Last Updated: March 2021
BlueBay Funds Management Company SA and BlueBay Asset Management LLP (“BlueBay”) are required to comply with the requirements set out under the EU Sustainable Finance Disclosure Regulation (“SFDR”) as Financial Market Participants (“FMPs”) and a Financial Adviser. BlueBay Asset Management LLP is categorised as an FMP to the extent that it distributes products to EU investors. The information disclosed herein outlines BlueBay’s compliance with the requirements under SFDR.
Relevance of Sustainability Risks to the returns of our products and policies on the integration of Sustainability Risks in the investment decision-making process
BlueBay considers Sustainability Risks to be relevant to the returns of the products we manage and has a policy to integrate Sustainability Risks into our investment decisions.
Since 2013, BlueBay has had an Environmental, Social and Governance (ESG) investment management framework in place firmwide to incorporate ESG factors and risks into its investment decisions. This Environmental, Social and Governance (ESG) Investment Policy outlines the approach we take to incorporating ESG considerations within our investment management practices at BlueBay. This Policy sets out our approach to ESG factors and ESG risks, how these considerations fit within our investment philosophy, our approach to the investment strategies we manage, how we resource and manage this from a governance perspective, as well as how we communicate our efforts and progress. It applies as standard to all investments made within pooled funds (“Funds”), separately managed accounts (“SMAs”) and where BlueBay provides investment advice.
The information in the Environmental, Social and Governance (ESG) Investment Policy outlines BlueBay’s compliance with the requirements under SFDR to disclose BlueBay’s approach to integrating ESG, and therefore Sustainability Risks into our decision-making. Please note that all references to ‘ESG risks’ and ‘ESG factors’ within this Policy are equivalent to ‘Sustainability Risks’ and ‘Sustainability Factors’ as defined in SFDR. Sustainability risks are deemed by BlueBay as being relevant to the returns of its products. Accordingly, all BlueBay managed assets (Funds and SMAs) integrate Sustainability Risks into the investment decision making process and this has been detailed in this Policy.
Remuneration Policy and Sustainability Risks
The policies below include information on the integration of Sustainability Risks into remuneration practices.
No Consideration of Sustainability Adverse Impacts
BlueBay does not consider the adverse impacts of its investment decisions on Sustainability Factors. BlueBay Asset Management LLP and BlueBay Funds Management Company S.A (“BlueBay”) collectively and individually fall outside of the employee threshold set out in SFDR and therefore are not required to comply with the principal adverse impacts provisions of SFDR. BlueBay has taken the decision not to voluntarily ‘comply’ with the principal adverse impacts regime but to ‘explain’ at this stage at a firm level as at the time of making this decision the principal adverse impacts metrics have yet to be finalised and given the many data and scope issues. As such, in the context of SFDR, BlueBay has not implemented a due diligence policy with respect to the principal adverse impacts of its investment decisions on Sustainability Factors.
BlueBay reserves the right to voluntarily comply in the future with the consideration of principal adverse impacts of investment decisions on Sustainability Factors under SFDR. Outside of the SFDR regime, BlueBay does have a framework for considering Sustainability Factors and Risks (primarily through our ESG integration approach) which has some degree of principle alignment to the consideration of such impacts. Furthermore, outside of the SFDR regime, BlueBay is committed to reporting on indicators which provide insights on the ESG characteristics of portfolio investments, and as part of this will take into consideration those principal adverse impacts indicators contained in SFDR.
SFDR Product Categorisation
All products managed by BlueBay that fall within the scope of SFDR meet the conditions set out in Article 6 of SFDR as Sustainability Risks are integrated into the investment decision making process.
The table lists those in scope products which meet Article 8 (in promoting environmental or social characteristics and follows good governance practices) or Article 9 (with sustainable investment as its investment objective) under SFDR. All other in scope BlueBay Funds meet the conditions set out in Article 6 of SFDR as Sustainability Risks are integrated into the investment decision making process.
SFDR Product Category