EU sustainability-related investment
regulations: an overview
U P D AT E | O C T O B E R 2 0 2 2

EU sustainable investment regulation | October 2022

The EU’s sustainability-related investment regulations are a continued focus for
Wellington. Sustainability, in all its forms, is a strategic priority for our firm and an integral
part of our long-term mindset and fiduciary commitment to our clients. We welcome theEU’s developing regulatory framework as a valuable tool in helping us meet this strategic
goal and support our clients on their respective sustainability journeys. In this report, we
review and explain the latest developments and share our approach, which is guided by aphilosophy of ensuring investment integrity and meeting clients’ expectations.
S U S TA I N A B L E F I N A N C E D I S C L O S U R E R E G U L AT I O N ( S F D R )Since the publication of the SFDR Level I legislation in November 2019, we have centred our efforts on ensuring
compliance with Level I requirements. Following the subsequent publication of Regulatory Technical Standards(RTS), we have widened our focus to ensure we understand and effectively implement the expanded Level IIstandards that come into force on 1 January 2023.
E U E N V I R O N M E N TA L TA X O N O M Y

We have made a concerted effort to source data, make enhancements to our infrastructure and bolster ourinternal framework to meet our Taxonomy disclosure obligations. We are also building internal tools so that
we can source and report accurately on environmental Taxonomy alignment data despite the numerous
outstanding questions.
M I F I D S U S TA I N A B I L I T Y P R E F E R E N C E S

In line with the requirements of the EU’s Sustainable Finance Action Plan, we are working to provide clients withgreater clarity on their sustainability choices and to map their preferences. We are also pro-actively enhancing
our Target Market Assessment approach and reporting templates.
A FIRMWIDE COMMITMENT

Wellington’s commitment to environmental, social and governance (ESG) integration and sustainability isreflected in our governance structure, which brings together our senior leadership and leading sustainability
experts, as well as the establishment of a dedicated regulatory working group. Another crucial aspect of oureffort involves extending our partnership with clients to meet both their financial and sustainable investment
goals. We look forward to working with you.

Wendy Cromwell, CFA
Vice Chair and Head of
Sustainable Investment

Please note: this report should be read in conjunction with the sustainability-related literature andpolicies applicable to individual Wellington investment products.
For further information, visit: www.wellington.com/sustainability
and our dedicated SFDR webpage: www.wellington.com/sfdr

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EU sustainable investment regulation | October 2022

A L O N G - S TA N D I N G C O M M I T M E N T
T O S U S TA I N A B I L I T Y

2007

Launch of first climate strategy

2011

Creation of ESG Research Team2015

Launch of Global Impact Strategy

2017

About Wellington
Wellington’s only business is managing money for our clients,
allowing us to concentrate on our goal of exceeding theirinvestment and service expectations. Our ownership model,a private partnership that is now more than 40 years old,
empowers a focus on the long term, so we are aligned with theinterests of our clients as well as the careers and development
goals of our talent.

A STRONG EUROPEAN PRESENCE
Since opening its London office in 1983, Wellington has
expanded across Europe and established fund ranges in Ireland(UCITS) and Luxembourg (UCITS and AIFs).

Launch of Global Impact Bond Strategy

2018

Research collaboration with Woodwell
Climate Research Center to study physicalclimate risks
Ireland2018

LondonHead of Sustainable Investment Wendy
Cromwell joins the UN PRI board

Luxembourg

Frankfurt
ZurichMilan

2020

Founding member of the Net Zero AssetManagers Initiative

Madrid2021

Groundbreaking power purchase agreement
matches 100% of US office and US
employees’ home electricity use withrenewable energy

OFFICESFUND RANGES• London• Ireland• Frankfurt• Luxembourg• Luxembourg

2022

Research collaboration with the Joint
Program on the Science and Policy of Global
Change at the Massachusetts Institute ofTechnology to study climate transition risks• Milan• Madrid• Zurich3

EU sustainable investment regulation | October 2022

Key elements of the EU’s
sustainability-related
investment regulations

claims to support, promote or improve environmental or social
characteristics or has a sustainable outcome as an investment
objective, it must provide specified technical disclosures.
Whether and how sustainability risks may impact investments
must be disclosed. In many cases, this also includes disclosing
the extent to which investments may harm the environment
or society.

