Sustainable Finance Disclosure Regulation (SFDR) & Insurance Distribution Directive (IDD):
IMO Financial Services do not specifically consider the adverse impacts of investment decisions on sustainability factors in our investment or insurance advice. We have made this decision for a number of reasons, some of which are outlined below:
- Important regulatory initiatives are still ongoing to identify and properly disclose investments in sustainable economic activities, including under the EU Taxonomy. These disclosures are crucial for insurers and insurance intermediaries to assess whether the products offered match the sustainability preferences of customers.
- Some of the rules are not yet finalised and the implementation of these initiatives do not converge at the same points in time, in particular the application date of the new legislation under the Insurance Distribution Directive (‘IDD’) precedes the deadlines for reporting of company data under the Corporate Sustainability Reporting Directive and of the application of the Delegated Regulation supplementing the Sustainable Finance Disclosure Regulation (‘SFDR’).
- As the area of the SFDR is new and evolving without sufficient information being currently available from all of the product providers with which we hold an agency, we do not currently assess in detail the adverse impact of investment decisions on suitability when providing investment or insurance advice.
- The key product providers with which we engage have developed responsible investment as part of their investment philosophies and sustainability policies. However, detailed information on specific funds is not always available in order to allow us to make a full and proper assessment of their suitability in accordance with IDD and SFDR Regulations.
However, IMO Financial Services will ask you to indicate your sustainability objectives. We will make our best efforts to provide suitable and relevant information in relation to the products which we can offer based on the data currently available and discuss if our offerings are acceptable to you. If we cannot match products to your sustainability objectives we will discuss an alternative approach with you.
As further information on the approach being taken by product providers, and their internal/external fund managers, becomes available over the course of the next year, we anticipate reviewing these areas in our assessments.