LuxFLAG explored the critical role of Impact Investing in curbing global warming and the destruction of the natural environment with its Side Event at COP27

On November 7th, 2022, LuxFLAG hosted a round-table discussion, moderated by LuxFLAG´s CEO, Isabelle Delas, on the sidelines of the United Nations Climate Change Conference (COP27) in Sharm El-Sheikh on “Impact Investing: Key Policy and Market Challenges in an Evolving Regulatory Environment”.

The event was designed to explore key market challenges faced by impact asset managers and investors and the way in which regulatory frameworks are evolving to encourage the transition to a more sustainable economy.

As an international labelling agency, LuxFLAG´s presence at COP27 highlighted its strong commitment to engage with and learn from new and existing partners active worldwide, showcasing for the first time at a United Nations Climate Change Conference the role of LuxFLAG and its partners towards more Sustainable Finance.

In the first part of LuxFLAG´ side event, Finance in Motion (FiM), a leading global impact asset manager and advisor, offered an overview of the main challenges market practitioners face when investing via their impact funds. Ms. Britta Bochert, Head of Product Development at FiM, highlighted the need to improve the traceability of sustainability metrics in emerging markets, and to work on developing green taxonomies that assess environmental risks and create the framework for collection of data that can demonstrate a positive impact.

Ms. Eila Kreivi, Chief Sustainable Finance Advisor at the European Investment Bank (EIB), underlined the challenges of sourcing metrics that underpin the sustainability characteristics of impact investment, particularly in emerging markets. In addition, she also referred to the pioneering role multilateral institutions such as the EIB played in impact investing.

In the second part of LuxFLAG’ Side Event, Professor Dirk Zetzsche, ADA Chair in Financial Law (Inclusive Finance) at the University of Luxembourg, presented how UN SDGs and sustainable finance regulation could overcome some of those most pressing challenges faced by asset managers and investors. According to Prof. Zetzsche, regulating impact investment is essential to ensure fair competition and avert greenwashing, along with the ability to classify investments across different international jurisdictions. “Harmonisation is key if we do not want the taxonomy to be a paper tiger,” said Prof. Zetzsche, who also argued that expertise must be developed rapidly.

Sustainable investment requires transparent and clear standards to bring about the change required”, Prof. Zetzsche concluded.

The livestream of the event is available at the link below:

https://www.youtube.com/watch?v=-fnGt035KWI

 

Investment with impact: creating metrics to guarantee sustainability

 

For more than a decade and a half, the Luxembourg Finance Labelling Agency (LuxFLAG)  has been developing labelling services to advance sustainability in the investment industry, in the Grand Duchy and worldwide. As the COP27 in Egypt confronts the increasingly urgent challenges of Climate Change, LuxFLAG has been helping delegates explore the critical role of impact investing in curbing global warming and the destruction of the natural environment.

 

As a recognised leader in the fields of sustainable finance and impact investing, LuxFLAG is an expert and influential voice in charting the financial sector’s growing involvement in decarbonisation and a broader embrace of human and natural capital. Hence its hosting on November 7 of a side event discussion on the sidelines of the United Nations Climate Change Conference in Sharm El-Sheikh on “Impact Investing: Key Policy and Market Challenges in an Evolving Regulatory Environment”.

 

The side event was designed to explore key market challenges faced by impact asset managers and investors and the way in which regulatory frameworks are evolving to encourage the transition to a more sustainable economy.

 

LuxFLAG has a critical ongoing role to play in helping the industry navigate some of the current market challenges,” said CEO Isabelle Delas. “Our mission is twofold: to support and enable the financial sector’s sustainability transition at an international level, and to identify sustainable finance leaders and provide them with market credibility regarding their governance and internal processes.”

 

As an international labelling agency, LuxFLAG’s presence at COP27 highlighted its strong commitment  to engage with and learn from new and existing partners active worldwide, showcasing for the first time at a United Nations Climate Change Conference the role of LuxFLAG and its partners towards more sustainable finance.

 

At its launch 16 years ago, the agency was already focused on impact investing; its first label was for microfinance, a sector of the investment industry pioneered by Luxembourg. Since then it has added three more impact labels covering the environment, climate finance and green bonds, all of them designed to instil confidence in investors that the investment product follows internationally recognised standards and uses their money to finance projects or organisations aligned with the particular classification.

