1. Website Disclosure Statement in respect of Article 8 Fund(s)
1.1 Chapter IV, Section 1 of the Commission Delegate Regulation (EU) 2022/1288 of 6 April 2022 (the “final RTS”, see here) sets out the website product disclosure requirements for FMPs marketing financial products that promote Environmental or Social Characteristics (in compliance with Article 10(1) of the SFDR).
1.2 Article 24 of the final RTS provides that the website product disclosure including the following section titles in the following order:
- ‘No sustainable investment objective’;
- ‘Environmental or social characteristics of the financial product’;
- ‘Investment strategy’;
- ‘Proportion of investments’;
- ‘Monitoring of environmental or social characteristics’;
- ‘Data sources and processing’;
- ‘Limitations to methodologies and data’;
- ‘Due diligence’;
- ‘Engagement policies’;
- ‘where an index is designated as a reference benchmark to attain the environmental or benchmark’.
1.3 The requirements for each section are provided by Articles 25 to 36 of the final RTS, as set out in the following table. The table includes our draft responses to be included in the website disclosure statement. We propose that this disclosure website disclosure statement should be published as a pdf statement, which is linked to on the Fengate website. Article 23 of the final RTS provides that website disclosures in respect of each applicable fund should be published in a separate section titled “Sustainability-related disclosures” in the same part of the website as the other information relating to the fund (including where market communications are published).
1.4 For further explanation, the responses below relate to the draft precontractual disclosures, included in the SFDR / Taxonomy Annex (re-attached for ease of reference). Where additional/new text has been included, this is shown in blue highlight. We have inserted our additional comments in yellow highlight.