SFDR overview

Asset managers are required to disclose firm-level and/or

SFDR is part of a broader EU regulatory regime designed toa certain size, consider and disclose the adverse impacts ofhelp finance sustainable growth and support the transition to atheir investments on sustainability factors. Additional policies

lower-carbon economy. The legislative actions at the centre of

may need to be developed or implemented to meet SFDR

this effort are in response to the EU’s commitment to the Paris

requirements on an ongoing basis as the RTS continue to evolve.

entity-level policies regarding sustainability risks, and, if of

Agreement and United Nations Sustainable Development Goals(UN SDGs).

Through its detailed criteria and disclosure requirements, SFDR
also aims to prevent “greenwashing” — marketing an investment

In the investment management context, SFDR is designed tovehicle as sustainable or ESG-focused when it is not, or grossly

provide asset owners and their beneficiaries with greater clarity

overstating its sustainability or ESG attributes and/or its ability

and confidence that their investment managers are delivering on

to meet stated sustainability or ESG objectives. The regulation

objective, transparent and quantifiable sustainable investment

should enhance investors’ ability to compare sustainable

goals. To achieve that objective, the regulation holds asset

investment products and evaluate financial services firms’

managers accountable for clearly disclosing to their clients how

commitment to ESG and to advancing a lower-carbon future.

they approach, measure and track progress on sustainability
and ESG at the firm and product level.

As regulatory clarity, issuer transparency and data availability
continue to improve, we will provide additional insights

SFDR applies to a broad range of financial products that are

into how we incorporate ESG and sustainability into ourmarketed and sold into and out of the EU, including pooled

investment process.

funds and separately managed accounts. If a regulated product

P R O D U C T C L A S S I F I C AT I O N C AT E G O R I E S E X P L A I N E D
ARTICLE 9: DARK GREEN

ARTICLE 8: LIGHT GREEN

ARTICLE 6: OTHER

Products have a core sustainable objective,
along with the goal of producing positive
financial returns. Managers must report
performance for both targets.

Products promote at least one E/Scharacteristic, but they are not required to havea specific sustainable investment objective.

Products that fall under Article 6 of SFDR
make no claim to being sustainable or topromote any ESG characteristics.

The E/S characteristics must be binding,measurable and reportable.

Pre-contractual product documents muststate that: “The investments underlying thisfinancial product do not take into accountthe EU criteria for environmentally or sociallysustainable investments.”

The product’s sustainable objectives and any
environmental/social (E/S) characteristics
promoted must be binding (cannot be
overridden by the portfolio manager),measurable and reportable, based on
objective criteria.
Substantially all holdings must be sustainable
investments and meet the standard of “dono significant harm”, using the 14 mandatory
Principal Adverse Impacts (PAIs).
All investee company holdings must be
deemed to have “good governance”.
Where the strategy has environmental
features, it will also have to be measured
against the EU Taxonomy.
Managers must also disclose whether andhow they incorporate sustainability risk
considerations into the investment process.

Managers may designate a portion of theportfolio as sustainable investments, with nominimum requirement defined. Those holdings
must contribute to an environmental or social
objective and meet the standard of “do no
significant harm”, using the 14 mandatory PAIs.
Outside those sustainable holdings, managers
may consider certain PAIs in a variety of ways.

Under Article 6 of SFDR, managers must also
disclose whether and how they incorporate
sustainability risk considerations into theinvestment process.

All investee company holdings must be
deemed to have “good governance”.
Where the strategy has environmental features,
it will also have to be measured against the
EU Taxonomy.
Managers must also disclose whether andhow they incorporate sustainability risk
considerations into the investment process.

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EU sustainable investment regulation | October 2022

Key sustainability considerationsin products
Wellington’s large and varied client base has a wide variety ofsustainability goals and requirements, which we discuss on
an ongoing basis. As a firm, we have also made a concerted

C L I M AT E

• Scopes 1, 2 and 3 greenhouse gas emissions• Carbon footprint• Greenhouse gas intensity of investee companies and countries• Exposure to companies active in the fossil fuels sector

effort to work with individual portfolio management teams• Exposure to fossil fuels through real estate assets

to understand how their investment philosophy, process and• Exposure to energy-inefficient real estate assets

portfolio guidelines align with the SFDR’s product classification
system. We have deliberately taken a conservative approachbased on investment integrity and client need. We continue to• Share of non-renewable energy consumption and production• Energy consumption per high-impact climate sector

evolve our offering based on those principles.

