The Remuneration Policy of AAIS is based on the one of ABN AMRO Bank N.V. Its purpose is to specify the necessary and mandatory prerequisites, as well as the principles applicable to performance and remuneration management, defined by the ABN AMRO Bank in accordance with the various applicable regulations, namely UCITS 5, AIMFD and SFDR for AAIS.
The remuneration policy takes into account internal factors such as the organisation, objectives, values and long-term interests of AAIS in order to ensure a sustainable and responsible policy, in line with ABN AMRO Bank’s objectives in terms of sustainability, social commitment and the products and services provided to our customers. The performance objectives of all ABN AMRO employees must also be in line with ABN AMRO Bank’s overall strategy, risk profile, values and long-term interests.
By running our business we have an impact on society and we assume the responsibilities this brings. The identification and management of sustainability risks is a key component of this responsibility (SFDR Article 3: sustainability risks are environmental, social, or governance events or conditions that, if they occur, could cause an actual or a potential material negative impact on the value of the investment).
The main component of our Sustainability Risk Policy is our Sustainable Investment Policy . It elaborates on how we deal with Sustainability risk: how do we identify risks and how we incorporated sustainability in our processes. Our ESG and Sustainable investment products meet our sustainability criteria as described in the Sustainable Investment Policy.
ABN AMRO’s and AAIS’ contribution to the Paris Agreement’s goals aligns with the purpose of ABN AMRO “Banking for better, for generations to come” and the bank wide strategy to “Accelerate the sustainability shift”. We do not only guide our clients towards sustainability but also want to lead by example ourselves. In our Climate Statement we explain how we, by means of our policies, aim to align with the Paris Agreement.
ABN AMRO Investment Solutions acknowledges that the defence industry poses sustainability risks. Although we acknowledge the right of states to defend themselves, we believe we should mitigate sustainability risks associated with the defence sector. Our Defence statement explains how we aim to do this.
Finally, our Exclusions List explains each exclusion in more depth: why do we exclude this activity and to which part of the fund range does it apply.
Together, these documents form our Sustainability Risk Policy under Article 3 of the SFDR. These documents are written in accordance with our parent company ABN AMRO’s Sustainability Risk Management Framework, although we may have stricter criteria in place were deemed necessary.
By publishing our Sustainability Risk Policy Framework we do not only meet regulatory requirements, but also intend to support our clients in taking better informed investment decisions. Our approach may have a negative impact on financial returns on the short run, for instance by excluding part of the investment universe, but in the long run we intend to decrease the sustainability risk exposure and thus financial risk to our portfolios. Our approach is focused on the funds that we offer via our own investment (delegation) platforms. External Portfolio Managers are free to have a more stringent approach in place. We realise that we may have indirect exposure on unsustainable sectors or companies via external funds that are not onboarded on our platforms, however, we strive to minimise these risks as much as possible.
Under Article 4 of the SFDR, ABN AMRO Investment Solutions, in its capacity of subsidiary of ABN AMRO Bank N.V. and with a total number of employees of less than 500, is not obliged to publish a Principal Adverse Impacts Statement. Nevertheless, in line with our ambitions regarding sustainability, we are working on our statement and aim to publish it here on short term.
We feel it is important to publish a Principal Adverse Impact Statement as we believe adverse sustainability impacts deserve as much attention as Sustainability risk. Adverse sustainability impacts are actual and potential negative impacts resulting from investments or investment advice on sustainability factors, i.e. environmental, social and employee matters, respect for human rights, and anti-corruption and anti-bribery matters. Identifying and measuring these impacts is important in order to assess whether a product is indeed a sustainable product. ABN AMRO Investment Solutions is currently working on fund level reporting that shows not only the Sustainability Risk a fund is subject to, but also the adverse sustainability indicators per fund. Currently, we already measure a number of the indicators defined by the Regulatory Technical Standards (RTS) but we do not yet report on them externally (for instance: Greenhouse Gas Emissions and Carbon Footprints). Next to that, some of the proposed indicators are on our exclusion list, such as UN Global Compact violations and exposure to Controversial Weapons.
Our sustainability criteria are built upon applicable international standards, conventions, treaties and regulation. The most important policies and statements are published under Sustainability Risk Policy Framework. Furthermore, we publish our voting policy and annual voting report, and will be publishing our engagement guidelines soon, under Other Due Diligence Disclosures.
Please find our statement under Principal Adverse Impact Statement 2022 .
In addition to the Principal Adverse Impact Statement, we have documents in place to guide and assess the sustainability performance of our ESG and Sustainable fund range. In this section we want to highlight specifically Active Ownership.
We define active ownership as engagement with investee companies and voting at their Annual General Meetings. Although voting can be seen as a form of engagement, we split this process as engagement rests with the individual portfolio manager and the exercise of proxy voting rights rests with ABN AMRO Investment Solutions. Over the past years we have observed an increase in Environmental and Social resolutions, thus enabling voting to be a more relevant tool to engage with our universe.
Engagement
Engagement is the responsibility of the portfolio manager, as specific engagement goals depend on the investment strategy of the fund and the role ESG criteria have. A fund that wants to contribute to Green House Gases reduction may engage in a different way with the holdings in its portfolio than a fund that focuses on human rights. Furthermore, a fund that has a value approach may engage in a different way than a fund that has a growth approach. However, regardless of these differences in approaches, there is always a minimum sustainability performance (sustainable) portfolio managers are ought to expect from companies in their portfolios. We therefore ask our portfolio managers to comply with our engagement guidelines . Portfolio managers report on a yearly basis to ABN AMRO Investment Solutions on their engagement efforts.
You will find our Global Engagement Report here .
Proxy Voting
Proxy voting is the responsibility of ABN AMRO Investment Solutions. AAIS has its own Voting policy in place. We work with ISS Governance, which provides us with voting recommendations in line with the policy we chose (a customised version of the ISS Governance International SRI Policy). From ISS’ range of specialised policies, we selected the one that enables us to be most advanced in the area of Environmental and Social, implying that we will support most E&S resolutions. We upgraded our policy with ISS in 2020. We report over our voting efforts on a yearly basis, you’ll find the latest voting report here .
We are committed to being transparent about the sustainability performance of the funds we manage. We have dedicated reports in place for this purpose and aim to add more disclosures over time. Historical reports can be found under ‘regulatory reporting’ in the footer of this webpage.
LTECV
Issued on 17 August 2015, the French Energy Transition Act for Green Growth (Loi de Transition Energétique pour la Croissance Verte - LTECV) prompts the various participants in the economic fabric to adopt a “climate” approach within their businesses whereby environmental, social and governance criteria are taken into account. An annual report is required by the regulator.
The purpose of the “LTECV report” required under the legislation is to explain the investment management company’s approach to ESG issues. The information thus communicated is dealt with at two levels:
European SRI Transparency Code
The European SRI Transparency Code (the Code) focuses on ESG/Sustainable funds distributed publicly in Europe and is designed to cover a range of assets classes, such as equity and fixed income. Signatories to the Code should be open and honest and should disclose accurate, adequate and timely information to enable stakeholders, especially consumers, to understand the ESG policies and practices of the fund.
Currently we publish the transparency codes for the following funds:
