Sustainable Finance Disclosure Regulation

ABOUT US 2° Investing Initiative is a non-for-profit, non-commercial organization based in Paris, London, Berlin and New York City. It is the leading research center on climate-related metrics for financial markets globally, and notably lead the EC-funded project "Sustainable Energy Investment Metrics" (H2020) that aimed at defining scientifically what is a "sustainable investment" in energy-related sectors.

Feedback of "Sustainable Inclusive Solutions" on the proposal for the “establishment of a framework to facilitate sustainable investment" The idea behind the proposal is to encourage green and social investments, ensuring credibility and comparison across the market.

ABOUT US 2° Investing Initiative is a non-for-profit, non-commercial organization based in Paris, London, Berlin and New York City. It is the leading research center on climate-related metrics for financial markets globally, and notably leads most EU-funded research projects on the topic. It regularly produces analysis and policy recommendations on the topic of financial institutions climate disclosures.

WWF European Policy Office welcomes the European Commission’s opportunity to give feedback on the proposal for a regulation on the establishment of a framework to facilitate sustainable investment. It is a positive step of the Commission, consistent with the EU Sustainable Finance Action Plan. We would like to make the following comments to the Commission’s legislative proposal: 1.

The Investment Association (“the IA”) welcomes the opportunity to respond to the European Commission’s proposed Sustainable Finance Package, which is of key importance in the promotion and development of sustainable finance throughout Europe and across the globe.

The Investment Association (“the IA”) welcomes the opportunity to respond to the European Commission’s proposed Sustainable Finance Package, which will be of key importance in the promotion and development of sustainable finance throughout Europe and across the globe.

BETTER FINANCE welcomes this opportunity to comment on the European Commission proposal on the establishment of a framework to facilitate sustainable investment. EU citizens as savers and individual investors are the main provider of long term funding to the EU economy and are mostly by nature long term oriented, as their needs are often long-term ones: pension, home purchase, children education, etc.

REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on the establishment of a framework to facilitate sustainable investment Response from the Zero Emissions Technology and Innovation Platform (ZEP) 1. Introduction ZEP welcomes the opportunity to provide input to the Commission’s proposal to introduce a framework for sustainable finance, recognising that investment in low-carbon technologies and infrastructure…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

BETTER FINANCE welcomes this opportunity to comment on the European Commission’s regulation proposal on disclosure relating to sustainable investment and sustainability risks (amending Directive (EU) 2016/2341).

PGNiG welcomes Commision efforts in establishing framework for sustainable finance. We would like to take this opportunity to encourage Commission to enable gas industry to benefit from this framework as it can provide significant contribution to achievement of the United Nations' Sustainable Development Goals (UN SDG). For more details, please find attached our position on the proposal.

ESBG supports the European Commission’s initiative on promoting sustainable investment products. Sustainable investments are of growing importance in the European Union, which is why European savings and retail banks are addressing the issue in depth.

Encouraging investments in sustainable products is a core element in the strive towards a more sustainable environment. Therefore, BVI is supportive of the European Commission’s Action Plan and the legislative proposals on Financing Sustainable Growth.

Encouraging investments in sustainable products is a core element in the strive towards a more sustainable environment. BVI therefore welcomes the European Commission’s Action Plan and in particular the aim to build a classification for sustainability (“Taxonomy”). A common language and disclosure building on such common language have the potential to facilitate a shift towards a more sustainable environment.

Please see attached file with CDP Europe's feedback. CDP Europe is a subsidiary and part of CDP Worldwide, an international non-profit that drives companies and governments to reduce their greenhouse gas emissions, safeguard water resources and protect forests.

Thank the European Commission for the proposal for a Regulation of the European Parliament and of the Council on sustainable investment reporting and risks to sustainability, amending Directive (EU) 2016/2341, and to give an opportunity to comment on the following issues of a general nature.

Filed in Italian · English published by the European Commission

Comments of the German Bundesverband Alternative Investments e.V. (BAI) on the Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on disclosures relating to sustainable investments and sustainability risks and amending Directive (EU) 2016/2341 COM(2018) 354 final (“Regulation”) as part of the EU Commission’s legislative initiative on “Institutional investors' and asset managers' duties regarding…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Insurance Europe welcomes the opportunity to provide comments on the European Commission proposal for a regulation on disclosures relating to sustainable investments and sustainability risks. Please find enclosed the Insurance Europe position paper, which includes our general and detailed comments on the EC proposal.

Insurance Europe welcomes the opportunity to provide comments on the European Commission proposal for a regulation on the establishment of a framework to facilitate sustainable investment. Please find enclosed the Insurance Europe position paper, which includes our general and detailed comments on the EC proposal.

UKSIF is the membership network for sustainable and responsible investors in the UK. We act as the voice of the UK responsible investment sector and promote long-term investment aimed at sustainable economic development. Our members include many of the UK’s largest pension funds, banks, insurance firms and asset managers, all of whom are committed to long-term sustainable economic growth.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

UKSIF is the membership network for sustainable and responsible investors in the UK. We act as the voice of the UK responsible investment sector and promote long-term investment aimed at sustainable economic development. Our members include many of the UK’s largest pension funds, banks, insurance firms and asset managers, all of whom are committed to long-term sustainable economic growth.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The text mentions that there should be a minimal compliance with social and governance norms. The eight basic principles of the ILO are included in article 13 and this is positive. Governance standards should include the fiscal responsibility – i.e.: responsible tax practices - of the issuers which receive institutional investor investments.

We believe that it would be of interest to link the platform to monitor and exchange good practices on the application of the SDGs created by the EC with the good practices of socially responsible investors who follow the SDGs (pension funds, etc.). For finance to contribute to sustainable and inclusive growth, it is necessary to integrate a minimum of ESG criteria into investment decision making.

Austrian Federal Economic Chamber Abteilung für Finanz- und Handelspolitik Wiedner Hauptstr. 63 | Postfach A-1045 Wien T [phone removed]DW | F [phone removed] E [email removed] W http://wko.at To European Commission DG FISMA Ihr Zeichen, Ihre Nachricht vom Unser Zeichen, Sachbearbeiter Durchwahl Datum FHP/Mag.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Austrian Federal Economic Chamber Abteilung für Finanz- und Handelspolitik Wiedner Hauptstr. 63 | Postfach A-1045 Wien T [phone removed]DW | F [phone removed] E [email removed] W http://wko.at To European Commission DG FISMA Ihr Zeichen, Ihre Nachricht vom Unser Zeichen, Sachbearbeiter Durchwahl Datum FHP/Mag.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

As the global pioneer for standardized ESG integration, SD-M GmbH welcomes the Commission´s legislative proposal on Sustainable Finance and the Commission´s effort to integrate Sustainability in financial markets and investment products. We appreciate the opportunity provided by the Commission to give feedback which can be found in the attached file.

23 August 2018 ICI Global feedback on the European Commission’s proposed regulation on sustainability disclosure ICI Global1 welcomes the European Commission’s effort (Commission) to foster a regulatory framework that encourages the financial system to focus appropriately on the longer-term impact of material environmental, social, and governance (ESG) factors.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

August 23, 2018 Valdis Dombrovskis Vice President for the Euro and Social Dialogue, also in charge of Financial Stability, Financial Services and Capital Market Union European Commission Rue de la Loi 200 Building BERL 1049 Bruxelles/Brussel Belgium RE: European Commission Regulation on disclosures relating to sustainable investments and sustainability risks and amending Directive (EU) 2016/2341 Dear Vice President…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

AEIP supports a balanced approach between the disclosure obligations of market participants and the objectives of the EC Proposal for a Regulation on disclosures relating to sustainable investments Paritarian funds are natural long-term investors, due to the match between the long duration of their liabilities on the one hand, and long-term financing on the other hand.

Sustainable finance is the cornerstone for the success of the Capital Markets Union. The European Association of Paritarian Institutions embraces the EC action and legislative proposals to facilitate sustainable investments and the new standards for an EU green bond.