 

The impact labels can be used to identify sustainable finance leaders pursuing a particular sustainable investment objective. LuxFLAG also awards three sustainability transition labels: ESG, ESG insurance product, and the most recently launched, ESG discretionary mandate.

 

LuxFLAG’ strict external review process for fund documentation and portfolio assets enable it to award impact labels to funds classified under articles 8 and 9 of the EU’ Sustainable Finance Disclosure Regulation, using eligibility criteria defined by an expert group for each label.

 

Said Ms. Delas: “At LuxFLAG we verify not only the product and its portfolio but also the institution and underlying processes, including the construction of the portfolio. The labelling procedure involves not only review of documentation but sampling and testing the portfolio to ensure the research process is systematic and has been conducted properly.”

 

For institutions such as Finance in Motion GmbH (FiM), a German impact asset manager and advisor based in Frankfurt with a branch in Luxembourg, LuxFLAG’s expertise is essential to provide investors with certainty and confidence that their portfolio will fulfil its sustainability mission, by providing the key metrics to verify performance.

 

The role of LuxFLAG is important to give us access to that primary data, which in the end means we can show investors something we are confident in and that offers credibility,” said Finance in Motion’s Head of product development, Britta Bochert, at the COP27 side event.

 

Finance in Motion has so far invested €6 billion worldwide to generate positive change in emerging markets through impact-driven investment vehicles and solutions that contribute to achievement of the UN’ Sustainable Development Goals. It is particularly closely involved in South-East Europe, the Caucasus region and, increasingly, the Middle East and North Africa.

 

Ms. Bochert highlighted the need to improve the traceability of sustainability metrics in emerging markets, and to work on developing green taxonomies that assess environmental risk and create the framework for collection of data that can demonstrate a positive impact.

 

In an ideal world we would have an end-to-end ESG system that aggregates information from all quarters,” she said. “Unfortunately, we are still far from that.” She says Finance in Motion is moving into “deep greening initiatives” to develop products as well as encouraging sustainability practices within emerging market institutions.

 

Ms. Eila Kreivi, Chief Sustainable Finance Advisor at the European Investment Bank (EIB), underlined the challenges of sourcing metrics that underpin the sustainability characteristics of impact investment, particularly in emerging markets. Multilateral institutions such as the EIB were the first adopters of impact investing, she said: “In the past we talked about [investment] volumes, whereas now we have to also talk about the impact of that money.”

 

Multilateral development banks face similar challenges to the private sector. “Data is one of the key issues,” Ms. Kreivi said. “Our regulators in Europe – the European Commission and legislators – say we need high-quality data verified by an auditor. This is a challenge even in Europe, and more so outside, where for example you may not have a body that rates buildings’ energy efficiency in a comparable way.”

 

Between 10% and 20% of the EIB’s work is carried out in emerging economies, she noted, pointing to its activities in Egypt itself, where it is supporting projects to build resilience to food shortages and price spikes by providing funding to increase storage capacity, improve distribution channels and boost irrigation through water efficiency measures.

 

Ms. Kreivi believes the EU’s green taxonomy is a huge step toward creating a level playing field that will enable one investment to be compared with another. A crucial next step will be learning how to apply the taxonomy outside the EU; the EIB has drawn up a 152-page report with recommendations for the European Commission, including considerations on how to develop international equivalence to facilitate global application.

 

We now have these high standards established, so it will be faster than starting from scratch,” she said. “One way is to earmark funds to develop technical assistance to fill existing data gaps, create transitions between data sets, and build in emerging markets so the money stays locally. We must build up local systems and not rely only on international consultants.”

 

Ms. Kreivi stressed that creating robust labels for investments can help private funding penetrate areas where impact investment can bring about positive transformation. “For private and retail investors, labelling is very important, as someone else has done the work,” she said. “Public sector banks like us need to put the seed capital into different structures to support that environment.”

