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 European Fund and Asset Management Association (EFAMA) is actively engaged in the EU on sustainable finance policy, while not supporting stringent regulatory intervention.
Top-line Messaging on Sustainable Finance Policy: EFAMA has stated support for the role of the finance industry in meeting EU climate goals, but has not clearly stated the need for financial sector reform. In comments on the European Commission consultation on the Renewed Sustainable Finance Strategy in 2020, EFAMA suggested policy should focus on positive action but not restrict negative action. EFAMA did, however, state strong support for the Renewed Strategy during 2021.
Position on Taxonomies: In 2018-19, EFAMA was particularly engaged on the taxonomy regulation, stating support for the policy but arguing that its use in disclosure requirements should be voluntary, that it should be only applicable to products marketed as sustainable rather than the whole market, supporting a delay to implementation and arguing for the weakening of thresholds that would define what investments can be considered sustainable. In consultation responses to the Commission in 2020, EFAMA opposed the creation of a taxonomy of environmentally harmful activities and appeared to support the weakening of the forestry criteria under the taxonomy. However, in a policy position and response to the Platform on Sustainable Finance in 2021, EFAMA supported the expansion of the taxonomy to cover transition activities but emphasized that the taxonomy should be supporting companies to transition and avoid blacklisting.
Position on ESG Standards, Labels & Benchmarks: In consultation responses in 2019, EFAMA argued for weaker exclusion thresholds for fossil fuels in the EU’s proposed labels for climate benchmarks. In consultation responses to the JRC in 2020, EFAMA argued for weaker green criteria and exclusion thresholds under the EU’s Ecolabel. In comments to the European Commission’s Renewed Strategy in 2020, EFAMA did not appear to support suggestions for new ESG labels or benchmarks.
Position on Integrating ESG into Investor Duties: In 2018-19, EFAMA argued for weaker regulation on the inclusion of ESG issues across a range of policies including MiFID II, Solvency II and IDD. EFAMA also supported a delay to regulation on disclosure of the integration of ESG issues into the investment process in a meeting with the Commission in 2019 and again in a letter to the Portuguese council presidency in 2020. In response to the ESA’s consultation on Sustainable Finance Disclosure Regulation (SFDR) in 2020, EFAMA argued for a less prescriptive approach, including a reduced number of mandatory indicators. In response to the Commission in 2020, did not appear to support further action to incorporate adverse ESG impacts into fiduciary duty.
Position on Regulated Corporate ESG Disclosure: Since 2019, EFAMA has been highly supportive of the need to improve regulated corporate ESG disclosure. In 2020, EFAMA advocated for an ambitious update to the Non-Financial Reporting Directive (NFRD) in a joint statement to policymakers and in response to a European Commission consultation. In 2021, EFAMA reiterated its strong support for the Corporate Sustainability Reporting Directive (CSRD), the successor of the NFRD, however, it did urge legislators to consider the exclusion of financial products and a waiver for asset managers disclosing under other regulations. In response to the first set of technical standards being developed by EFRAG in 2022, EFAMA stated broad support but cautioned against some of the specifics on the disclosure standard requirements. During 2022, EFAMA has also been strongly supportive of an ambitious approach to the global sustainability standards developed by the International Sustainability Standards Board (ISSB), such as arguing for the inclusion of double materiality.
Lobbying Transparency: EFAMA is transparent about some of its positions on sustainable finance policies, with full details of activities to influence these policies. It has also fully transparent about its membership, including companies and individuals in the executive and key committees.