WWF Germany welcomes the commission's legislative proposal on sustainable finance and the commission's effort to integrate sustainability in financial markets and to channel financial flows towards more sustainable investments. We believe that a sustainable financial market prevents misallocation of capital and supports achieving central targets of the European Union.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Norsk Hydro welcomes the initiatives and legislative proposals aimed at a more coordinated approach to ESG factors in the finance sector. More transparency and harmonization of sustainability evaluations in investments can be a contributor for driving the EU towards a low-carbon economy.

The European Association of Co-operative Banks (EACB), the voice of 3.135 co-operative banks in the EU, welcomes the opportunity to comment on the European Commission’s proposal for a “Regulation on the establishment of a framework to facilitate sustainable investment”.

The Alternative Investment Management Association (AIMA) welcomes the opportunity to provide feedback on what it considers a worthy initiative in promoting sustainable finance on the part of the European Commission (Commission).

Please find attached EFAMA's feedback. EFAMA is the representative association for the European investment management industry. EFAMA represents through its 28 member associations and 62 corporate members close to EUR 23 trillion in assets under management of which EUR 15.6 trillion managed by more than 60,000 investment funds at end 2017.

The Alternative Investment Management Association (AIMA) welcomes the opportunity to provide feedback on what it considers a worthy initiative in promoting sustainable finance on the part of the European Commission. The fundamental principle expressed therein is that increasing ESG investment should be a client driven, rather than regulation driven process.

Comments On the proposal for a regulation on the establishment of a framework to facilitate sustainable investment Register of Interest Representatives Identification number in the register: 52646912360-95 Our reference Ref.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Executive Summary ISDA and AFME support the European Commission’s efforts to enhance transparency and comparability regarding low carbon and positive carbon impact benchmarks. We welcome the draft proposal for a Regulation.

Summary: With this proposed regulation, the EC aims at regulating the construction of benchmark indices that seek to ensure a representation of what a market compatible with a well below 2°C scenario would look like today, in order to protect investors from greenwashing and support the transition to a low carbon economy.

At ABN AMRO we welcome the European Commisions proposal on the establishment of a framework to facilitate sustainable investment. Sustainability is an integral part of business at our bank. Together with our clients we are working on making their real estate more sustainable, we aim to accelerate the transition to the circular economy and we are making sustainable investments mainstream.

AFG decided very early on to fully support the development of responsible investment in France. French asset management companies are fully committed to this approach and are adapting their offering to the concerns of their institutional and private investors by proposing products that entail varying degrees and types of commitment – SRI funds, integration of ESG criteria, shareholder engagement, thematic investing…

AFG decided very early on to fully support the development of responsible investment in France. French asset management companies are fully committed to this approach and are adapting their offering to the concerns of their institutional and private investors by proposing products that entail varying degrees and types of commitment – SRI funds, integration of ESG criteria, shareholder engagement, thematic investing…

· We support the Commission’s view that sustainability and the transition to a low carbon economy is key to ensuring the long term competitiveness of the EU economy. · LSEG is a thought leader in sustainable finance working closely with issuers and investors as a market infrastructure provider.

CONSULTATION RESPONSE MSCI RESPONSE TO THE PROPOSAL FOR A REGULATION AMENDING REGULATION (EU) 2016/1011 ON LOW CARBON BENCHMARKS AND POSITIVE CARBON IMPACT BENCHMARKS MSCI August 2018 AUGUST 2018 MSCI RESPONSE TO THE PROPOSAL FOR A REGULATION AMENDING REGULATION (EU) 2016/1011 ON LOW CARBON BENCHMARKS AND POSITIVE CARBON IMPACT BENCHMARKS | AUGUST 2018 MSCI appreciates opportunity to comment on this consultation and…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

22 City Road Finsbury Square London EC1Y 2AJ Tel: [phone removed] Email: [email removed] Website: www.pimfa.co.uk PIMFA feedback to the European Commission Sustainable Finance Initiative – Proposal for a regulation on the establishment of a framework to facilitate sustainable investment and Proposal for a regulation on disclosures relating to sustainable investments and sustainability risks Introduction: about PIMFA…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

22 City Road Finsbury Square London EC1Y 2AJ Tel: [phone removed] Email: [email removed] Website: www.pimfa.co.uk PIMFA feedback to the European Commission Sustainable Finance Initiative – Proposal for a regulation on the establishment of a framework to facilitate sustainable investment and Proposal for a regulation on disclosures relating to sustainable investments and sustainability risks Introduction: about PIMFA…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Association for Financial Markets in Europe (AFME) is the voice of all Europe’s wholesale financial markets, providing expertise across a broad range of regulatory and capital markets issues. We represent the leading global and European banks and other significant capital market players.

TAXONOMY The PRI welcomes the proposal to establish a framework to facilitate sustainable investment. We believe the taxonomy will create additional demand for and supply of sustainable financial products by simplifying, and as such, enabling, the investment of private capital in economic activity consistent with the EU’s sustainability objectives.

REGULATION ON DUTIES AND DISCLOSURES RELATING TO SUSTAINABLE INVESTMENTS The PRI considers the Commission’s Investor Duties and Disclosures proposal (2016/2341) critical for the success of its sustainability objectives.

The International Association of Oil & Gas Producers (IOGP) is following with great interest developments in the area of sustainable finance and appreciates the opportunity to provide our input at this stage. We are convinced that the following recommendations will contribute to the establishment of a robust, credible, efficient and technology-neutral taxonomy to reach its goal i.e.

The International Association of Oil & Gas Producers (IOGP) is following with great interest developments in the area of sustainable finance and appreciates the opportunity to provide our input at this stage. We are convinced that the following recommendations will contribute to the establishment of a robust, credible, efficient and technology-neutral taxonomy to reach its goal i.e.

BETTER FINANCE welcomes this opportunity to comment on the Commission proposal on low carbon benchmarks and positive carbon impact benchmarks released as part of the Sustainable Finance Action Plan of the European Commission.

Proposal on the establishment of a framework to facilitate sustainable investment We explicitly welcome the measure to introduce a taxonomy for sustainable activities and the proposal for a corresponding regulation. It is of high importance for such a taxonomy that it establishes the criteria needed for the transformation paths for sectors and technologies on a transparent and comprehensible scientific basis.

WWF Germany welcomes the commission's legislative proposal on sustainable finance and the commission's effort to integrate sustainability in financial markets and to ensure a better alignment of capital allocation decisions within the financial system with sustainability objectives and policy targets.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The International Association of Oil & Gas Producers (IOGP) is following with great interest developments in the area of sustainable finance and appreciates the opportunity to provide our input at this stage. We are convinced that the following recommendations will contribute to the establishment of a robust, credible, efficient and technology-neutral taxonomy to reach its goal i.e.

The International Association of Oil & Gas Producers (IOGP) is following with great interest developments in the area of sustainable finance and appreciates the opportunity to provide our input at this stage. We are convinced that the following recommendations will contribute to the establishment of a robust, credible, efficient and technology-neutral taxonomy to reach its goal i.e.

Encouraging investments in sustainable products is a core element in the strive towards a more sustainable environment. BVI (BVI represents the interests of the German fund industry at national and international level. The association promotes sensible regulation of the fund business as well as fair competition vis-à-vis policy makers and regulators.

FESE members organise markets dedicated to sustainable finance and offer products that contribute to sustainable development, facilitate management of climate risk and incorporate carbon reduction in investment strategies, as well as allow the tracking of sustainable companies’ performance. Moreover, FESE members actively engage in the UN Sustainable Stock Exchanges initiative to promote sustainable capital markets.

Please find attached EFAMA's feedback. EFAMA is the representative association for the European investment management industry. EFAMA represents through its 28 member associations and 62 corporate members close to EUR 23 trillion in assets under management of which EUR 15.6 trillion managed by more than 60,000 investment funds at end 2017.

