Posted on: November 4th, 2021
The ‘Sustainability Disclosure Requirements (SDR) and investment labels’ paper that this relates to was published on 3 November 2021, can be found on the FCA website here, starting with the following text:
“We are seeking initial views on new sustainability disclosure requirements for asset managers and FCA-regulated asset owners, as well as a new classification and labelling system for sustainable investment products.(DLAG) as an independent advisor.”
The Treasury (HMT) had previously indicated the creation of the DLAG in their ‘Greening Finance: a Roadmap to Sustainable Investment’ published on 18 October 2021. It was introduced (on page 13) as follows:
Box 6: Sustainable investment labelling regime. The FCA is working closely with HM Treasury on the development of a sustainable investment labelling regime. The labels will help consumers select investment products based on their sustainability characteristics and will be supported by the underlying SDR disclosures. It is envisaged that the labelling regime will cover the spectrum of investment products, classifying them objectively against specified sustainability criteria, and considering a) products’ objectives, policies, and strategies, and b) how their investments are allocated. The FCA intends to publish further detail in an Autumn 2021 Discussion Paper and will set up an advisory forum to help inform the work.
The newly published FCA paper (November 2021) , DP21/4 ‘Sustainability Disclosure Requirements (SDR) and Investment Labels’ can be downloaded directly here:
The paper lists SRI Services as a member of the DLAG and also references the Fund EcoMarket database.
Our work has not yet begun but some initial thoughts – initially drafted rather rapidly from Glasgow – are as follows:
“First and foremost it is an honour and a pleasure to be appointed to DLAG.
I very much hope the work I have been doing in this area for over 25 years will prove useful – particularly the SRI Styles fund classifications we have been running for the last 11 years.
The challenges however will be many and various.
Although some of us have been working to raise the alarm about issues like climate change, habitat loss and inequality for decades, many people are relatively new to such things. The investment community is no different. It comprises people with widely varied opinions who are at different stages in their personal and professional journeys.
This makes it incredibly important to have a regulatory regime that cater for everyone – encouraging, enthusing and enabling those who are newer to the area – and helping leaders to lead and thrive.
We need to both massively increase investment in solutions and solutions companies – and drive rapid change elsewhere.
In order for both to happen – and to maintain and enhance trust – people need to understand what funds and fund managers do, how they operate and their reasons for doing what they do.
We believe effective disclosure and a sound, readily understandable labelling system have key roles to play in making this happen.
My hope is that the DLAG will help put effective regulatory ‘tramlines’ in place, encourage investors to look forward not backward – and direct investment professionals to pay careful attention to both science and the art of well informed and careful communication.
If we can achieve these things we will have helped make both ‘Net Zero by 2050’ and ‘+1.5’ entirely achievable.
I am very much looking forward to collaborating with others on the DLAG and hope that by the spring 2022 reporting deadline we will have laid the foundations for an urgently needed flexible and trustworthy regime.
Time however is not on our side. The race is on.”
Founder SRI Services & Fund EcoMarket
On 3 November 2021, at COP26, Nikhil Rathi (FCA CEO) also gave a speech entitled: ‘A strategy for positive sustainable change’. The speech references many of the recent major initiatives that will shape this area in future (etg IOSCO, ISSB etc).
It also referenced key messages such as: ‘The financial sector can only support the transition effectively if consumers can trust firms to deliver on their promises’.
The speech also references their new ‘strategy for positive change’.