 

According to Professor Dirk Andreas Zetzsche, an expert in financial law (ADA Chair in Inclusive Finance) from the University of Luxembourg, regulating impact investment is essential to ensure fair competition and avert greenwashing, along with the ability to classify investments across different international jurisdictions.

 

Harmonisation is key if we do not want the taxonomy to be a paper tiger,” said Prof. Zetzsche also argued that expertise must be developed rapidly.

 

He added: “How do two entities compete fairly for capital? We have to start by standardising the language and the regulations. If we don’t know what the ESG goal is, how can we invest in it?”

 

Sustainable investment requires transparent and clear standards to bring about the change required, Prof. Zetzsche concluded: “We have seen over the years that climate impact constitutes a systemic dimension; what is triggered today will have an impact 15 years from now. No single investment product can make a change – it is a system and must be regulated in that way.”

 

The livestream of the event is available at the link below:

https://www.youtube.com/watch?v=-fnGt035KWI

 

LuxFLAG Press Release – 4 November 2022

LuxFLAG hosts a COP27 Side Event titled Impact Investing: Key Policy and Market Challenges in an Evolving Regulatory Environment

As part of its mandate to promote sustainable finance and responsible investment, LuxFLAG joins the EIB Benelux Pavilion at COP27 with a Side Event titled: “Impact Investing: Key Policy and Market Challenges in an Evolving Regulatory Environment”.

The objective of the LuxFLAG’ Side Event is to shed light on key market challenges faced by impact asset managers and investors and on how regulatory frameworks are evolving to enable the transition towards a more sustainable economy.

In the first part of the side event, Finance in Motion, a leading global impact asset manager and advisor, will walk us through the main challenges market practitioners face when investing via their impact funds, through the example of the Green for Growth Fund (GGF). The European Investment Bank (EIB), as one of the initiators of the GGF will contribute to the panel by sharing its long-standing investor expertise.

In the second part of the Side Event, Prof. Dr. Dirk Andreas Zetzsche will present how UN SDGs and sustainable finance regulation could overcome some of those most pressing challenges faced by asset managers and investors. In addition, policy recommendations will be explored with the objective of identifying ways to reorient more private-public capital towards sustainable projects.

The side event will last 90 minutes and envisages a total of two sessions:

  • one panel discussion among Eila Kreivi, Chief Sustainable Finance Advisor at EIB and Britta Bochert, Head of Product Development at Finance in Motion, moderated by LuxFLAG CEO Isabelle Delas; and
  • one presentation by Prof. Dr. Dirk Andreas Zetzsche, Professor of Law, Holder of the ADA Chair, University of Luxembourg on UN SDGs and the Sustainable Finance Regulation followed by an open discussion with all panelists.

You may find the latest event news and registration details on the event webpage.

The event will take place at the EIB Benelux Pavilion, Sharm el-Sheikh, Egypt, on 7th November 2022 at 3:30 pm EGT (2:30 pm CET) and it will be livestreamed on YouTube on https://www.youtube.com/watch?v=-fnGt035KWI.

LuxFLAG hosts the fourth edition of its Sustainable Investment Week (#LSIW22)

 

After a successful third edition, LuxFLAG is pleased to announce the fourth edition of the LuxFLAG Sustainable Investment Week (#LSIW22), which will be taking place from 17th to 19th October 2022. #LSIW22 is a series of 24 standalone events, which will cover a wide range of topics such as Climate Finance, ESG, Impact Investing, Sustainable Development Goals and much more.

 

A total of 23 partner organizations have confirmed their participation and will be hosting an event as part of #LSIW22 – ABBL, ADA Microfinance, Luxembourg Stock Exchange, PwC Luxembourg, Union Investment, T Rowe Price, Morningstar, Fidelity, LIST, Arendt Regulatory & Consulting, Banque de Luxembourg Investments, Candriam, Degroof Petercam Asset Management, Intertrust Group, GSK Stockman SA, Société Générale Private Wealth Management, ING, Linklaters LLP, FactSet, LPEA, Allen & Overy, Vistra, and CMS.

 

Some of our institutional partners have also offered their support for the #LSIW22 – ABBL, ADA, ALFI, ACA, EIB, ICFA, LFF, LSIF, and the Luxembourg Government.