We are writing in our capacity as a Taskforce on Growing a Culture of Social Impact Investing in the UK. Please find attached our response to the consultation on Sustainable Finance Initiative - Regulation on the establishment of a framework to facilitate sustainable investment.

We are writing in our capacity as a Taskforce on Growing a Culture of Social Impact Investing in the UK. Please find attached our response to the consultation on Sustainable Finance Initiative - disclosures relating to sustainable investments and sustainability risks.

We are writing in our capacity as a Taskforce on Growing a Culture of Social Impact Investing in the UK. Please find attached our response to the consultation on Sustainable Finance Initiative - amending Regulation (EU) 2016/1011 on low carbon benchmarks and positive carbon impact benchmarks.

FESE members organise markets dedicated to sustainable finance and offer products that contribute to sustainable development, facilitate management of climate risk and incorporate carbon reduction in investment strategies, as well as allow the tracking of sustainable companies’ performance. Moreover, FESE members actively engage in the UN Sustainable Stock Exchanges initiative to promote sustainable capital markets.

The GBIC welcomes the opportunity to comment on the European Commission's legislative proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL amending Regulation (EU) 2016/1011 on low carbon benchmarks and positive carbon impact benchmarks as regards organisational requirements and operating conditions for investment firms and defined terms for the purposes of that Regulation.

The PRI is a membership organisation of over 2000 global institutional investors, (including insurers, investment managers and advisors) with approximately US $82 trillion in assets under management. Over 1000 of these signatories are based in the Europe. The PRI strongly supports all four of the Commission’s recent regulatory proposals.

BIPAR welcomes the opportunity to comment on the Commission proposal for a Regulation on disclosures relating to sustainable investments and sustainability risks and amending Directive (EU) 2016/2341, as part of a broader Commission’s initiative on sustainable growth. We recognize the need for a concise framework on transparency of sustainability risks and ESG factors towards consumers and the public in general.

BIPAR supports the initiative to establish a framework setting out uniform criteria to determine whether an economic activity is environmentally sustainable, based on which labelling schemes will be further developed at national or EU level.

As official certification body for the Austrian Ecolabel, the Austrian Consumer Association (Verein für Konsumenteninformation – VKI) is also in charge of the Austrian Ecolabel Guideline 49 „Sustainable Finance Products“ – with currently 36 licence holders and 96 awarded funds.

We appreciate the initiative of the European Commission to introduce rules stablishing and governing the provisions of “low carbon” and “positive carbon impact” benchmarks. This allows investors, being interested in climate change related impacts, to make informed investment decisions.

The Alternative Investment Management Association (AIMA) welcomes the opportunity to provide feedback on what it considers a worthy initiative in promoting sustainable finance on the part of the European Commission (Commission).

WWF welcomes the European Commission’s opportunity to give feedback on the proposal for a regulation amending Regulation (EU) 2016/1011 on low carbon benchmarks and positive carbon impact benchmarks to create a new category of benchmarks which will provide investors with better information on the carbon footprint of their investments.

Morningstar welcomes the opportunity to respond to the proposals in the EC Sustainable Finance Initiative. Morningstar’s mission is to help investors reach their financial goals. Because we offer an extensive line of products for individual investors, professional financial advisers, and institutional clients, we have a broad view on the proposals to improve the quality, comparability, and robustness of information…

Morningstar welcomes the opportunity to respond to the proposals in the EC Sustainable Finance Initiative. Morningstar’s mission is to help investors reach their financial goals. Because we offer an extensive line of products for individual investors, professional financial advisers, and institutional clients, we have a broad view on the proposals to improve the quality, comparability, and robustness of information…

FNG position on the establishment of a framework to facilitate sustainable investment In general, FNG welcomes the establishment of a consistent classification system of sustainability, but has some comments: - The classification system must be dynamic and must be reviewed regularly to take into account new scientific, technological and market developments and promote market innovation.

Morningstar welcomes the opportunity to respond to the proposals in the EC Sustainable Finance Initiative. Morningstar’s mission is to help investors reach their financial goals. Because we offer an extensive line of products for individual investors, professional financial advisers, and institutional clients, we have a broad view on the proposals to improve the quality, comparability, and robustness of information…

Forum Nachhaltige Geldanlagen (FNG) (Forum for Sustainable Investment representing members in Germany, Austria and Switzerland) position on the EU Legislative Package on Sustainability Obligations of Institutional Investors and Asset Managers FNG welcomes the enhanced transparency requirements for institutional investors and asset managers.

WWF welcomes the European Commission’s opportunity to give feedback on proposal for a regulation on disclosures relating to sustainable investments and sustainability risks and amending Directive (EU)2016/2341. WWF welcomes the fact that the Commission is moving forward with many of the ‘key actions’ numbered in the EU Sustainable Finance Action Plan, including partly ‘Action 7: Clarifying institutional investors'…

Australian Council of Trade Unions (ACTU) Submission to the European Commission (EC) Proposal for a Regulation of the European Parliament and of the Council on the establishment of a framework to facilitate sustainable investment – COM (2018) 353 Introduction Since its formation in 1927, the ACTU has been the peak trade union body in Australia. There is no other national confederation representing unions.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Australian Council of Trade Unions (ACTU) Submission to the European Commission (EC) A proposal for a regulation of the European Parliament and of the Council amending Regulation (EU) 2016/1011 on low carbon benchmarks and positive carbon impact benchmarks COM (2018) 355 Introduction Since its formation in 1927, the ACTU has been the peak trade union body in Australia.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Federation of German Industries, the BDI, shares the opinion that there is a funding gap in sustainable investment. As outlined in the Action Plan for Financing Sustainable Growth, the capital markets can be stimulated to contribute to better reaching the EU’s climate and energy targets.

Taxonomy: The Nordic Securities Association (NSA) supports the European Commission’s objective to integrate sustainability targets into the European financial markets. The aim of creating an EU taxonomy is to help investors to direct their investments towards economic activities which contribute to the achievement of environmental objectives, while also respecting minimum social and governance standards.

Please find attached our feedback. EFAMA is the representative association for the European investment management industry. EFAMA represents through its 28 member associations and 62 corporate members close to EUR 23 trillion in assets under management of which EUR 15.6 trillion managed by more than 60,000 investment funds at end 2017.

Trade unions believe that ESG criteria should be integrated in a balanced manner in all sustainability indices, including the proposed environmental indices (low carbon and positive carbon impact). The proposed text raises reasonable doubts that this is the case: in the explanatory memorandum it is mentioned "or working conditions", when it should say "and working conditions", since this question is undoubtedly a…

Trade unions believe that ESG criteria should be integrated in a balanced manner in all sustainability indices, including the proposed environmental indices (low carbon and positive carbon impact). The proposed text raises reasonable doubts that this is the case: in the explanatory memorandum it is mentioned "or working conditions", when it should say "and working conditions", since this question is undoubtedly a…

Eumedion´s response to the proposal for a regulation on the establishment of a framework to facilitate sustainable investment (COM(2018) 353 final) Eumedion, representing the interests of 65 Dutch and non-Dutch institutional investors who have more than € 5 trillion assets under management, is in favour of a framework to facilitate sustainable investment.

Eumedion´s response to the proposal for a regulation on disclosures relating to sustainable investments and sustainability risks (COM (2018) 354 final) Eumedion, representing the interests of 65 Dutch and non-Dutch institutional investors who have more than € 5 trillion assets under management, supports the underlying objectives of the proposal but believes that parts of it go too far and can have unintended side…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Eumedion´s response to the proposal for a regulation on disclosures relating to sustainable investments and sustainability risks (COM (2018) 354 final) Eumedion, representing the interests of 65 Dutch and non-Dutch institutional investors who have more than € 5 trillion assets under management, supports the underlying objectives of the proposal but believes that parts of it go too far and can have unintended side…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

See attached document for full policy position. In summary, in its core recommendations IIGCC urges the EU to: 1. Set out a clear, long-term policy framework for the real economy – encompassing energy, transport and industry – backed up by concrete targets and objectives, as a priority issue, to move capital to support a transition to a sustainable low carbon economy. 2.

