We have expanded the list of climate policies we assess company engagement with to incorporate land-use related policy, referring to legislative or regulatory measures to enhance and protect ecosystems and land where carbon is being stored. Assessments under this category are currently underweighted in terms of their contribution to the overall company metrics. This weighting will be progressively increased over the next 6 months.
We adjusted the terminology used to describe the queries running down the left-hand side of our scoring matrix and added additional explanatory text to the info-boxes. This has no impact on the scores and methodology. It has been done following user feedback to improve clarity.
Sustainable Finance Lobbying Overview: The Alternative Investment Management Association (AIMA) does not appear to have supported regulatory intervention on sustainable finance.
Top-line Messaging on Sustainable Finance Policy: In EU consultations, AIMA has supported the view that ESG integration should be market-led, has argued against prescriptive regulation and has also suggested that it does consider short-termism to be a significant issue.
Position on Regulated Corporate ESG Disclosure: In 2020, AIMA appeared to support the review of the Non-Financial Reporting Directive (NFRD) including the expansion of the scope to cover more companies. In feedback to the UK’s Department for Business, Energy and Industrial Strategy in May 2021, AIMA supported the mandatory implementation of the recommendations of the TCFD. However, in feedback to the US SEC in June 2022, AIMA supported the proposed climate disclosure rule with some minor objections.
Position on Taxonomies: In feedback to the European Commission’s Technical Expert Group (TEG) in 2019, AIMA argued that the taxonomy should only be applied to products marketed as sustainable, and that it should remain voluntary. In feedback to the Commission in 2020, AIMA opposed the expansion of the taxonomy to cover environmentally harmful activities.
Position on ESG Labels, Standards and Benchmarks: In a response to the UK Financial Conduct Authority (FCA) in January 2022, AIMA stated support for the UK’s Sustainability Disclosure Requirements (SDR) with a number of significant exceptions.
Position on Integrating ESG into Investor Duties: In response to the ESA’s Sustainable Finance Disclosure Regulation (SFDR) consultation in 2020, AIMA argued for a less prescriptive approach, including a reduced number of mandatory indicators. In an article in IPE in 2022, the AIMA head of markets, governance and regulation appeared to advocate for more recognition of derivatives in the regulation. In feedback to the US SEC in 2022, AIMA did not appear to support the proposed rule to enhance ESG disclosures by investors.
In 2020, AIMA did not support the US Department of Labor's rollback which limited fiduciaries' ESG investing, however, it supported certain aspects of the DOL's rollback on voting on ESG issues.
Position on Integrating ESG into Prudential Regulation: In feedback to the European Commission in 2020, AIMA did not appear to support action to integrate climate risk into the macro-prudential framework.
Transparency: On its website, AIMA lacks transparency on its positions, which are accessible to members only. AIMA does not publically disclose its membership.