US and the EU’s New Sustainable Investing Regulations

New EU regulations for administrators of sustainable funds, or those that invest based on environmental, social, or governance (ESG) considerations are now effective as of 10th March 2021. These portfolio managers must also reveal specifics on how they spend. The EU’s Sustainable Finance Disclosure Regulation (SFDR) extends to all asset managers that collect funds in the EU, regardless of where they are based. As a result, these rules would have an effect on funds available to US investors.

Capital administrators would have to report how they evaluate their firms across a variety of metrics, which will necessitate revisions to disclosures and publicity materials. Beginning in 2022, comprehensive disclosures must be given.

It is no longer all about disclosing ESG data; it is also about how you use it to accomplish unique ESG goals. 

The Securities and Exchange Commission (SEC) has announced that it will expand its examinations of fund managers to ensure that their shareholder statements are consistent with their strategies. It also examines how ESG funds vote in shareholder proxies on environmental issues to see if they are compliant with environmentally sustainable policies.

Morningstar said that beginning April 2021, it would begin collecting information on funds that describe themselves as green and making it available to consumers. Since several multinational investment managers sell almost equal portfolios in the United States and Europe, US clients can check Morningstar data on the European equivalent of their fund to see how well it adheres to the ESG mandate. 

Investors have been concerned about greenwashing in the mutual fund sector, particularly given the rapid rise in sustainable investments. The category has seen a surge in funding. According to US SIF, the trade body for the sustainable investing sector, U.S.-domiciled sustainable investments totalled $17.1 trillion at the start of 2020, up 42 percent from two years prior. This equates to about a third of all funds under administration in the United States.

Firms will aim to set themselves apart by making more comprehensive disclosures on how they use ESG investing. Since too many businesses in the United States still provide funds in Europe, this could increase sustainable investment efficiency in the United States, comparable to how automakers increased their emissions when California implemented tougher standards than the federal government.

More U.S.-based investment managers are now publishing impact reports that outline proxy voting and participation, as well as the net impact of their portfolios.

Aside from the SEC, the Labor Department is trying to make the climate more favourable to long-term investing. The department also stated that it would not implement two Trump-era guidelines that would have slowed the introduction of renewable funds, including one that would make it more difficult to incorporate them in 401(k) accounts. Since it administers and enforces the Employee Retirement Income Security Act of 1974, or Erisa, which protects the needs of employee benefit plan members and their beneficiaries, the DOL is critical to America’s retirement programs. According to analysts, the flurry of new legislation allows fund managers to tread carefully. 

ESG Products in Asia

Asia has been gaining pace in its progress within the realm of ESG and sustainability. The heterogeneous nature of different fund markets in Asia implies that the adoption of ESG in these markets has been quite diverse. The common positive thread, however, is the increasing awareness and importance of ESG in asset and wealth management over the past few years.

The People’s Bank of China in its latest green bond standard consultation paper removed clean coal projects from the list of green bond financing targets, reversing its previous decision to categorise coal pollution mitigation enterprises as green assets. The removal has garnered positive responses from foreign investors given that China is the largest carbon emitter and the second largest green bond issuer after the U.S.

A range of factors have contributed to this increased ESG interest in Asia. Regulatory developments have been a key push to bolster the ongoing ESG momentum. These include stewardship codes, ESG risk management guidelines, forming of steering committee and cross-collaborations among industry players. Not only are regulations and asset and wealth managers driving the ESG agenda, so too are the investors themselves.

Pressure of EU and US investors making investments into Asia markets has exerted influence in this area for many years. Institutional investors in Asia have also been forthcoming in increasing allocations to ESG assets and awarding ESG mandates.

On the distribution front, questions on ESG are slowly becoming a part of the due diligence process for onboarding funds on distributors’ platform. Increased information disclosures and availability of ESG analytics tools are other contributing factor as the data and methodologies for risk and opportunity assessment are available.

In Asia, while some asset managers have become UN PRI signatories, others are still in the process of setting up ESG teams and ramping up their talent pool in the form of sustainability or stewardship teams. There are also varied ESG adoption approaches observed with some managers having gone the ‘process route’ of broader ESG integration into their overall investment process as compared to the ‘product route’ of launching specific ESG labelled funds.

From an asset managers’ perspective, challenges remain to increase the adoption of ESG investing in Asia. These include lack of data availability, lack of standardised regulations and absence of suitable benchmarks to measure fund performance. Clients have been reaching out, looking for guidance and education in this area – either in relation to the changing regulations and their disclosure obligations, or else in relation to how they can integrate ESG within their business.