On 24 May 2018, the European Commission presented a package of measures as a follow-up to its Action Plan on financing sustainable growth. OMV appreciates the opportunity to comment on the proposals. This is a first assessment of these proposals, which will have to be discussed extensively in the process ahead.

On 24 May 2018, the European Commission presented a package of measures as a follow-up to its Action Plan on financing sustainable growth. OMV appreciates the opportunity to comment on the proposals. This is a first assessment of these proposals, which will have to be discussed extensively in the process ahead.

The text mentions that there should be a minimal compliance with social and governance norms. The eight basic principles of the ILO are included in article 13 and this is positive. Governance standards should include the fiscal responsibility – i.e.: responsible tax practices - of the issuers which receive institutional investor investments.

OMV key-priorities for EC consultation on the Sustainable Finance Initiative On 24 May 2018, the European Commission presented a package of measures as a follow-up to its Action Plan on financing sustainable growth. OMV appreciates the opportunity to comment on the proposals. This is a first assessment of these proposals, which will have to be discussed extensively in the process ahead.

We believe that it would be of interest to link the platform to monitor and exchange good practices on the application of the SDGs created by the EC with the good practices of socially responsible investors who follow the SDGs (pension funds, etc.). For finance to contribute to sustainable and inclusive growth, it is necessary to integrate a minimum of ESG criteria into investment decision making.

Trade unions believe that ESG criteria should be integrated in a balanced manner in all sustainability indices, including the proposed environmental indices (low carbon and positive carbon impact). The proposed text raises reasonable doubts that this is the case: in the explanatory memorandum it is mentioned "or working conditions", when it should say "and working conditions", since this question is undoubtedly a…

Mr Olivier Guersent Director General for Financial Stability, Financial Services and Capital Markets Union DG FISMA Rue de Spa 2, Brussels Belgium Swiss Re's response to the EU Commission's consultation on the legislative proposal for a regulation amending "Regulation (EU) 2016/1011 on low carbon benchmarks and positive carbon impact benchmarks" Dear Director General Guersent, Swiss Re welcomes the opportunity to…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The aba (Arbeitsgemeinschaft für betriebliche Altersversorgung e.V., German Association for Occupational Pensions) is the German association for all matters regarding supplementary pensions. Please find our comments on the Commission’s Proposal for a Regulation on disclosures relating to sustainable investments and sustainability risks and amending Directive (EU) 2016/2341 in the attached document.

ALFI has been at the forefront of actively promoting sustainable finance opportunities for asset managers. ‘Responsible Investing’ is a major pillar of the Luxembourg investment fund industry and ALFI firmly believes that asset managers can play a key role in this area.

Finanzplaner Forum (FPF) supports the initiative on fostering sustainable investments, and the EU Commission’s Action Plan with the proposed regulation based on this action plan. The financial industry has a pivotal role in this fundamental change. FPF is a network of qualified and certified financial advisors and planners, who directly serve their clients. It is from this position that our comments are made.

Finanzplaner Forum (FPF) supports the initiative on fostering sustainable investments, and the EU Commission’s Action Plan with the proposed regulation based on this action plan. The financial industry has a pivotal role in this fundamental change. FPF is a network of qualified and certified financial advisors and planners, who directly serve their clients. It is from this position that our comments are made.

ALFI has been at the forefront of actively promoting sustainable finance opportunities for asset managers. ‘Responsible Investing’ is a major pillar of the Luxembourg investment fund industry and ALFI firmly believes that asset managers can play a key role in this area.

FECIF agrees with the general aim of this proposal, i.e. the integration of ESG in disclosures to end-investors. In particular, we appreciate the integration of sustainability risks and sustainable investment objectives both in the decision-making processes by institutional investors and asset managers and in the advisory processes by financial advisors.

Dear Madam / Sir, Österreichischer Verband Financial Planners is pleased to comment on the proposed Regulation COM (2018) 353 final. Please find our comments below: Proposed Regulation on disclosures relating to sustainable investments and sustainability risks COM (2018) 354 final COMMENT Österreichischer Verband Financial Planners (in short OVFP) welcomes and supports any initiative on fostering sustainable…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Dear Madam / Sir, Österreichischer Verband Financial Planners is pleased to comment on the proposed Regulation COM (2018) 353 final. Please find our comments below: Proposed Regulation on the establishment of a framework to facilitate sustainable investment COM (2018) 353 final COMMENT Österreichischer Verband Financial Planners (in short OVFP) welcomes and supports any initiative on fostering sustainable…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The French Asset Management Association (Association Française de la Gestion financière, AFG) is grateful for the opportunity to comment on the Commission’s proposal for a Regulation amending regulation (EU) 2016/20111 (hereinafter the ‘BMR’).

Enagás welcomes this Commission’s initiative and its invitation to provide our opinion on the proposal for a Regulation of the European Parliament and of the Council amending Regulation (EU) 2016/1011 on low carbon benchmarks and positive carbon impact benchmarks. In general Enagás supports the amendments and the text inserted.

EU Sustainable Finance Initiative Briefing Note The Association of Investment Companies (AIC) is the trade association for the closed-ended investment company sector, representing 350 investment companies with £165bn of assets under management. Investment companies are closed-ended collective investment funds whose shares are publicly traded, usually on the main market of the London Stock Exchange.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

EU Sustainable Finance Initiative Briefing Note The Association of Investment Companies (AIC) is the trade association for the closed-ended investment company sector, representing 350 investment companies with £165bn of assets under management. Investment companies are closed-ended collective investment funds whose shares are publicly traded, usually on the main market of the London Stock Exchange.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

DIRECTION DES AFFAIRES FINANCIERES, PRUDENTIELLES ET COMPTABLES DIRECTION DES ASSURANCES DE DOMMAGES ET DE RESPONSABILITE FFA - FEEDBACK ON THE COMMISSION LEGISLATIVE PROPOSALS ON SUSTAINABLE FINANCE AUGUST 16, 2018 1 COMMENTS ON THE PROPOSAL FOR A REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL ON THE ESTABLISHMENT OF A FRAMEWORK TO FACILITATE SUSTAINABLE INVESTMENT All member companies of the French…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

DIRECTION DES AFFAIRES FINANCIERES, PRUDENTIELLES ET COMPTABLES DIRECTION DES ASSURANCES DE DOMMAGES ET DE RESPONSABILITE FFA - FEEDBACK ON THE COMMISSION LEGISLATIVE PROPOSALS ON SUSTAINABLE FINANCE AUGUST 16, 2018 1 COMMENTS ON THE PROPOSAL FOR A REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL ON THE ESTABLISHMENT OF A FRAMEWORK TO FACILITATE SUSTAINABLE INVESTMENT All member companies of the French…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

DIRECTION DES AFFAIRES FINANCIERES, PRUDENTIELLES ET COMPTABLES DIRECTION DES ASSURANCES DE DOMMAGES ET DE RESPONSABILITE FFA - FEEDBACK ON THE COMMISSION LEGISLATIVE PROPOSALS ON SUSTAINABLE FINANCE AUGUST 16, 2018 1 COMMENTS ON THE PROPOSAL FOR A REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL ON THE ESTABLISHMENT OF A FRAMEWORK TO FACILITATE SUSTAINABLE INVESTMENT All member companies of the French…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

I have two suggestions on the proposal for a regulation of the European Parliament and the Council on disclosures relating to sustainable investments and sustainability risks and amending Directive (EU) 2016/2341: 1) with regards to the information to be disclosed in periodical reports (article 7), I suggest a third item is included, at least for institutional investors: "(c) percentage of the investments portfolio…

I have two suggestions: 1) all the definitions adopted in this regulation shall be extended to the banking (lending) market; there's no reason why they are applied only to investments/capitals market, since banks of all sizes all over Europe also have initiatives of "green credit" and regulation on this topic is also missing, so that banks clients (and other stakeholders) can compare their portfolios (the degree of…

• Reformulating Indices is of capital importance in a financial system where the 'benchmark' is the investment reference. Therefore embedding 'ESG considerations in benchmark methodologies could do much to fast-forward towards mobilising the climate investment required to meet the Paris Agreement shared goals of limiting global warming to 2 degrees and adapt to climate change impact.

