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The EU Regulation (EU) 2019/2088 on sustainability-related disclosures in the financial services sector, “SFDR” or the “Disclosure Regulation”, comes into effect on 10 March 2021. SFDR is part of the EU financial policy framework of regulatory measures aimed at mobilising finance for sustainable growth and channelling private investment to the transition to a climate-neutral economy. SFDR imposes transparency and disclosure requirements on Russell Investments Ireland Limited (“Russell Investments”) including in relation to the integration of sustainability risks in investment decisions. Set out below is the way in which Russell Investments will integrate Sustainability Risks into investment decisions from 10 March 2021.
Russell Investments’ policy is to integrate sustainability risks in its investment solutions by identifying, evaluating and managing relevant risks in our sub-adviser review process, portfolio management and through implementing proprietary solutions. We believe sustainability risks are most relevant to investment outcomes when they exhibit financial materiality, and, like all investment risks, are incorporated by balancing expected risk with expected reward. In managing investment solutions, we consider financially-material sustainability risks in the context of expected rewards using a blend of inputs from sources including, but not limited to, sub-adviser, third-party data sources and Russell Investments propriety analysis.
Sustainability Risks will be considered in all investment decisions except for investments in certain asset classes or where a strategy or service does not support the integration of Sustainability Risks1 .
There may be circumstances in which Sustainability Risks will not be relevant to investments decisions including but not limited to:
Where the purpose of the investment is to achieve one or more specific outcome(s) e.g. placing derivative trades to manage liquidity.
In respect of certain instruments or asset classes e.g. Sustainability Risks are unlikely to affect the value of reserve currency.
Performance of bespoke mandates which exclude Sustainability Risks or environmental, social or governance (ESG) characteristics.
Services which are performed by Russell Investments with limited discretion.
Where investment decisions are taken by sub-advisers, each sub-adviser will be responsible for identifying and considering Sustainability Risks and opportunities of investments and determining, in their opinion, whether they are, or could potentially be, financially material. Sub-advisers will be held accountable for monitoring and disclosing Sustainability Risks to Russell Investments on an ongoing basis.
Furthermore, we incorporate bespoke Sustainability Risks based on clients’ requirements for customised mandates. As well, we seek to collaborate with our advisory clients to consider, monitor and manage Sustainability Risk priorities in their portfolios.
More information on Russell Investments responsible investing practices can be found here.
"Sustainability Risks" are defined by Russell Investments as financially-material risks related to environmental, social or governance issues that are relevant to our investment practice.
1 Russell Investments Sustainability Risks Policy does not apply to: (i) transition management, interim management, FX, Currency Overlay and certain EPI Services; (ii) outsourced security trading services; (iii) passive and certain systematic strategies; (iv) unlisted securities; and (v) cash equitisation, cash management, currency hedging, derivative overlays and certain direct investing strategies.
Set out below is the way in which Russell Investments Limited, Russell Investments Implementation Services Limited and Russell Investments Ireland Limited (together, “Russell Investments”), consider the adverse impacts of its activities on sustainability factors.
Russell Investments is steward of its clients’ capital and takes seriously its commitment to respond to the mandates entrusted to it by its clients. As standard practice across its portfolios, Russell Investments seeks to identify and manage financially material sustainability risks as detailed in its Sustainability Risk Policy. Adverse impacts and financially material sustainability risks are not mutually exclusive, and those adverse impacts that overlap with sustainability risks are considered as standard operating procedure.
Russell Investments also monitors and reports on a limited number of metrics related to adverse impacts in the equity asset class, and for a limited number of portfolios outside of equities. In addition to monitoring and reporting, there are also circumstances where Russell Investments incorporates explicit management of adverse impacts into a mandate.
Russell Investments differentiates between two levels of response to adverse impacts. The first is measuring and reporting on adverse impacts. The second is explicitly managing adverse impacts.
a) Monitoring and reporting on adverse impacts
Russell Investments considers some specific adverse impacts metrices for the equity asset class as standard practice and these metrices are monitored for all equity portfolios. This includes monitoring carbon emissions and an overall ESG score. This information is made available to investment teams for their consideration and is an input into quarterly calls with its subadvisors for the consideration of such subadvisors. It is also made available to clients. Russell Investments actively investigates data offerings in other asset classes and will seek to expand reporting and monitoring of adverse impact metrices to other metrics and asset classes over time as data availability and quality permits.
b) Managing Adverse Impacts
Where agreed with a client or clearly stated in a fund’s objectives, Russell Investments explicitly manages some investment portfolios to reduce one or more adverse impacts. Russell Investments employs various methodologies to do this including:
i. screening certain types of investments that are considered to have an adverse impact; or
ii. centralised implementation of multi-manager portfolios, enabling Russell Investments to use an overlay to reduce certain adverse impacts by shifting weight out of those securities with the highest adverse impacts.