As ESG continues its rise to the mainstream, regulators are responding with new rules, with both the EU and MAS recently issuing new rules and guidelines that should be adhered to.

With sustainability now at the leading edge of global concerns, regulators are responding with a raft of new rules, regulations and guidance that apply both to the investment community and to the underlying businesses themselves.

Monetary Authority Singapore (MAS) issued Guidelines on Environmental Risk Management for the asset management industry covering environmental risks, including materiality and associated responsibilities to ensure resilience of customers’ assets against environmental risk. Asset managers should implement robust environmental risk management policies and procedures and channel capital flows through ‘green’ investment activities.

The guidelines:

  • apply to Capital Market License Holders for Fund Management (LFMC), Real Estate Investment Trust Management (REIT), Fund Management Companies (RFMC) under 5(a)(i) of the Second Schedule of the SF (Licensing and Conduct of Business) Regulation (Rg. 10.);
  • address proposed duties on boards and senior management with regards to environmental risk;
  • address matters of portfolio construction, investment research and investment monitoring;
  • highlight stewardship responsibilities, including to investee companies.

The Monetary Authority of Singapore wants asset managers to launch more ESG products in Singapore. 22 ESG-related funds were authorised by the regulator in 2020. Singapore’s regulator has introduced general environmental risk management guidelines however some have commented that the lack of standardised ESG regulations and reporting in Singapore leaves local investors at greater risk of being exposed to so-called greenwashing. 

There is a demand for a common standard that brings clarity and communication about how sustainability has played a role in the selection process.  According to Broadridge data, cross-border ESG fund sales reached $1.2bn from January to November 2020.  Clients would like more detailed descriptions and reporting transparency. 


In 2020, Hong Kong’s Securities and Futures Commission began compiling a list of verified ESG products that have at least 70 per cent of their total net asset value in green or ESG-related investments. There are currently 37 mutual funds and exchange traded funds on the list. 


The European Commission’s sustainability agenda is another example that Singapore could look towards. The agenda’s three key principles are focused on differentiating products with “different shades of green”, mandating the disclosure of the adverse impacts of their investments and forcing a rethinking of fund naming conventions such as the use of the terms “sustainable” and “ESG”. 

Taiwan is also setting up its Green Finance Action Plan 2.0, which was launched in 2020 and includes establishing a unified ESG classification standard. 

Securing broad-based adoption of ESG fund labelling standards across markets in the region would be key to future market development and the emergence of competing local ESG fund labels would be something to watch out for in Asia. The introduction of an ESG fund label would be an important ingredient in Singapore’s plan as Asia’s green financing centre. 

In June 2020, the MAS addressed some of the gaps in local ESG standards by releasing consultation papers that proposed a set of environmental risk management guidelines for financial institutions, including fund firms. This included having asset managers develop risk management tools and metrics such as scenario analysis and stress testing, as well as disclosure requirements on risk management and the impact of material environmental risk. The new rules do not cover standardised labelling for sustainable investment products. 

There is a growing consensus around the world that ESG factors are a key determinant factor in the corporate performance of companies, and would become even more important in the near future, exacerbated in the wake of Covid-19 with increased scrutiny on how companies treat their employees and customers, coupled with the rise of carbon taxes.

According to a report by the Chartered Financial Analyst [CFA] Institute that studies ESG Integration among companies in Asia [CFA Report], among the 3 ESG factors, corporate governance was the main driver of share prices in listed companies in 2017. More importantly however, the report also indicated that social and environmental issues will have an even greater impact on share prices moving forward.

It is worth noting that Singapore listed companies, while ranking amongst the highest in Asia for ESG, surprisingly rank amongst the lowest when rankings are adjusted to only reflect Environmental and Social factors [E/S] as compared to companies in other highly developed economies in Asia such as Hong Kong, Korea, Taiwan and Japan. While this is a testament to the long-standing reputation of Singapore’s good corporate governance, it also highlights how comparatively, environmental and social factors are lacking.

With the rise of institutional shareholding in listed companies all around the world, institutional investors’ portfolio selection of companies can have a very large impact on a company’s share price performance due to the enormous amount of funds they have at their disposal for investment.  Importantly, institutional funds are increasingly screening for E/S factors when making their investment decisions. Taken together, a company that winds up on the negative list of a large international institutional fund such as Blackrock or Vanguard could see its share price drop.