Aviva Public Ref. Ares(2018)4206722 - 10/08/2018 Aviva feedback on Commission sustainable finance proposals: disclosure and taxonomy Contents A. Context................................................................................................................................................ 2 B.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Aviva Public Ref. Ares(2018)4206681 - 10/08/2018 Aviva feedback on Commission sustainable finance proposals: disclosure and taxonomy Contents A. Context................................................................................................................................................ 2 B.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Division Bank and Insurance of the Austrian Federal Economic Chamber, as legal representative of the entire Austrian banking industry, appreciates the possibility to comment on the above cited proposal and would like to submit the following position: Taking into account our remarks regarding the proposed framework we assess the proposal for disclosure requirements crucial: Hierarchy of implementing sustainable…

The Austrian banking and insurance industry is in favour to support the European Commission`s efforts in the area of climate protection and sustainability. Austrian banks and insurances have always been pioneers in the area of climate protection and sustainability. Hence, we expressly support all political targets for creating a sustainable European economy.

August 2018 NASDAQ comments to European Commission proposals on sustainable finance: - Proposal for a regulation on the establishment of a framework to facilitate sustainable investment - Proposal for a regulation amending Regulation (EU) 2016/1011 on low carbon benchmarks and positive carbon impact benchmarks Nasdaq welcomes the European Commission’s initiative to move forward with measures intended to support the…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

August 2018 NASDAQ comments to European Commission proposals on sustainable finance: - Proposal for a regulation on the establishment of a framework to facilitate sustainable investment - Proposal for a regulation amending Regulation (EU) 2016/1011 on low carbon benchmarks and positive carbon impact benchmarks Nasdaq welcomes the European Commission’s initiative to move forward with measures intended to support the…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The BdB, BVR and DSGV associations support the start made by the European Commission on promoting sustainable investment products. Sustainable investments are of growing importance on the German market, which is why the German banks and savings banks are addressing the issue in depth.

Assogestioni welcomes the growing focus on ESG transparency: we are of the view that an enhanced transparency would contribute to raising awareness among investors and encourage a positive competition among asset managers in the integration of sustainability considerations in their investment choice.

Assogestioni, the Italian asset management association, would like to express its appreciation and support to the Action plan and the proposed legislative action as a tool to achieve a transition toward a more sustainable financial system. As for the specific proposal, Assogestioni regards the definition of a taxonomy as a founding base on which to build a clearer and stronger framework for sustainable investing.

Association française des marchés financiers (AMAFI) is the trade organisation working at national, European and international levels to represent financial market participants in France. It mainly acts on behalf of credit institutions, investment firms and trading and post-trade infrastructures, regardless of where they operate or where their clients or counterparties are located.

Warsaw, 23 July 2018 The position on financing sustainable growth The European Commission has on 08.03.2018 presented the action plan for financing sustainable growth 1 and on 24.05.2018 the proposals for the relevant legislative acts. Both the action plan and the aforementioned legislative proposals are based on the recommendations from the High-Level Expert Group on Sustainable Finance2.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

ANASF agrees with the general aim of this proposal, i.e. the integration of ESG in disclosures to end-investors. In particular, we appreciate the integration of sustainability risks and sustainable investment objectives both in the decision-making processes by institutional investors and asset managers and in the advisory processes by financial advisors.

Finance Watch welcomes the proposal for a Regulation on the establishment of a framework to facilitate sustainable investment. We would like to point out that the message in the recital number 28 should be further clarified. It is important for the Commission to clarify how the consideration of stranded asset risk is going to impact the choice of the criteria for environmentally sustainably activities.

Finance Watch welcomes the EC proposal for a Regulation on disclosure relating to sustainable investments and sustainability risks and amending Directive (EU) 2016/2341. Climate change is the greatest threat to the global financial stability, given its double nature as idiosyncratic and systematic risk.

Finance Watch is glad to provide the following contribution to the public consultation on the EC proposal for a regulation amending Regulation (EU) 2016/1011 aimed at defining low carbon benchmarks and positive carbon impact benchmarks.

In INVERCO´s view, the purpose of these proposals is valued very positively, since to the extent that the capital flows are directed more easily towards activities that positively impact on the fulfillment of environmental, social and governance objectives, the recipients of said financing will conduct their model of business towards these objectives.

In INVERCO´s view, the purpose of these proposals is valued very positively, since to the extent that the capital flows are directed more easily towards activities that positively impact on the fulfillment of environmental, social and governance objectives, the recipients of said financing will conduct their model of business towards these objectives.

The purpose of these proposals is valued very positively, since to the extent that the capital flows are directed more easily towards activities that positively impact on the fulfillment of environmental, social and governance objectives, the recipients of said financing will conduct their model of business towards these objectives.

(1) Amundi agrees that we need to have, at least at the EU level, a common language and understanding of what sustainable investment means. Otherwise national regulators may develop various approaches using different concepts and priorities that would make it impossible for investors to understand and compare.

Please find below the general comments of Amundi and read the attached document for further detail. (1) The application date of the proposed regulation is foreseen 1 year after the date of publication in the OJ. But some RTS and delegated acts are due to be drafted by ESAs within 18 months of the entry into force, i.e, 18 months and 20 days after the publication in the OJ.

(1) In Amundi’s view, the more general aim of introducing ESG references in Benchmarks Regulation (BMR) should appear in the title of the proposed regulation. We suggest the : “…amending Regulation (EU) 2016/11 on low carbon benchmarks, positive carbon impact benchmarks and disclosure by administrators on integration of ESG considerations in the methodology of their benchmarks.” (2) In recital 15, we read that the…

The Advisory Committee of the CNMV has been set by the Spanish Securities Market Law as the consultative body of the CNMV. This Committee is composed by market participants (members of secondary markets, issuers, retail investors, intermediaries, the collective investment industry, etc) and its opinions are independent from those of the CNMV.

The ART Fuels Forum wants to comment to these proposals. ART Fuels Forum brings together European industry and other stakeholders including research and non-governmental institutions for the innovative development and deployment of renewable, sustainable and low carbon fuels for the transport sector (on road, water and at air).

The ART Fuels Forum wants to comment to these proposals. ART Fuels Forum brings together European industry and other stakeholders including research and non-governmental institutions for the innovative development and deployment of renewable, sustainable and low carbon fuels for the transport sector (on road, water and at air).

The ART Fuels Forum wants to comment to these proposals. ART Fuels Forum brings together European industry and other stakeholders including research and non-governmental institutions for the innovative development and deployment of renewable, sustainable and low carbon fuels for the transport sector (on road, water and at air).

Comment of the German Insurance Association (GDV) on the Proposal for a Regulation on disclosures relating to sustainable investments and sustainability risks and amending Directive (EU) 2016/2341 ID-Number: 6437280268-55 Gesamtverband der Deutschen Versicherungswirtschaft e. V.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Comment of the German Insurance Association (GDV) on the Proposal for a Regulation on the establishment of a framework to facilitate sustainable investment ID-Number: 6437280268-55 Gesamtverband der Deutschen Versicherungswirtschaft e. V.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Comment of the German Insurance Association (GDV) on the Proposal for a regulation amending Regulation (EU) 2016/1011 on low carbon benchmarks and positive carbon impact benchmarks ID-Number 6437280268-55 Gesamtverband der Deutschen Versicherungswirtschaft e. V.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Please see the attached file for Swedbank's comments on the key themes relevant to the Commission proposal. Swedbank welcomes the Commission’s proposal for a regulation on the establishment of a framework to facilitate sustainable investment and sees that such a framework could create a solid legal foundation in Union law for the progressive development and market adoption of the taxonomy.