O T H E R E N V I R O N M E N TA L I M PA C T S

In selecting an investment strategy that aligns with any• Activities negatively affecting biodiversity-sensitive areas

sustainability goal, there are three key SFDR-related concepts• Emissions to waterthat are important to consider:
1. Principal Adverse Impacts (PAIs) – the extent to which• Hazardous waste and radioactive waste ratio

the investment strategy considers and attempts to avoid or

SOCIAL

mitigate the harmful effects that an investment can have on• Violations of UN Global Compact principles and Organisation

the environment or society;
2. Sustainable investments – the extent to which an investment

for Economic Cooperation and Development (OECD)
Guidelines for Multinational Enterprises

strategy seeks to identify and invest in assets that are• Lack of processes and compliance mechanisms to monitor

considered sustainable according to its own criteria;

compliance with UN Global Compact principles and OECD

3. EU Environmental Taxonomy alignment – the extent to

Guidelines for Multinational Enterprises

which an investment strategy invests in economic activities• Unadjusted gender pay gap

that are classified as “environmentally sustainable” under the• Board gender diversity

criteria developed by the European Union.
These three concepts are described in further detail below.
Since 2 August 2022, for the investment strategies we offer
under MIFID we are also integrating these three concepts• Exposure to controversial weapons (anti-personnel mines,
cluster munitions, chemical weapons and biological weapons)• Investee countries subject to social violations

into our broader suitability analysis and the target market

H O W A R E PA I S C O N S I D E R E D ?

assessments that we use to determine which investment

Investment products that consider one or more of the above

strategies are appropriate for our clients. We look forward to

PAIs, or any other PAIs, can do so in a variety of ways depending

continuing our dialogue with clients around these features andon the ESG strategy and guidelines, including via engagement,

how they are embedded in our strategies.

reporting of outcomes, strict exclusions, the application of

PA I S E X P L A I N E D

specific tolerance thresholds or other investment restrictions.

Under SFDR, PAIs or Principal Adverse Impacts, are intended
to capture the ways in which investments can negatively
impact or harm the environment or society. Under SFDR
Level I, this concept is broadly defined to refer to where
investment strategies may take into account the harmful effects
investments may have on sustainability factors, including
environmental, social and employee matters; respect for humanrights; anti-corruption and anti-bribery matters. SFDR Level
II further defines the specific indicators that may be used toassess adverse impacts, including, but not limited to:5EU sustainable investment regulation | October 2022

S F D R S U S TA I N A B L E

and these portions may vary from one Article 8 product to

INVESTMENTS EXPLAINED

another. Article 8 and 9 products are currently required to

SFDR defines a sustainable investment as “an investment inan economic activity that contributes to an environmental
objective, as measured, for example, by key resource efficiency
indicators on the use of energy, renewable energy, raw materials,

disclose details around how any Sustainable Investments are
identified and monitored. Under SFDR Level II, these disclosures
will also include details of how the individual PAIs are assessed
and monitored under the DNSH test.

water and land, on the production of waste, and greenhousegas emissions, or on its impact on biodiversity and the circular

HOW ARE WE SUPPORTING CLIENTS?

economy, or an investment in an economic activity thatAs Level II SFDR takes the concept of the consideration ofcontributes to a social objective, in particular an investment that
contributes to tackling inequality or that fosters social cohesion,social integration and labour relations, or an investment in
human capital or economically or socially disadvantaged
communities, provided that such investments do notsignificantly harm any of those objectives and that the investee
companies follow good governance practices, in particular withadverse impacts from the high level to the very specific,
we are, as mentioned above, in the process of sourcing,analysing and integrating the data on the full list of 14+
PAIs while recognising that the data is still very much awork in progress. However, we expect that data to improve
incrementally as issuers increase their disclosure.

respect to sound management structures, employee relations,
remuneration of staff and tax compliance.”
Individual investment products may assess how theirinvestments meet these criteria using different methodologies.
In addition, the metrics and data used to assess the contribution
to these objectives may vary from one investment strategy
to another.
THE DO NO SIGNIFICANT HARM (DNSH) TEST

Sustainable investments must also be assessed to notsignificantly harm any environmental or social objective.
Currently, under SFDR, this assessment may be done in a

E U TA XO N O M Y E X P L A I N E D
The EU Taxonomy on sustainable activities, or EU Environmental
Taxonomy, is a defined methodology that the EU has developed
to classify whether an economic activity can be considered“environmentally sustainable”. Where SFDR allows individual
products to develop and disclose various methodologies used toassess the sustainability of an investment, the EU Environmental
Taxonomy has defined six environmental objectives that an
economic activity must “significantly contribute” to for it to beconsidered environmentally sustainable:variety of ways using qualitative and quantitative inputs. For• Climate change mitigation

instance, at Wellington, we currently conduct DNSH tests with

• Climate change adaptationreference to an investee company’s compliance with the United
Nations Global Compact Principles (UNGC). The UNGC is abroad set of environmental and social sustainability principles,• The sustainable use and protection of water andmarine resources

the violation of which, in our view, is indicative of potential• The transition to a circular economy

significant harm to the environment or society.