However, one might argue that the impact of a low E/S score in the Singapore context is less pronounced. Afterall, Singapore’s shareholder landscape is dominated by government linked and family-owned companies, where institutional investors do not have a substantial shareholding. Consequently, the impact of an institutional fund’s perception of companies listed in Singapore might not be as pronounced as in the West.

Be that as it may, the implications of having a low E/S score would go beyond altering the perception of institutional investors, to also affecting a company’s reputation amongst their consumers and employees as well. This is especially so in the wake of the Covid-19 pandemic. Also, with the introduction of carbon taxes in Singapore,  the cost of non-compliance by companies would be higher, since companies would have to pay more taxes if they are less fuel efficient and this would in turn negatively affect the financial performance of such companies.

In addition to the financial implications for companies, the stakes are even higher for Singapore, which markets itself an International Financial Centre [IFC]. Scoring significantly lower than the other developed economies in the Asia-Pacific region on environmental and social factors is not beneficial to Singapore’s reputation.


As of 2016, the Singapore Exchange [SGX] has introduced a regime requiring listed companies to publish annual reports on a “comply or explain” basis. However, these sustainability reports issued by companies have been criticised for box-ticking. Critically, companies are seen to be publishing these reports “without a clear sense of what it means for their future”, and whether environmental issues such as climate change would force them to alter their business model in the long term. 

Furthermore, there is no body that serves the function of an independent auditor/regulator monitoring the accuracy and the extent to which these companies actually follow through with the E/S plans they publish in their sustainability reports. In contrast, in Japan, the top ranked economy for E/S factors in the CG Watch Report 2018, most of the corporate disclosures with regard to environmental and social issues have to be sent “to the national regulators for monitoring and compliance purposes”.


There are suggestions as to whether the government should follow the European Union, “which is debating whether to deploy a stick and become a lot more prescriptive in its approach”. In the European Union and the UK where awareness of sustainability issues is high, hard law provisions regulating these issues make sense because compliance is likely to be high.

However, in Asia, where many companies are still trying to grapple with E/S concepts, either due to a strong profit maximisation mindset or simply a lack of information, a softer regulatory regime that focuses on education rather than penalties could be more appropriate. Arguably Singapore is in the latter scenario, and in a phase where companies are still trying to grapple with E/S concepts. However, once E/S factors have gained a stronger traction in Singapore, more can be done to ensure companies continuously look for ways integrate E/S concepts into their business practices such as through instituting harsher penalties for failing to comply with E/S laws and guidelines.

On the other hand, the results have shown that the current approach might not be sufficient on its own to achieve the desired results. At the very least, SGX could improve the current regulatory regime by issuing clearer guidelines on what companies should report on, so that companies will publish useful data that others can reference to make their own E/S related decisions. 

Stewardship is another area of focus which the government could look into to help companies better integrate E/S factors into their businesses. The Singapore Stewardship Code and Family Stewardship Code were Singapore’s unique response to the UK’s Stewardship Code, which itself was enacted in response to the rise of institutional investors as the largest investor group in listed companies in the United Kingdom [UK] and to compel them to play a supervisory role to alleviate the shareholder-management agency problem.

Unlike the UK, institutional ownership of listed Companies in Singapore continue to be small, and Singapore’s shareholder landscape is dominated by family owned and government-linked companies [GLCs]. Singapore’s stewardship codes were designed to signal good corporate governance in the country by keeping up with developments in “Anglo-American-cum global standards of good corporate governance”.

The Singapore Stewardship and Family Stewardship code do “not articulate a singular model of stewardship with which investors should comply”. Secondly, the codes do not employ a “comply or explain” approach, and it operates purely on a voluntary basis. Thirdly, there is no mechanism/metric to determine if institutional investors have complied with the codes. Finally, there is no regulatory agency in Singapore that is responsible for the administration of the codes.

Stewardship Asia, the organisation tasked with drafting the stewardship codes, is only responsible for promoting the code, and does not perform any regulatory function. 

Based on a textual analysis of the Family Stewardship Code, it does not seem to have a huge focus on ESG. ESG factors seem to be implied rather than expressly mentioned in the code, and there are no guidelines on what E/S actually means. For example, Principle 6 of the family stewardship code appears to reflect environmental, social and governance concerns. It states, “Do well, do good, do right; contributing to community”. 