 

Isabelle Delas, the CEO of LuxFLAG, highlights the importance of this event series: “Financial market participants are today confronted with the task of managing an ever more complex regulatory environment governing sustainability practices and reporting. It is in this context that, information and best market practice sharing becomes crucial to speed up the process of adapting to new regulatory and market standards. With LuxFLAG being a pioneer and key European actor in promoting Sustainable Finance, we launched the idea of #LSIW to provide a platform to our associate members to showcase their commitment and concrete actions in advancing sustainable finance.”

 

‘‘The regulator calls for a mobilization of private capital to achieve the Paris Agreement targets. This can only be achieved through the participation of all players in the value chain of financial services, joining efforts as a sector in order to tackle the variety of shared challenges related to Sustainable Finance. With Luxembourg being the largest fund center in Europe, the entirety of its ecosystem of market players – ranging from asset managers to audit and law firms – plays an important role in tackling specific issues regarding sustainable finance. LuxFLAG with the LSIW, offers a common platform needed to allow all actors to come together, network and share best practices.

 

#LSIW21

In its third iteration, the LSIW21 attracted over 1,500 attendees across the week. LSIW21’s attendees included fund managers, regulators and representatives of the following sectors: advisory, banking, academia, law, fund administration, FinTech, and insurance.

 

Practical information for #LSIW22

All #LSIW22 physical events are free to attend and mainly open to participants of the financial industry. However, registration is mandatory for all attendees.

 

You may find the latest event news and registration details on http://luxflag.org/lsiw22/.

Labelling as a tool to promote the sustainable finance transition

 

For the past 16 years, LuxFLAG (Luxembourg Finance Labelling Agency), has been developing and expanding its range of labels for funds and other financial products. Now regulators and other officials are catching up with the urgency of the sustainability transition. Ms Chrysa Alexandraki, Sustainability Operations Officer and Ms Roberta Consiglio, Business Development Officer outline the challenges faced by asset managers in a fast-evolving environment and the ways in which LuxFLAG can help them respond.

 

Asset managers and other financial product providers today are confronted with the task of managing an ever more complex regulatory environment governing sustainability practices and reporting, alongside the gradual harmonisation of regional and international standards – as well as managing frustration over the slow emergence of the essential supporting data.

 

However, they are finding that LuxFLAG’ s 15-plus years of experience providing labelling according to environmental, climate and sustainability criteria offers essential support in confronting these increasingly urgent challenges.

 

For financial institutions in Europe, the pace of regulatory evolution has been steadily accelerating since the European Commission’s publication in 2018 of its Sustainable Finance Action Plan to enlist the financial industry to help drive the EU’s climate and sustainable development agenda.

 

Over the past four years, new legislation under the Action Plan has taken effect in Europe: the EU’s Benchmark Regulation, the Sustainable Finance Disclosure Regulation (its implementing rules will come into force next January 1) and the Taxonomy Regulation. Proposals for the Corporate Sustainability Reporting Directive (CSRD) and Corporate Sustainability Due Diligence Directive are also advancing through the legislative process.  Furthermore, sustainability preferences were added to MiFID II client questionnaires last August.

 

Delays and data gaps

Some of the legislative and guidance changes call for a shift in focus on the part of financial institutions, for example the recent report by the Commission’s Platform on Sustainable Finance on the planned social taxonomy and its draft advice on minimum safeguards, which underline the increased importance of social impact and governance considerations.

 

Asset managers and other institutions say compliance with the new rules is made more difficult by overlap and divergence among international and in some cases, European standards, as well as delays in the arrival of regulatory guidance and detailed implementing rules (notably for the SFDR), which can add to their costs.

 

They also complain that lagging availability, consistency and comparability of data on the sustainability of underlying investments remain a barrier to effective ESG transparency. However, this is gradually being eased by proactive reporting by companies and in Europe at least, the planned introduction of the CSRD, which will apply to an estimated 50,000 companies from January 2024, should represent a major step forward.

 

European regulators have been urged to establish a common language – not least a clear definition of what ‘sustainable’ entails. EU efforts should be bolstered by the establishment in 2021 by the International Financial Reporting Standards Foundation of the International Sustainability Standards Board to help meet investor demand for more transparent and comparable corporate ESG reporting.