• Pollution prevention and control

Under SFDR Level II, the DNSH test must incorporate at least 14• The protection and restoration of biodiversity and ecosytems

mandatory PAIs, including those listed above. While investment

Each environmental objective has its own technical screening

products must disclose confirmation of how these PAIs wereused to assess DNSH, the ways in which these are assessed mayvary from one investment strategy to another, including withregard to any specific thresholds used to determine whether
harm can be considered “significant” and whether qualitative
and/or quantitative elements are used in the assessment.
WHICH INVESTMENT PRODUCTS DOES THISA P P LY T O ?

criteria, which include detailed requirements specific economic
activities must meet to be considered environmentally
sustainable or “Taxonomy-aligned”. Activities must also alignwith the OECD Guidelines for Multinational Enterprises andthe UN Guiding Principles on Business and Human Rights. In
addition, they must “do no significant harm” to any of the otherenvironmental objectives listed above according to the EU
Taxonomy’s prescribed methodology.

SFDR Article 9 products have a sustainable investment

While the EU has made significant progress in its work

objective, and as a result, substantially all investments must

towards classifying the environmental sustainability of

be assessed to ensure they are sustainable investments that

economic activities, the scope and ambition of the projectcontribute to the environmental and/or social objectives ofis vast, and significant work and several critical questions

the strategy. Article 8 products are not required to invest inremain outstanding before asset managers can accurately

sustainable investments. Some Article 8 products may elect toand transparently disclose a meaningful level of alignment ofinvest a defined portion in sustainable investments, however,

portfolio investments with the EU Environmental Taxonomy.

6EU sustainable investment regulation | October 2022

W H AT D O E S TA X O N O M Y A L I G N M E N T M E A N ?

Moreover, only the technical screening criteria for the climate

For an economic activity to be considered “Taxonomy aligned”,

change mitigation and adaptation categories are currently in

it must:• Substantially contribute to an environmental objective
listed above;effect, with the remaining four categories not expected to comeinto force until 2023. Another difficulty is the limited extent
to which individual companies or issuers disclose the details
necessary to accurately assess the Taxonomy alignment of their• Comply with the screening criteria prescribed for the activity;

activities. Regulations requiring corporate issuer disclosure of• Comply with the minimum safeguards; andTaxonomy alignment will likely not become official until 2024.

• Do no significant harm.
Taxonomy alignment is assessed at the economic activity
level and is typically expressed as a percentage of an investee
company’s overall revenue that can be attributed to its
Taxonomy-aligned activities. As a result, individual companies
may be anywhere from 0%–100% Taxonomy-aligned dependingon the nature and scope of their business activities.
The overall Taxonomy alignment of an investment productis expressed as the total percentage of Taxonomy-aligned
economic activities that the product is invested in based on the

HOW ARE WE SUPPORTING CLIENTS?

We have made a concerted effort to source data, makeenhancements to our systems and infrastructure andbuild out the internal framework needed to meet our
Taxonomy disclosure obligations. However, while it isimportant to us that we provide timely, accurate andtransparent Taxonomy-alignment data for our in-scope
portfolios, we are unable to commit to or provide
Taxonomy-alignment figures for strategies today given

market value of its investments.

the regulatory and data gaps outlined above. There are,W H E N I S TA X O N O M Y A L I G N M E N T R E Q U I R E D ?

that came into effect on 1 January 2022 as part of the

Article 9 products that have sustainable investment objectives

Level I SFDR rules, which allow us to disclose whichtied to environmental goals, as well as Article 8 products that

products are in scope and which are not. We are also able

promote environmental characteristics, are required to disclose

to provide some additional details on the environmental

their overall Taxonomy alignment.

objectives of our sustainable investments, which may lead

however, some high-level requirements around Taxonomy

to eventual Taxonomy alignment.
W H AT A R E T H E C U R R E N T
I M P L E M E N TAT I O N C H A L L E N G E S ?

