This document describes how Life Investment manages sustainability risks within the framework of the Sustainable Finance Disclosure Regulation (SFDR, Regulation (EU) 2019/2088). Sustainability risks are events or circumstances relating to environmental, social or governance (ESG) factors which, if they occur, could have a material adverse effect on the value of an investment or financial product.
1) Scope
This policy applies to all advisory and intermediary activities carried out by Life Investment in relation to insurance and credit products with an investment component. If the firm does not take sustainability risks into account for a particular product, this will be explicitly stated in the pre-contractual information provided to clients.
2) Integration of sustainability risks
– When selecting products or providers, Life Investment examines whether information is available on ESG risks and how these are managed.
– If an insurer or credit institution provides sustainability information, this is taken into account in the advice given to clients.
– If no information is available, the client is informed of this and the product is assessed on the basis of the other financial and contractual criteria.
3) Limitations
As Life Investment relies on information provided by insurers and credit institutions, the extent to which sustainability risks can be integrated is limited by the availability and quality of this information. The firm does not carry out its own independent ESG analysis.
4) Transparency towards clients
– Clients receive pre-contractual information on how (where applicable) sustainability risks have been taken into account in the advice.
– If sustainability risks have not been taken into account, this is explicitly stated.
– The information is presented in clear and understandable language.
5) Periodic review
This policy is reviewed annually and, where necessary, amended to reflect changes in legislation, guidelines from the FSMA or the European supervisory authorities (ESMA, EIOPA).
Practical example
Example: When advising on an investment-linked life insurance policy, Life Investment checks whether the insurer indicates in the product documentation how climate risks are taken into account. If this is the case, it is discussed with the client. If such information is missing, this is also communicated so that the client can make an informed choice.