 

Market credibility for sustainable finance leaders

Against this backdrop, LuxFLAG has a critical ongoing role to play in helping the industry meet the challenges of the future. LuxFLAG’s mission is two-fold: to support and enable the financial sector’s sustainability transition at an international level, and to identify sustainable finance leaders and provide them with market credibility for their governance and internal processes.

 

We verify not only the product and its portfolio, but also the institution’s underlying processes, including ensuring that the construction process for the portfolio adheres to the label criteria. Thus, the labelling process involves not only review of documentation but sampling and testing of the portfolio to ensure that the research process is systematic and has been conducted properly.

 

LuxFLAG complements legislative requirements such as the SFDR, in which the sustainability disclosure is placed on asset managers, by providing a critical additional layer of quality assurance, by independently reviewing and verifying that market participants meet substantive sustainability standards.

 

The eligibility criteria for the various LuxFLAG labels incorporate the latest regulatory developments without requesting an additional effort on applicants. Nevertheless, in practice the process exerts significant influence on their behaviour and governance – for example, changing their policies, on occasion radically, to align with the best practice standards we promote through LuxFLAG’ s eligibility criteria and exclusion policy. In practical terms, fund managers might be asked in order to obtain the label, for instance, to incorporate a clause in their ESG Watchlist Policy regarding the systematic engagement with companies found in breach of the United Nations Global Compact (UNGC) 10 principles, encompassing human rights, labour, environment, anti-corruption and/or OECD Guidelines for Multinational Enterprises and/or equivalent internationally recognised standards to assess the behaviour of companies.

 

Broader role in the sustainability transition

Our organisation is conscious of its broader role in the transition toward sustainability, for example, making our in-house deep knowledge and expertise available to asset managers seeking guidance. This can involve ongoing regulatory advancements as well as our perceptions of future market trends in the sustainability field.

 

The sharing of best practice also involves the development of principles and standards, as well as identifying through our operations issues for their significance to asset managers as well as their complexity – for example, areas not yet regulated by the EU. LuxFLAG periodically draws up principles to enhance the application process and provide reassurance to asset managers and others on how to perceive and respond to such issues. This task is facilitated by the creation of working groups comprising renowned industry experts ready to share their knowledge and expertise.

 

In addition, a vital element of LuxFLAG’ s labelling application process is feedback to applicant asset managers to help them undertake additional steps toward sustainability. This may involve suggested improvements to governance, investment policies, disclosure and the investment process itself. We have realised that asset managers renewing their label often demonstrate enhanced procedures and disclosures inspired by our standards. Obtaining a LuxFLAG label itself constitutes a source of additional international recognition and credibility regarding sustainability in the broadest sense in the financial markets.

 

Sustainability poses a substantial ongoing challenge to the whole of the financial industry. While LuxFLAG does not offer solutions in all these areas, we are keen to play a critical part in this process by sharing best practice that can foster wider change, as well as providing an incentive for asset managers to advance further along their journey to sustainability.

#LSIW22 is composed of a series of standalone events covering a wide range of topics such as Climate Finance, ESG, Impact Investing, in line with the Sustainable Development Goals (“SDGs”).

All events are free to attend and open mostly to participants of the financial industry. However, online registration is mandatory for all attendees.

We look forward to welcoming you at our #LSIW22, which will be taking place over three days, on October 17th, 18th and 19th.

LuxFLAG Team

The Luxembourg Finance Labelling Agency (LuxFLAG) is pleased to announce that 11 new investment and insurance products have been granted the use of a LuxFLAG label, for a total of 363 labelled investment and insurance products, with €208 billion of assets under management as at 1st July 2022.

The newly labelled investment and insurance products are*:

  • Artemis Funds (Lux) – Global Select
  • FLE SICAV-FIS
  • Tahoe Income Credit Fund
  • Symbiotics Sicav II – SEB Microfinance
  • Tikehau Impact Credit
  • Finaltis Efficient Beta Euro
  • UniRak Nachhaltig
  • UniRak Nachhaltig Konservativ

 

The funds which were granted the use of the LuxFLAG Applicant Fund Status are:

  • Schelcher Euro Core Infrastructure Transition Debt
  • Schelcher Euro Impact Infrastructure Transition Debt
  • Eurazeo SME Industrial Assets II

* Please note that the list might not be exhaustive

 

The full list of LuxFLAG labelled investment and insurance products is available on our website.

