SFDR
Regulation on sustainability‐related disclosures in the financial services sector
The Sustainable Finance Disclosure Regulation (EU) 2019/2088 (SFDR) aims to increase transparency on how financial market participants integrate sustainability (environmental, social and governance - ESG) risks and opportunities into their investment decisions.
Sustainability factors relate to environmental, social and workforce issues, compliance human rights, anti-corruption and anti-bribery issues.
Sustainability risk means an environmental, social or governance event or condition (ESG) which, if it were to occur, could cause an actual or potential material adverse effect,on the value of the investment made by the fund.
Banca Comerciala Romana S.A. (BCR), a member of Erste Group Bank AG ("EGB") is a participant in the SFDR :
- in its quality of intermediary of insurance-based investment products (IBIP) provided by BCR Asigurari de Viata Vienna Insurance Group S.A.
- in its quality of distributor of investment funds managed by SAI Erste Asset Management S.A. (EAM), member of the Erste Group and Fidelity International Limited (Fidelity International)
Insurance company providing an insurance-based investment product (IBIP): BCR Asigurari de Viata Vienna Insurance Group S.A.
Fund management company for funds included in insurance-based investment products (IBIP): Erste Asset Management S.A., member of Erste Group Bank AG ("EGB")
BCR intermediates insurance-based investment products (IBIP) provided by its partner BCR Asigurari de Viata Vienna Insurance Group S.A.. Due to BCR's exclusive cooperation with BCR Asigurari de Viata Vienna Insurance Group S.A., the selection of sustainable insurance-based investment products (IBIPs) is limited to suitable products of BCR Asigurari de Viata Vienna Insurance Group S.A. that meet the criteria of Article 8 or 9 of the EU Regulation on sustainability reporting obligations in the financial services sector (Regulation (EU) 2019/2088).
Details about the integration of sustainability risks by the insurance company providing an insurance-based investment product (IBIP) can be found on the website of BCR Asigurari de Viata Vienna Insurance Group S.A. at https://www.bcrasigviata.ro/documente-utile.
Products provided by BCR Asigurari de Viata Vienna Insurance Group S.A. include financial investments in investment funds managed by Erste Asset Management.
Erste Group Bank AG ("EGB") assists BCR in the selection of financial products for which BCR provides insurance advice as well as in the product review process. This includes reviewing sustainability criteria and sustainability risks in financial products. Sustainability risks are defined internally. Financial instruments provided by EGB and EAM are included in BCR's insurance advice. Third party products offered in the available product lists also go through the same review processes.
More information about how EGB and EAM implement sustainability in their products and processes can be found on the websites of EGB and EAM respectively:
In order to be able to offer and recommend financial products in insurance consulting, we first analyze the financial products that are suitable for the client. The necessary information will be obtained about the client with regard to the targeted investment objectives, risk tolerance, loss bearing capacity, as well as knowledge and experience.
Through the tools made available by the insurance company that provides an insurance-based investment product (IBIP) BCR collects, via the Customer Needs and Requirements Analysis form, information on customer sustainability preferences.
Investment fund management companies whose investment funds are distributed by BCR:
- SAI Erste Asset Management S.A., member of Erste Group Bank AG ("EGB")
- Fidelity International Limited ( Fidelity International)
- Erste Asset Management GmbH, Vienna
In the case of managed open-ended investment funds, given the investment universe and the still limited availability of data on ESG criteria at local market level, EAM takes steps to identify, assess, prevent and integrate sustainability risks into investment decisions according to internal policy, but does not offer, for the time being, funds that promote or target environmental or social characteristics as required by EU Regulation 2019/2088.
Further information on the integration of sustainability risks into the investment decision-making process for portfolios managed and distributed by S.A.I. Erste Asset Management S.A. can be found on the EAM website, Investor Information section: https://www.erste-am.ro/ro/informatii-investitori.
For individual managed investment portfolios, the EAM shall take steps to identify, assess, prevent and integrate sustainability risks into investment decisions in accordance with internal policy and offer both traditional investment strategies and strategies that promote environmental or social characteristics as required by Article 8 of the Regulation EU Regulation 2019/2088.
Further information on the adverse effects of investment decisions on sustainability factors that are material or likely to be material in accordance with the requirements of Articles 3 and 4 of EU Regulation 2019/2088 can be found on the SAI Erste Asset Management S.A. website, Investor Information section: https://www.erste-am.ro/ro/informatii-investitori/reglementari-legale/Politicaprivindinvestitiiledurabile/FonduristrainepasaportatesidistribuitedeSAIErsteAssetManagementSA.
For investment funds that consider Principal Adverse Impacts (PAI), information on PAI on sustainability factors is available in the fund-specific sustainability annex of each fund and in the annual report of the funds.
Detailed information on integrating sustainability risks into investment decision-making for investment funds managed by Fidelity International can be found on the Fidelity International website, in the Fund Updates section available at: https://www.fidelity.ro/events/corporate-actions/2022-12-19-sustainable-finance-disclosure-regulation-1671435171440
The consideration of ESG risk issues is an integral part of the business at BCR and EGB level. Efforts are focused not only to provide clients and investors with the opportunity to choose, but also to ensure a safe and transparent approach to ESG financing.
BCR's Remuneration Policy is aligned with the ESG objectives set at BCR and Erste Group Bank AG in accordance with the BCR Group ESG Risk Definition Policy, which provides an overview of the most important environmental, social and governance risks that BCR Group has identified.
Relevant information addressed to the public/investors can be found on the BCR and Erste Group Bank AG websites, available at: