UK's Financial Conduct Authority (FCA) in 2019 In 2021, abrdn supported mandatory implementation of TCFD-aligned disclosures for asset managers and asset owners in response to the UK’s FCA, although stated concerns around data availability for some of the proposed requirements, such as Scope 3 emissions. Also in 2021, abrdn supported mandatory implementation of the TCFD as part of a joint statement to governments and in response to the UK government in 2020 and 2022. In another joint statement in 2022, abrdn further advocated for disclosure on nature-related impacts and dependencies by 2030 under the COP15 framework. In 2022, abrdn stated [1021917 broad support for climate and sustainability disclosures proposed by the ISSB, which are likely to inform government policy.

Position on Taxonomies: In response to the UK’s FCA consultation on green finance in 2019, Aberdeen Standard Investments referred to their support of the EU's taxonomy, suggesting it should be expanded to cover wider social and governance aspects but that it could be used to develop similar frameworks for wider application. In response to the European Commission in 2020, however, it opposed the expansion of the EU taxonomy to cover environmentally harmful activities.

Position on ESG Standards, Labels & Benchmarks: On its website in 2019, Aberdeen Standard Investments stated support for the EU Green Bond Standard. In response to the European Commission on the Renewed Sustainable Finance Strategy in 2020, abrdn did support verification mechanisms for the EU GBS but again appeared to express concerns around its stringency. In response to the UK’s FCA on investment labels, abrdn suggested a more flexible approach to labeling transition activities and weaker levels of alignment with the UK taxonomy.

Position on Integrating ESG into Investor Duties In a 2019 website article, Aberdeen Standard Investments appeared to support the DWP’s proposal for trustees to include disclosures on the extent of ESG integration. However, in response to the ESA’s Sustainable Finance Disclosure Regulation (SFDR) consultation on investor ESG disclosure in 2020, abrdn argued for a more flexible approach. In response to the Commission in 2020, abrdndid not support incorporating adverse ESG impacts into fiduciary duty and suggested that asking retail clients about sustainability preferences should not be regulatoryIn response to the UK’s FCA on the Sustainability Disclosure Requirements in 2022, abrdn stated concerns around the availability of data for Principal Adverse Impact (PAI) disclosures.

Lobbying Transparency: abrdn has stated it is engaging with policymakers on sustainable finance, but with no further details of specific policies it is engaging over or the outcomes.. abrdn has listed its roles within some of the trade associations it is a member of, but with no further details on indirect influence governance.