Taxonomy alignment of individual investment products may varysignificantly, with some products identifying investments asenvironmentally sustainable in a way that does not align with the
EU Environmental Taxonomy methodology.

EU sustainable investment regulation | October 2022

Firm/entity-level compliance andclient support
SFDR includes various firm- and entity-level requirements
designed to provide transparency into how an asset
management firm incorporates sustainability into its
investment processes and to consider and disclose the negativeenvironmental and social impacts of its investments. As a global
firm with over 200 investment approaches serving institutional
and intermediary clients worldwide, our firm-level compliancewith sustainability regulations will evolve over time. We expect
additional guidance from European regulators to continue. Our
approach must also take into account sustainability-related
requirements in the multitude of other jurisdictions in which we
operate, including Singapore, Hong Kong and the UK.
While we expect regulators to set the baseline requirements, we
anticipate engaging extensively with our clients to understandand meet their expectations with regard to the sustainabilityof investments we manage on their behalf, over and above abaseline. Our goal is to provide clients with detailed, transparent
reporting on our strategies’ E/S characteristics, sustainableobjectives and sustainability risk management.
In addition, as part of MIFID, we have created a high-level
European ESG Template (EET) for our funds, which we will refine
as more information becomes available.

HOW ARE WE SUPPORTING CLIENTS?
ROBUST GOVERNANCE

Our dedicated Sustainable Investment Regulatory and
Third-Party Working Group is designed to help ensure wecan meet both the requirements of the EU’s sustainable
investment regulations and our clients’ expectations. It is
underpinned by a firmwide governance structure in supportof our sustainability commitments that encompasses our
CEO and senior leaders from across our Investment, Clientand measurement approaches with clients; engaging withcompanies to promote science-based targets as part ofcredible climate transition plans; enhancing our proprietaryinvestment research tools; and taking an active role on the
net-zero advisory board and in associated working groups.
ESG scoring: Several of our investment teams use
proprietary research and third-party ESG scores to honetheir opportunity sets and broaden coverage. This approachspurs portfolio managers to allocate higher portfolio weights

and Infrastructure platforms.

to companies with good ESG practices and encourages

DEVELOPING TOOLS AND RESOURCES

ESG practices.

Carbon measurement: As a founding member of the Net
Zero Asset Managers initiative, we are bolstering our researchon science-based net-zero targets and climate- transition
planning for corporate issuers. Where consistent with our
fiduciary obligations and our client’s sustainability goals,
we seek to advance the net-zero agenda across multiple
related fronts: discussing net-zero implementation options

engagement with management teams to improve
ESG engagement: Some investment teams are allocatinga minimum percentage of their portfolio to support anenvironmental or social characteristic and have committed
to using engagement to increase that exposure. As ourreporting evolves, we plan to report more consistently on
the broad range of engagement discussions our investment
teams are holding with companies.

8EU sustainable investment regulation | October 2022

The journey ahead
Implementing the EU’s evolving sustainability-related
investment regulations — most notably the Level II requirementsof the SFDR —remains a journey of adaptation for Wellington
Management and the investment management industry. We
expect that key terms such as “good governance”, “do no
significant harm”, “sustainable objective” and “environmental
or social characteristics” will continue to evolve both in termsof the regulatory standards applied to them and with respect
to the industry’s understanding of them. We are optimistic that
regulators will continue to clarify the application of the new
regulations within their jurisdictions.
In the meantime, like many of our clients and peers, we rely on
a combination of market intelligence, legal counsel, discussions
with industry experts and our deep experience with ESG
research and engagement as well as simple common sense.
Our dedicated ESG Research Team has been developing
knowledge and engaging with clients on a range of issues since2012, providing us, we believe, with an informed perspective.
We are proud of our work to date and feel confident that weare well prepared for the journey ahead. Yet we take a humble
approach to this major transformation, recognising that someof our sustainability policies and approaches may evolve
as we advance our knowledge. We also expect further rapid
development and adoption of the market data and technologicalinfrastructure that support sustainable investing. We believe
we have the teams, research and data in place to meet the
expectations of regulators and funds’ boards of directors as well
as clients, consultants and other evaluators, in relation to ourcompliance with these sustainability-related regulations and ourown aspiration to exceed the baseline.
For more information, please explore:
www.wellington.com/sustainability
or visit our dedicated SFDR webpage:www.wellington.com/sfdr
To set up a call with a member of Wellington’s Sustainable
Investment Team, please contact your relationship manager.

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Wellington [Fund Name] Fundi m p o r ta n t i n f o r m at i o n

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