SFDR’s level 2 measures provided much-needed clarification. It is clear that investment managers must report any negative impacts their investment decisions cause or any changes to the sustainability characteristics of their product range by responding to the following: Have you taken these impacts into account? How? And if not, why not?
Continued SFDR classification under Article 8 or 9 (funds integrating sustainability into their investment process) must regularly justify their status through information documents and the prospectus.
Depositaries’ non-financial duties concerning Article 8 and 9 funds are not explicitly addressed. However, SFDR establishes two baseline controls for [...]