A LEADING ROLE FOR THE FINANCIAL SECTOR The financial sector financial must first recognize that the priority of sustainable finance is to harmonize financial flows with a pathway to lower greenhouse gases and more climate-resilient development, according to the Paris agreement and social expectations. Secondly, the sector must recognize the urgency of the climate change challenge.

Managed Funds Association (“MFA”) welcomes the opportunity to provide comments to the European Commission (the “Commission”) on its proposal for a delegated regulation as regards organisational requirements and operating conditions for investment firms (the “Draft Delegated Regulation”).

BETTER FINANCE welcomes this opportunity to comment on the proposal amending Delegated Regulation (EU) 2017/565 supplementing MiFID II as regards organizational requirements and operating conditions for investment firms and defined terms for the purpose of that directive. Investment firms shall act in accordance with the best interest of their clients.

BETTER FINANCE welcomes this opportunity to comment on the proposal amending Delegated Regulation (EU) 2017/2359 to include the customer’s ESG preferences in the criteria and practical details to be taken into account by insurance intermediaries and insurance undertakings when assessing the suitability of insurance-based investment products for their customers.

AFG decided very early on to fully support the development of responsible investment in France. French asset management companies are fully committed to this approach and are adapting their offering to the concerns of their institutional and private investors by proposing products that entail varying degrees and types of commitment – SRI funds, integration of ESG criteria, shareholder engagement, thematic investing…

The Principles for Responsible Investment (PRI) believes that dialogue between investors and clients on ESG interests and preferences is a necessary to a sustainable financial system and we welcome policy initiatives to encourage this dialogue.

The European Association of Co-operative Banks (EACB) is closely following the European Commission work on sustainable finance as this is a very important workstream for the EACB members due to the fact that co-operative banks, being local and regional banks, play a key role in sustainable financing.

The FIR — French RIS fully supports the idea of allowing the commitment of savers questionnant preference on the social, societal, environmental and good governance. To meet their aspirations, French savers can choose products labelled or label SRI (TEEC). These labels are steered by the Ministry of Economy and Finance and the Ministry of Ecological and Inclusive Transition.

Filed in French · English published by the European Commission

The Alternative Investment Management Association Limited (AIMA) welcomes the opportunity to respond to the proposal for a delegated regulation amending Regulation (EU) 2017/565 (‘MiFIR’) supplementing Directive 2014/65/EU (‘MiFID II’) as regards organisational requirements and operating conditions for investment firms and defined terms for the purposes of that Directive (the ‘draft delegated regulation’).

Draft delegated regulatio Sustai a le Fi a e I itiative Distribution of insurance- ased i vest e t produ ts Response of the 2° Investing Initiative BACKGROUND 1) The HLEG recommended not to use the o ept of i tegratio of ESG fa tors For the past 15 years, the debate on fiduciary duties has been framed around the question of whether investors and insurance intermediaries a o ust i teg ate ESG fa to s i to i est e t…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Finance Denmark strongly supports the proposals of sustainable finance and we think The European Commission’s proposals overall are a positive step towards a sustainable economy. The Commission´s initiative is an important part of the steps to achieve the necessary funding for the transition to a low-carbon, resource-efficient and circular economy.

The Investment Association (IA) thanks the Commission for the opportunity to comment on proposed changes to the MiFID II Suitability Assessment. Asset managers are increasingly seeking to integrate an assessment of environmental, social and governance (ESG) factors in their investment process and decisions and to monitor and mitigate their risks and opportunities, where these factors are deemed to have a material…

DRAFT DELEGATED REGULATION SUSTAINABLE FINANCE INITIATIVE MIFID II SUITABILITY REQUIREMENTS Response of the 2° Investing Initiative Stanislas Dupre, CEO of 2° Investing Initiative Former member of the High-Level Expert Group on Sustainable Finance Co-Chair of the ISO 14097 standard working group on climate-related metrics for the finance sector BACKGROUND 1) The HLEG recommended not to use the o ept of integration…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The concept of “best interest” should be defined at the EU level to include both financial and non-financial benefits. In other words, we believe that it should be made clear that the utility of investors can depend on both financial and non-financial returns.

WWF welcomes the European Commission’s opportunity to give feedback on amendments to delegated acts under the Markets in Financial Instruments Directive (MiFID II) and the Insurance Distribution Directive to include ESG considerations into the advice that investment firms and insurance distributors offer to individual clients.

WWF welcomes the European Commission’s opportunity to give feedback on amendments to delegated acts under the Markets in Financial Instruments Directive (MiFID II) and the Insurance Distribution Directive to include ESG considerations into the advice that investment firms and insurance distributors offer to individual clients.

Encouraging investments in sustainable products is a core element to move towards a more sustaina-ble environment. BVI (BVI represents the interests of the German fund industry at national and international level. The association promotes sensible regulation of the fund business as well as fair competition vis-à-vis policy makers and regulators.

The concept of “best interest” - as mentioned in the art. 24 (paragraph 1) of MIFID II and art. 54 of Delegated Regulation (EU) 2017/565, should be defined at the EU level to include both financial and non-financial benefits. In other words, we believe that it should be made clear that the utility of investors can depend on both financial and non-financial returns.

The Dutch Banking Association (Nederlandse Vereniging van Banken, or ‘NVB’) welcomes the opportunity to comment on the amendments to MiFID II delegated act, which is part of the Commission proposals on financing sustainable growth (‘Commissions package’). In essence, the NVB endorses the intention behind the Commissions package’s goals.

June 2018 SPANISH BANKING ASSOCIATION COMMENTS ON COMMISSION DELEGATED REGULATION (EU) AMENDING REGULATION (EU) 2017/565 SUPPLEMENTING DIRECTIVE 2014/65/EU OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL AS REGARDS ORGANISATIONAL REQUIREMENTS AND OPERATING CONDITIONS FOR INVESTMENT FIRMS AND DEFINED TERMS FOR THE PURPOSES OF THAT DIRECTIVE PROPOSAL Spanish Banking Association shares the European Commission Action Plan…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

UKSIF supports the EC Action Plan and the intention behind this legislation. We have consistently called for clients’ sustainability preferences to be discussed in the suitability assessment and this has the full support of our members including over 50 financial advisers specialising in ESG. However, we have concerns over the way terms have been defined.

Please see our attached response document. Charles Stanley & Co Limited is a long-established member of the UK wealth management sector, having served retail investors in the UK for over 100 years. As at 31 March 2018 we had approximately £25 billion of client assets under management and/or administration.

The Nordic Securities Association (NSA) supports the European Commission's (EC) sustainable finance agenda. We regret the short period of time allowed to give feedback to this draft delegated act, despite its substantial impact on companies' investment advisory processes.

The European Savings and Retail Banking Group (ESBG) welcomes the opportunity to provide comments on the draft Commission Delegated Regulation amending Regulation (EU) 2017/565 supplementing Directive 2014/65/EU of the European Parliament and of the Council as regards organisational requirements and operating conditions for investment firms.

We are writing in our capacity as a Taskforce on Growing a Culture of Social Impact Investing in the UK. The Implementation Taskforce was formed in January 2018 and is an independent taskforce that continues to be a focal point for engagement and cohesion to ensure that as many recommendations of the Advisory Group come to fruition as possible and that sustained industry engagement continues at a sufficient pace.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Climate change should be the first priority when addressing long term sustainable development issues; therefore it is required for the financial sector to adopt a carbon neutral approach to achieve sustainable finance. Eurelectric welcome the Commission proposal that challenges the EU financial regulation with sustainable goals. 1.

We welcome the opportunity to comment on the European Commission’s consultation on its Sustainable Finance Initiative for the distribution of insurance-based investment products. We would like to point out some practical elements which need to be considered to ensure that the ultimate benefit is afforded to the customer. TIMING The introduction of a transitional period in the draft Regulation is highly appreciated.

