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ESG 5.5 Sustainability product-level reporting

Form and content of Part A of a public product-level sustainability report

ESG 5.5.1R

1A manager must prepare Part A of a public product-level sustainability report in circumstances where a sustainability product does not have pre-contractual materials that relate to it.

ESG 5.5.2R

1A manager must ensure that Part A of a public product-level sustainability report:

  1. (1)

    contains the information set out in ESG 5.3.3R and ESG 5.3.6R; and

  2. (2)

    is made available to clients before they invest in a sustainability product.

ESG 5.5.3R

1A manager must publish Part A of a public product-level sustainability report on the relevant digital medium for the business of the manager in a prominent place on the specific webpage or page on a mobile application or other digital medium at which the sustainability product is offered.

ESG 5.5.4R

1A manager must ensure that it keeps the information set out in Part A of a public product-level sustainability report under review in accordance with ESG 5.1.2R.

Form and content of Part B of a public product-level sustainability report

ESG 5.5.5R
  1. (1)

    1ESG 2.3.1R to ESG 2.3.4R apply for the purposes of a manager preparing Part B of a public product-level sustainability report, where the reference to ‘public TCFD product report’ is substituted with the reference to ‘public product-level sustainability report’.

  2. (2)

    A manager must:

    1. (a)

      where a manager uses a sustainability label in relation to a sustainability product, include in Part B of its public product-level sustainability report the information set out under ESG 5.5.6R; or

    2. (b)

      where a manager does not use a sustainability label in relation to a sustainability product but uses one or more of the terms in ESG 4.3.2R(2) in accordance with ESG 4.3.2R(1), include in Part B of its public product-level sustainability report the information at:

      1. (i)

        ESG 5.5.6R(3);

      2. (ii)

        ESG 5.5.6R(5);

      3. (iii)

        ESG 5.5.6R(8) (in relation to the manager’s investment policy and strategy);

      4. (iv)

        ESG 5.5.6R(9); and

      5. (v)

        ESG 5.5.6R(10)

ESG 5.5.6R

1In addition to the requirements at ESG 5.4.4R, a manager must include the following information in relation to a sustainability product in Part B of a public product-level sustainability report:

  1. (1)

    the sustainability label that the manager is using in relation to the sustainability product;

  2. (2)

    details of the product’s sustainability objective;

  3. (3)

    the date of the report;

  4. (4)

    details as to the product’s progress towards achieving its sustainability objective;

  5. (5)

    details as to how the product invests in accordance with the manager’s investment policy and strategy for that product on an ongoing basis;

  6. (6)

    the proportion of assets (which may be expressed as an approximate figure or range) that are invested in accordance with the product’s sustainability objective, as well as the types of assets that are not invested in accordance with that objective and the reason(s) for that;

  7. (7)

    details of the sustainability product’s performance against the KPIs under ESG 4.2.4R(3);

  8. (8)

    details of the relevant metrics (other than those set out in ESG 5.5.6R(7)) that a retail client might reasonably find useful in understanding the product’s sustainability objective and/or the manager’s investment policy and strategy for that product:

  9. (9)

    details of the following information, where this is relevant to a retail client’s understanding of the metrics set out at ESG 5.5.6R(7) and ESG 5.5.6R(8):

    1. (a)

      relevant contextual information such as how the metrics should be interpreted and their associated limitations – for example, if particular assumptions or proxies have been used; and

    2. (b)

      historical annual calculations of the metrics in ESG 5.5.6R(7) and ESG 5.5.6R(8) after the first year of preparing Part B of a public product-level sustainability report in relation to the product that enable clients to compare the product’s sustainability performance year-on-year in a way that is easy to understand and is not misleading;

  10. (10)

    details (if any) of how the manager’s approach in relation to the product deviates materially from the manager’s overarching approach disclosed in the manager’s sustainability entity report;

  11. (11)

    details of how the manager’s investor stewardship strategy has been applied in relation to the sustainability product, including the activities undertaken and the outcomes the manager has achieved or expects to achieve; and

  12. (12)

    details of the matters escalated (if any) in accordance with the manager’s escalation plan under ESG 4.2.9R(6).

ESG 5.5.7R

1In addition to the information set out in ESG 5.5.6R, where a manager uses the sustainability label ‘sustainability impact’, it must also include in Part B of a public product-level sustainability report details of the progress that the sustainability product’s assets are making towards achieving a positive environmental and/or social impact, as measured in accordance with the method set out under ESG 4.2.17R(2).

ESG 5.5.8G

1In relation to ESG 5.5.5R(2)(b), a manager may choose to disclose any further information in ESG 5.5.6R that it considers appropriate to include in Part B of a public product-level sustainability report.

ESG 5.5.9G

1To the extent that a manager discloses the information referred to at ESG 5.5.6R(9):

  1. (1)

    the manager should clearly explain the methodology used in providing each relevant metric and ensure that the metrics calculated under ESG 5.5.6R(7) and ESG 5.5.6R(8) are at least as prominently presented; and

  2. (2)

    the metrics referred to in ESG 5.5.6R(8) may include (for example) KPIs that are not linked specifically to the sustainability objective of the sustainability product, but which may be common metrics within a particular sector.

ESG 5.5.10G

1If a manager discloses material deviations under ESG 5.5.6R(10), it may refer to the relevant sections of its sustainability entity report, and similarly its sustainability entity report may refer to these disclosures in Part B of its public product-level sustainability report.

ESG 5.5.11G

1A manager may, for the purposes of ESG 5.5.6R(11), choose to cross-reference and include a hyperlink in its public product-level sustainability report to a report that it has published for the purposes of demonstrating its compliance with the UK Stewardship Code 2020, published by the Financial Reporting Council; if doing so, it should clearly signpost the information which is relevant to the sustainability product.

Reviewing Part B of a public product-level sustainability report

ESG 5.5.12R

1A manager must ensure that Part B of a public product-level sustainability report remains consistent with the sustainability label that is used in relation to a sustainability product, as well as the disclosures required under ESG 5.2 and ESG 5.3 in relation to that product.

On-demand product-level sustainability information

ESG 5.5.13R
  1. (1)

    1A manager must prepare and provide on-demand sustainability information to a person who requests it in order to satisfy sustainability-related disclosure obligations, whether under this chapter or as a result of other legal or regulatory requirements:

    1. (a)

      within a reasonable period of time; and

    2. (b)

      in a format which the manager, acting reasonably, considers appropriate to meet the information needs of that person.

  2. (2)

    A manager that receives a request for on-demand sustainability information under ESG 5.5.13R(1) must provide the information under ESG 5.4.4, ESG 5.5.1R to ESG 5.5.4 (as applicable) and ESG 5.5.5R to ESG 5.5.7R.

ESG 5.5.14R
  1. (1)

    1On receipt of a request from a person under ESG 5.5.13R(1), a manager must provide on-demand sustainability information as at a calculation date determined in accordance with ESG 5.4.8R or at an alternative calculation date where this has been agreed between the person and the manager.

  2. (2)

    A manager is not required to comply with a request made under ESG 5.5.13R(1) before 2 December 2025.

ESG 5.5.15R

1The entitlement in ESG 5.5.13R(1) is limited to one request for on-demand product-level sustainability information in respect of each sustainability product in each of the manager’s 12-month reporting periods under ESG 5.4.8R.

ESG 5.5.16G

1A manager is encouraged to consider, where practicable, making available to a person the information under ESG 5.5.13R(2) irrespective of the person’s eligibility to request such information under ESG 5.5.13R(1).