Sustainable Finance Disclosure Regulation (SFDR)

as well as on the integration of sustainability risks, the consideration of principal adverse sustainability impacts, sustainable products that promote environmental or social characteristics and on products that have sustainable investment as its objective.

Sustainability risks are financial risks that are defined as 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 (art. 2 para. 22 SFDR).

IFB believes that sustainability risks may affect the performance of investment portfolios. To enhance the long-term performance of clients' investments, IFB integrates sustainability risk into its investment decision making process, investment advice and insurance advice where relevant. The integration of sustainability risk is implemented in line with IFB`s policies governing the creation of investment research views, portfolio construction and product selection.

Additional information on how WM integrates sustainability risk in the investment decision making process

The integration of sustainability risk in investment decision making and advisory processes is included in IFB`s policies governing these processes. The policies, amongst other things, include guidelines that analysts need to observe when forming their independent views. The investment decision and advisory processes of IFB are multi-step processes, a part of which is the selection of preferred instruments based on their market outlook.

When assessing securities of single issuers (equity and bonds) or investment funds, sustainability risks, among other financial risks, are considered when conducting the financial analysis of issuers and fund due diligence:

·       The evaluation of sustainability risks and their materiality is one of the numerous factors determining whether or not securities of single issuers are recommended and, therefore, in how far such instruments should be selected in investment management mandates and in investment advice. Sustainability risk is explicitly referred to in the Principles and methodology of research in Wealth Management CIO Investment Office.

·       Fund due diligence focuses on strategy, and how a fund manager captures risks and opportunities (including ESG risks and opportunities) in their investment process. It is not an assessment of the individual holdings within a portfolio. As part of standard fund due diligence, IFB WM evaluates an ESG rating to each fund. While sustainability and other risk topics should be considered by every manager, it is likely that funds with higher ESG intentionality ratings carry less sustainability risk given that more focus and resources are placed on research, investment decisions and/or active shareholder engagement. A fund manager’s lack of integration of sustainability risks in its investment decision making process will typically result in a lower ESG rating.

During investment research and due diligence, IFB aims to identify financial risks (including sustainability risks) with a view to managing overall portfolio risk.

IFB’s approach to compensation globally is underpinned by the Total Reward Principles, which establish a framework with a focus on conduct and sound risk management practices. Employees are assessed and rewarded for their performance against a range of financial and non-financial goals, including risk management. Where applicable, the risk management goal will include a consideration of sustainability risk. Where sustainability risks form part of an employee’s performance objectives, they are taken into account in the qualitative performance assessment, which, in turn, is one of the factors that determines an employee’s total remuneration. This approach to an employee's remuneration is outlined in the relevant remuneration policies.

IFB acknowledges a need for transparency of principal adverse impacts of investment decisions on sustainability factors. IFB has defined and follows internal procedures on identification and prioritisation of the adverse impacts and considers these as part of its investment decision making process as well as its investment and insurance advice where relevant. Currently, IFB is working to further enhance the internal framework in line with EU Regulation 2019/2088 on sustainability-related disclosures in the financial services sector. Therefore, further information about policies on the identification and prioritisation of principal adverse sustainability impacts, a description of these impacts and of any actions thereto will be enhanced, and further information will be published in line with the finalisation of applicable Commission Delegated Regulation.

The IFB Asset Management (AM) Engagement Policy provides its definition of engagement and outlines how it is interrelated to IFB AM's integration and proxy voting processes. The document stresses how engagement is part of IFB AM's fiduciary duty towards clients and is an integral part of IFB AM's investment process across both passive and active strategies. The policy provides an overview of how we prioritise engagement cases based on IFB AM's financial exposure, the presence of high environmental, social and governance (ESG) risks, the consideration of major sustainability externalities and controversies. It also describes IFB AMs research process, the sources IFB AM uses, the topics IFB AM addresses and the company representatives we usually interact with. In the document, IFB AM provides more information on the system IFB AM has put in place to define engagement objectives and track progress against them as well as the IFB AM escalation process, should IFB AM be unsuccessful in its dialogue with companies. IFB AM's criteria in collaborating with other investors and our processes to deal with insider dealing and risks arising from conflicts of interest are also explained. Finally, the policy sets our commitments to engage in good quality dialogue with companies and providing useful disclosure to clients and the public more generally. The appendix to the document includes a complete list of the stewardship codes we sIFBcribed to and a list of the most relevant ESG/stewardship initiatives 
IFB AM is currently supporting.  

IFB Wealth Management also regards stewardship as an important part of fiduciary duty as well as an important tool for impact within sustainable investment strategies. As IFB Wealth Management (IFB WM) is primarily a fund distributor, we have embedded consideration of our external asset manager’s stewardship practices into IFB WM’s fund due diligence. IFB WM's Engagement Policy is geared towards asset managers’ own engagement in their capacity as shareholders. In the general case of individual wealth management, IFB merely receives authorization for the client custody account, i.e. IFB acts as a representative that submits declarations of intent on behalf of the client. However, the client remains the owner of the equities and thus the shareholder. With this in mind, IFB Engagement Policy sets the following procedures:

·       Exercise of shareholder rights - Rights to vote

·       Discretionary mandates with clients provide for no explicit authorization for IFB when it comes to voting rights or expressly exclude exercising of voting rights. Therefore, IFB does not exercise any of the rights to vote derived from its holdings of equities in a portfolio. 

If IFB acquires fund units, the asset management company of the fund is normally authorized to exercise the rights to vote associated with the fund assets from the holdings of equities. During the fund selection process, IFB gives consideration to the Engagement Policy published by the fund management company.

Over the years IFB has committed to various business conduct codes, international standards for due diligence and reporting initiatives in order to meet the expectations of our stakeholders. IFB adheres to the recommendations of the Task Force on Climate-related Financial Disclosures (TCFD) and the Principles for Responsible Banking. In addition, IFB AM follows Principles for Responsible Investments and IFB WM adheres to IFB Operating Principles for Impact Management. 

A full list of sustainability-driven initiatives (investment process and non-investment process related) is available in the Sustainability Report.