The Association for Financial Markets in Europe (AFME) is the voice of all Europe’s wholesale financial markets, providing expertise across a broad range of regulatory and capital markets issues. We represent the leading global and European banks and other significant capital market players.

Dear Sir or Madam, please find attached our feedback on the Sustainable Finance Initiative - MiFID II suitability requirements. If you have any questions do not hesitate to contact Dr [name removed]: [phone removed] [email removed] Best regards, [name removed] [phone removed] [email removed]

Consultation response from the Swedish National Pension Fund AP1, WP2, WP3 and WP4. an English translation of the AP Funds response below will be supplemented on the 26 of June. First of all we would like to commend the Task Force made an excellent work in a very short period of time. Welcomes the proposal which has now been submitted.

Filed in Swedish · English published by the European Commission

Dear Sir or Madam, please find attached our feedback on the Sustainable Finance Initiative - MiFID II suitability requirements. If you have any questions do not hesitate to contact Dr [name removed]: [phone removed] [email removed] Best regards, [name removed] [phone removed] [email removed]

st Bologna, 21 June 2018 SUSTAINABLE FINANCE INITIATIVE DISTRIBUTION OF INSURANCE-BASED INVESTMENT PRODUCTS AND MIFID II SUITABILITY REQUIREMENTS UNIPOL GROUP’s COMMENTS The Unipol Group (“Unipol”) welcomes the opportunity provided by the European Commission to comment on both (i) its draft Delegated Regulation (UE) amending Regulation (EU) 2017/565 supplementing Directive 2014/65/EU of the European Parliament and…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

st Bologna, 21 June 2018 SUSTAINABLE FINANCE INITIATIVE DISTRIBUTION OF INSURANCE-BASED INVESTMENT PRODUCTS AND MIFID II SUITABILITY REQUIREMENTS UNIPOL GROUP’s COMMENTS The Unipol Group (“Unipol”) welcomes the opportunity provided by the European Commission to comment on both (i) its draft Delegated Regulation (UE) amending Regulation (EU) 2017/565 supplementing Directive 2014/65/EU of the European Parliament and…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

With reference to the additional input of our organisation Euroside the Forum Sustainable Geldlage (FNG) is included to its input. FNG welcomes the mandatory integration and documentation of economic benefits on sustainability and their implementation in the client insurance industry. FNG has been kept for a sustainability questions in the documentation of the opinion.

Filed in German · English published by the European Commission

Please see attached file for CDP Europe's feedback. CDP Europe is a subsidiary and part of CDP Worldwide, an international non-profit that drives companies and governments to reduce their greenhouse gas emissions, safeguard water resources and protect forests.

Please see attached file for CDP Europe's feedback. CDP Europe is a subsidiary and part of CDP Worldwide, an international non-profit that drives companies and governments to reduce their greenhouse gas emissions, safeguard water resources and protect forests.

Submitted by: A Agathangelou, Transparency Task Force; Dr. K Tan Bhala, Seven Pillars Institute for Global Finance and Ethics; F Lundie, Hermes Investment; J Marshall, Jane Marshall Consulting LLP; JB Beckett, Association of Professional Fund Investors; J Dreblow, SRI Services and Fund EcoMarket (Lead Author); R Scott, Capital Cranfield Pension Trustees Ltd; S Trust, Grant Thornton UK LLP; S Kenzie, UN Global…

Please see attached file for CDP Europe's feedback. CDP Europe is a subsidiary and part of CDP Worldwide, an international non-profit that drives companies and governments to reduce their greenhouse gas emissions, safeguard water resources and protect forests.

Please find enclosed ABI’s remarks on the EUROPEAN COMMISSION on the Draft Delegated Regulation amending Regulation (EU) 2017/565 supplementing Directive 2014/65/EU as regards organisational requirements and operating conditions for investment firms and defined terms for the purposes of that Directive.

Deutsche Bank response to the European Commission’s public consultation on Sustainable Finance Initiative – MiFID II suitability requirements Deutsche Bank welcomes the opportunity to provide comments on the European Commission’s initiative on Sustainable Finance and in particular the approach to integrate Environmental, Social and Governance (ESG) considerations into the investment and advisory process under the…

Demanding the inclusion of ESG considerations in the provision of investment advice, represents an important step in the sustainable finance equation. If well defined, the recommended delegated acts amendments can truly unlock the growth potential of sustainable finance.

Demanding the inclusion of ESG preferences in Distribution of insurance-based investment products, could further contribute to the mainstreaming of sustainable and responsible investment for retail clients. This initiative will certainly increase the level of involvement in sustainability of insurance intermediaries and insurance undertakings, representing an important step in the sustainable finance equation.

Comments by Schroder Investment Management. Schroders welcomes the increasing focus of policy makers and industry stakeholders on sustainable investing and supports its overall aim. Sustainability is already a core focus of our business and we recognise it is only going to increase in importance.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

CNMV’S ADVISORY COMMITTEE COMMENTS ON COMMISSION DELEGATED REGULATION (EU) …/... amending Delegated Regulation (EU) 2017/2359 with regard to environmental, social and governance preferences in the distribution of insurance-based investment products The CNMV's Advisory Committee has been established by the Spanish Securities Market Law as CNMV’s consultative body.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

CNMV’S ADVISORY COMMITTEE COMMENTS ON COMMISSION DRAFT DELEGATED REGULATION AMENDING REGULATION (EU) 2017/565 SUPPLEMENTING DIRECTIVE 2014/65/EU OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL REGARDING ORGANISATIONAL REQUIREMENTS AND OPERATING CONDITIONS FOR INVESTMENT FIRMS AND DEFINED TERMS FOR THE PURPOSES OF THAT DIRECTIVE CNMV's Advisory Committee has been established by the Spanish Securities Market Law as…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

General comments Insurance Europe welcomes the opportunity to comment on the European Commission’s public consultation on its Sustainable Finance Initiative for the distribution of insurance-based investment products (IBIPs). Insurance Europe agrees that the existence of any customer ESG preferences would be a useful consideration to include during the advisory process.

The German Banking Industry Committee (GBIC) welcomes the opportunity to comment on the European Commission's legislative proposal for amending Regulation (EU) 2017/565 supplementing Directive 2014/65/EU of the European Parliament and of the Council as regards organisational requirements and operating conditions for investment firms and defined terms for the purposes of that Directive.

Insurance Ireland Response to European Commission consultation on draft Delegated Regulation amending Delegated Regulation (EU) 2017/2359 with regard to environmental, social and governance preferences in the distribution of insurance-based investment products Insurance Ireland welcomes the opportunity to comment on the European Commission’s public consultation on its Sustainable Finance Initiative for the…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Hermes MIFID II consultation response It is a long-held belief of Hermes Investment Management that the environmental and social impacts of investments cannot be considered separately to financial considerations - since these impacts will fundamentally affect the conditions into which Hermes’ end beneficiaries retire into, impacting the quality of their retirement.

Aviva Public Ref. Ares(2018)3285335 - 21/06/2018 Aviva feedback on sustainable finance initiative - MiFID and IDD suitability requirements Context Aviva is strongly supportive of targeted policy measures to promote sustainable finance. We have been closely involved in this agenda for many years, including as members of the EU Sustainable Finance High-Level Expert Group.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Aviva Public Ref. Ares(2018)3285220 - 21/06/2018 Aviva feedback on sustainable finance initiative - MiFID and IDD suitability requirements Context Aviva is strongly supportive of targeted policy measures to promote sustainable finance. We have been closely involved in this agenda for many years, including as members of the EU Sustainable Finance High-Level Expert Group.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Sustainable finance is a clear priority within Amundi. Amundi offers a large range of funds incorporating ESG criteria, with a particular focus on Environmental factors and low carbon portfolios. For example Amundi founded with EDF a management company, Amundi energy transition, dedicated to efficient energy finance.

"ESG preferences” should be amended clarify both the financial and non-financial nature of ESG preferences. Confusion around this terminology abounds, and we recommend a recognition that ESG preferences may be financially material, or may have no/negative financial impact on the risk profile of an instrument.

Following the European Commission’s Action Plan for Sustainable Growth launched in March 2018 and the HLEG recommendations in January 2018, BIPAR welcomes the opportunity provided by the European Commission to comment on its proposed Delegated Regulation amending Regulation (EU) 2017/565 supplementing Directive 2014/65/EU of the European Parliament and of the Council as regards organizational requirements and…

BIPAR welcomes the opportunity provided by the European Commission to comment on its proposed Delegated Regulation amending Delegated Regulation (EU) 2017/2359 with regard to environmental, social and governance (ESG) preferences in the distribution of insurance-based investment products, following the European Commission’s Action Plan for Sustainable Growth launched in March 2018 and the HLEG recommendations in…

SRI Services is devoted to advancing retail (individual investor) Sustainable and Responsible Investment (SRI). This includes offering a free online fund tool www.FundEcoMarket.co.uk designed to help financial services intermediaries meet their clients SRI/ESG needs. SRI Services is run by Julia Dreblow who has specialised in this area for 25 years.

Please see our feedback attached. EFAMA is the representative association for the European investment management industry. EFAMA represents through its 28 member associations and 62 corporate members close to EUR 23 trillion in assets under management of which EUR 14.1 trillion managed by 58,400 investment funds at end 2016.

The German Insurance Association (GDV) welcomes the opportunity to comment on the European Commission’s public consultation on its Sustainable Finance Initiative for the distribution of insurance-based investment products.

Dear Sir/Madam, as an association, we represent the professional interests of the (banks’) independent asset managers and, inter alia, the financial portfolio management agency. The total number of independent asset managers authorised in Germany amounts to about 450 companies. The VUV currently includes 290 member institutions. Our member companies are valued at around EUR 100 billion.

Filed in German · English published by the European Commission

We sincerely support the Commission’s initiative to consult upon possible amendments to Regulation 2017/565 resp. Reg. 2017/2359. We appreciate the scope of the amendments, i.e. all investments and all investors. This will enable true choices between sustainable and non-sustainable causes.

AMAFI welcomes the opportunity to give feedbacks on European Commission proposed amendments to delegated acts under MiFID 2 to include ESG considerations into Suitability requirements. Indeed, AMAFI pays particular attention to the development of ESG criteria in the financial markets and welcomes this objective to develop sustainable investments which are vital for our future.

Recommend bringing Article 11 into line with best or good practice for financial investment and development projects by aligning with International Finance Corporation Performance Standard 6 and its Guidance Notes, the Equator Principles and the World Bank Environmental and Social Safeguard 6.

Directorate-General for Financial Stability, Financial Services and Capital Markets Union European Commission Rue de Spa 2 1000 Brussels Response to the Commission’s public consultation on draft amendments to delegated acts – sustainable finance. Thank you for the opportunity to respond to the Commission’s public consultations. The response below should be seen as remarks to both consultations.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Directorate-General for Financial Stability, Financial Services and Capital Markets Union European Commission Rue de Spa 2 1000 Brussels Response to the Commission’s public consultation on draft amendments to delegated acts – sustainable finance. Thank you for the opportunity to respond to the Commission’s public consultations. The response below should be seen as remarks to both consultations.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Nordic Financial Unions (NFU) supports the Commission’s aim of including ESG considerations in the advisory process under IDD (Directive EU/2016/97 and Delegated Regulation EU/2017/2359), both in the customer profiling and product selection. NFU believes that finance employees are key levers to facilitate the transition to green finance.

Nordic Financial Unions (NFU) supports the Commission’s aim of including ESG considerations in the investment and advisory process under Mifid II, as part of the duties towards clients. NFU believes that finance employees are key levers to facilitate the transition to green finance.

Ecofi Investissements, the asset management company of Crédit Coopératif Group, welcomes the EU proposition to integrate the MiFID II suitability requirements with the consideration of ESG factors. The existing MiFID II framework is focused in obtaining data and information just about financial client's knowledge and about its experience in the investment field but their extra financial needs are not considered.

FECIF appreciates the publication of the Action Plan on Financing Sustainable Growth. We agree with the proposal aimed at amending the delegated act under IDD to ensure that sustainability considerations are taken into account in the advisory process, both in the customer profiling and subsequent product selection.

FECIF appreciates the publication of the Action Plan on Financing Sustainable Growth. We agree with the proposal aimed at amending the delegated act under MiFID II to ensure that sustainability considerations are taken into account in the advisory process, both in the customer profiling and subsequent product selection.

With reference to the Sustainable Finance Initiative - MiFID II suitability requirements, please find attached the response from the Personal Investment Management and Financial Advice Association (PIMFA), the trade association for firms that provide investment management and financial advice to help individuals and families plan for their financial life journeys.

I. General remarks Austrian banks have always been proactive and supportive in the area of climate protection and sustainability. Hence, we expressly support political targets for creating a sustainable European economy. However, one should remember that the new MiFID II regime has entered into force on 3 January, only a few months ago.

We agree with the proposal aimed at amending the delegated act under MiFID II to ensure that sustainability considerations are taken into account in the advisory process, both in the customer profiling and subsequent product selection.

We agree with the proposal aimed at amending the delegated act under IDD to ensure that sustainability considerations are taken into account in the advisory process, both in the customer profiling and subsequent product selection.

I provide these comments as Head of Sustainability for Kommuninvest, Sweden's largest issuer of green bonds. Kommuninvest proposest that Article 9.1 (i): “ avoiding incineration and disposal of waste” (see Chapter II - Environmentally sustainable economic activities) is amended, to read: ” avoiding incineration and disposal of waste; however acknowledging that energy generation based on waste incineration may be…

Invest Europe supports the Commission’s (EC) work to ensure that material sustainability factors are assessed, consistently taken into account and disclosed by institutional investors and asset managers. However, it is crucial that an accepted definition of “sustainability” (eg Brundtland report) is used and the scope captures all aspects of sustainability (climate change, environment, social & governance).

INVERCO supports the need to improve undertakings' disclosure of social and environmental information, as well as, developing positions towards considering ESG aspects and integrate them on a voluntarily basis in their asset allocation decisions. Nevertheless, “comply or explain” should be the fundamental transparency principle.

BVI’s view on responsible investment Responsible and long-term considerations play an increasingly important role in investment decisions. Many investors feel a responsibility to address environmental, social and governance (ESG) issues by being more selective in their investments. The asset management industry plays a crucial role in facili-tating this trend.

BETTER FINANCE welcomes this impact assessment aiming at ensuring that material sustainability factors are consistently taken into account and disclosed by institutional investors and asset managers. BETTER FINANCE agrees with the European Commission on the fact that increasing the transparency of the integration of sustainability in the investment process of asset managers and institutional investors will lead to…

Conselho Empresarial para o Desenvolvimento Sustentável (BCSD Portugal) welcomes the initiative “Institutional investors’ and asset managers’ duties regarding sustainability” and the opportunity given to stakeholders to comment on the Inception Impact Assessment.

We agree that the European asset management industry has a role to play in contributing to the sustainability agenda. We see this role in 3 distinctive parts: • First, the asset management industry provides its clients, institutional investors and other asset owners, investment solutions that respond to their investment as well as ESG / impact demands; • Secondly, asset managers can give institutional investors the…

Introduction The Association of the Luxembourg Fund Industry (ALFI) is the representative body of the Luxembourg investment fund community. Created in 1988, the Association today represents over 1,400 Luxembourg domiciled investment funds, asset management companies and a wide range of service providers such as depositary banks, fund administrators, transfer agents, distributors, legal firms, consultants, tax…

In general, the integration of physical ESG (environmental, social and governance factors and the standardisation of terminology and the introduction of generally applicable definitions is welcomed. The increased transparency between asset managers, as they take these factors into account, should be supported.

Filed in German · English published by the European Commission