These investment and insurance products are domiciled in nine jurisdictions viz. Belgium, Denmark, France, Finland, Germany, Ireland, Luxembourg, Monaco and Spain and are managed by more than 110 financial institutions based in 16 countries.

LuxFLAG labels are valid for a period of 12 months and are subject to renewal on expiry.

We are entering the Q4 2022 application cycle for our LuxFLAG label applications.

Please ensure to submit your label applications by latest 30 September 2022.

Application Session Q4 2022
Application submission deadline 30 September
Sample selection / evidence collection* 25th Oct.*
LuxFLAG Team and Management review Oct.- early Dec.
LuxFLAG Eligibility Committee review Early/Mid-Dec.
LuxFLAG Board review End-Dec.
Final decision announcement 21 Dec.

*The sample selection can only be conducted by 25th Jan./Apr./July / Oct. if the application package has been provided in due time. Otherwise the sample selection will be treated on best effort basis.

If you wish to apply within the next application cycle for one or more LuxFLAG labels for your investment or insurance products feel free to contact us. All application documents can also be found on each of the individual label pages under useful information.

When the Insurance Industry Embraces Sustainability Labelling

Last year Luxembourg sustainability and responsible investment labelling agency LuxFLAG extended its scope beyond funds and green bonds to the insurance industry. Chairwoman Denise Voss and head of Sustainability Operations Ahmed Ouamara explain the challenges of creating a certification process for the sustainability of insurance activities – initially unit-linked life insurance products – and emerging opportunities in a financial sector in transition.

 

A decade and a half after the launch of LuxFLAG as an independent non-profit entity dedicated to certifying the authenticity of responsible investment vehicles for the benefit of investors, the organisation branched out last year with the creation of the LuxFLAG Sustainable Insurance Product (LSIP) label – joining a total of 365 labelled products with €190 billion in assets at the end of last year.

Since then LuxFLAG – which appointed Isabelle Delas as CEO to succeed to the late Sachin Vankalas – has added a further 18 products authorised since April 1 to use its labels. These now encompass four positive impact labels, for microfinance, climate finance environment and green bonds, and two sustainable transition labels, for ESG investment funds and sustainable insurance products, notes chairwoman Denise Voss.

Labels have been awarded to products not just from Luxembourg but domiciled in Belgium, Denmark, France, Finland, Germany, Ireland, Monaco and Spain.

The growth in LuxFLAG’s activities and range of labelled products reflect developments across the European and global financial services industry, especially with the introduction of the Sustainable Finance Disclosure Regulation and the EU taxonomy for sustainable activities, as well as the increasing convergence of regulatory requirements for funds and other comparable products such as insurance-linked investments.

“We added this insurance label because the SFDR and the rest of the European regulation applies to all financial market participants,” Ms Voss says. “Asset managers may be out ahead, but the insurance and banking industries all need to comply as well. At the request of Luxembourg’s Association of Insurance and Reinsurance Companies (ACA), we set up a working group with members of the insurance industry, auditors, lawyers and other experts to draw up criteria for the label. It’s very similar to the ESG criteria for funds, but specific to the insurance industry.”

 

Change of mindset

Obtaining a LuxFLAG label is not the work of a moment, she notes: “The education required to do all this needs to run throughout an organisation, and it takes time. It’s not like the days when asset management was just about looking at the numbers. It requires a change of mindset, and time to incorporate all of those non-financial elements into areas such as investment management and risk management.”

Ahmed Ouamara, the organisation’s head of Sustainability Operations, adds: “The SFDR is the baseline, but what we do is something more, because we’re neutral and independent. We certify not only the product and the portfolio, but also that the construction process is in line with the label criteria.” The labelling process, he says, includes not only a review of the documentation, but just as importantly sampling and testing of the portfolio to ensure that the research process is systematic and has been properly conducted.

LuxFLAG’s coverage of financial instruments other than investment funds differentiates it from many of the other financial product labelling agencies across Europe. “Our aim is to engage with as many different market participants as possible,” Mr Ouamara says. “In insurance we are a pioneer – there are currently no other labels for insurance products.”

The first labels for insurance products were awarded last December, and Ms Voss says LuxFLAG is increasingly being contacted by other industry members seeking to understand the requirements and process. “The first batch of applicants say our review was extremely thorough – perhaps more than people expected, which I take as a compliment. It means you really need to earn the label.”

 

Labelling criteria

Mr Ouamara notes that the process starts with preliminary discussions to ensure that insurers can provide the right documentation and understand the application process. LuxFLAG’s process foresees that applicants can be rejected, but Ms Voss says this is not a desired outcome. “It’s about engaging with the asset manager or insurance company, so they understand what they need to do;” she says. “Sometimes they have to go away and maybe come back in a year. Part of what the label is about is helping people progress along the journey.”

The award of the insurance label is based on six criteria, starting with the sustainability of the product’s underlying investment holdings; at least 66% of investments under discretionary management must comply with at least one of the seven responsible investment strategies defined by sustainable finance network Eurosif: best in class according to ESG criteria, engagement and voting, explicit ESG integration, exclusions, impact investing, screening according to international standards, and investment according to sustainability-linked themes.

In addition, the product must be classified under SFDR article 8 (sustainability characteristics) or 9 (sustainability objective). For new unit-linked policies, at least 66% of offered funds and 50% of invested funds must be article 8 or 9; for existing products the thresholds are 50% and 33% respectively. The insurer should incorporate responsible investment strategies into the product’s investment process.

Underlying investments must comply with LuxFLAG’s LSIP exclusion policy; the insurer must adhere to best corporate responsibility and sustainability market practice, and regularly disclose sustainability-related information publicly, including key performance indicators and data sources; and the insurer must provide legal documentation including licensing details and for Luxembourg companies, the product technical specifications submitted to industry regulator Commissariat aux Assurances.

 

Exclusion policies

Says Mr Ouamara: “In general, we require at least three responsible investing strategies applied at portfolio level for the ESG label but currently only one for the LSIP label. But the requirements will evolve over time. We would expect it to change as the market matures.”

He adds that the introduction of its own exclusion policies is a relatively recent development for LuxFLAG: “The LSIP Exclusion policy is a mix of sector and value-based exclusions, and covers controversial behaviour, controversial weapons and controversial jurisdictions, as well as the tobacco sector. The exclusion of nuclear activities is on hold until further notice, given discussions at the European political level.”

Ms Voss acknowledges that for herself and Mr Ouamara, who share a background in the asset management industry, the creation of the insurance label has been “a learning experience for us as well. Fortunately, we have insurance experts we can call upon as part of the education and governance process.”

Labelling goes through three layers of review starting with LuxFLAG’s CEO, who makes a recommendation to the eligibility committee for the respective label; in the case of the insurance label this includes industry and ESG specialists. The committee in turn issues a recommendation to the board, which determines whether a label should be granted or not.

 

Challenge of existing products

“The challenge with the insurance industry is that unlike an investment fund, for which the investment strategy can be amended or an additional asset class added, for an insurance policy that’s not as easy,” Ms Voss says. “It is probably simpler to create a new product that meets the requirements of the label than to bring an existing one into compliance. That’s something the industry is having to figure out.”

She adds: “The challenges are very different from one insurer to another, whether it’s on the distribution side, on governance or about the availability of data. Initially insurers with unit-linked products had to determine which funds were under SFDR article 8 and 9, although their number has recently shot up. But we will soon be at the stage where asset managers must implement the SFDR level 2 rules. All of this is happening at the speed of light.

“Meanwhile the clock is ticking as we try to get to net zero. We can play our part in this process by sharing best practice, for example on divestment policy or the extent of disclosures. Insurance is a more conservative industry than the fund industry. The products are designed for the longer term – policy holders may be investing in the same product for multiple decades. Hence, it may take more work for insurance companies to figure out what to do about their existing products – but they will get there.”

Scroll to Top