The objective of stewardship codes should go beyond signalling good corporate governance to also aid in the integration of E/S factors into company’s business practices. For example, stewardship codes can help to spread best practice and have an educative effect on companies, preparing companies for the “potential strengthening of hard law provisions” on sustainability in Singapore. Unlike the area of corporate governance, which is predicated on shareholders having a specific amount of corporate control, institutional investors could play an integral role in educating companies on ESG best practices, regardless of the size of their stake in the company.

These institutional investors have better knowledge and experience on how best to integrate E/S practices to boost corporate performance. Also, the presence of clear and fixed metrics in stewardship codes when determining whether stewards have done enough to assist companies on E/S factors would provide the necessary incentives for institutional investors to engage in adequate stewardship since falling short would be detrimental to their reputation, on which they rely on predominantly to attract investors. More importantly, there should be a regulator monitoring stewardship activity in Singapore. 

While every European policy and regulation would have to be tailored to suit Asia’s needs, there is much to be learnt from observing other economies, especially economies which have done better in the E/S sphere. For now, the priority should be to ensure that Asia’s companies are keeping up with global developments in the E/S sphere. While the current arrangement of maintaining the status quo has worked well in the area of corporate governance as evidenced for example by Singapore’s high score in this area, this approach has to be tweaked to facilitate greater integration of E/S factors by listed companies across Asia including Singapore.

Alongside digitalisation, ESG issues are changing the face of infrastructure investment. ESG disclosures represent a different way of gauging the performance of an organisation beyond its balance sheet, focusing instead on its impact on society in general.

And when asked about key considerations for future-proofing their projects, investors reveal that an increased focus on sustainability and the green credentials of projects was the most important.

Recent surveys show that there is a renewed focus on the importance of strong corporate governance and sustainable and diverse supply chains, as well as on the need to finally address the climate crisis.

Sustainable development is the key theme in 2021.

Environmental principles are being closely monitored by investors, and authorities in many regions are giving more importance to environmental regulations.

Other key issues around ESG concern reputational risk which can be mitigated by increased transparency and stronger reporting. Business ethics and transparency are also important for determining the value of a project in the long term.

In line with this need for greater transparency, ESG-specific reporting is becoming fundamental for managers. Indeed, a 2020 survey by Russell Investment of 400 global asset managers found that 49% claimed to offer this type of reporting to clients. The pandemic and climate change concerns among investors can only grow this number.

Awareness grows

Large institutional investors are increasingly aware of pressure to ensure that investments are made in accordance with sustainable principles, and this is as much to do with future-proofing reputations as it is returns. Almost three quarters (74 per cent) cited ESG considerations as being important when contemplating investing in an Asia-Pacific infrastructure project.

Awareness in the region of the power of sustainable finance has been slow to develop and lags behind EMEA and the Americas. This is partly due to the short-term view historically taken by many Asian investors who have understandably been preoccupied with rapid economic development. However, the need for change has become increasingly apparent, with growing levels of pollution and social inequality in the region.

Although the pandemic has reinforced the need to consider the social impact of a project and enhance internal governance processes, ESG principles were becoming better understood in Asia even before COVID-19. In Japan, for example, a leading financial services group announced in 2019 that it would reverse its policy of investing in coal-fired power generation projects.

Environmental issues

Fifty-five per cent of survey respondents cited energy efficiency as the most important consideration when thinking about the environmental impact of their investments. Greenhouse gas emissions and energy efficiency are most important for infrastructure projects. Setting benchmark standards is important as well as putting an emphasis on green development plans.

Controlling deforestation levels was cited as a main environmental objective by some investors. Some investors will ascertain that there are no biodiversity issues when contemplating an investment. If the construction process affects marine or wildlife, organisations has said that they will provide suggestions and alternatives.

Social issues

Forty per cent of survey respondents confirmed that labour standards were the most important consideration when thinking about the social impact of their investments. Human rights, community relations and labour standards are very important for nurturing talent and avoiding social conflicts where projects are being conducted.

Governance issues

More than half (51 per cent) of survey respondents said that political influence was the most important governance consideration when contemplating an investment.

Regulators can play a hugely important role in helping to support sustainable investing and, in this regard, Asia has been something of a pioneer. Hong Kong’s Securities and Futures Commission (SFC) has made it compulsory for listed companies to disclose all of their sustainability credentials while mainland China now requires all listed companies to report their ESG risks.

Supply chain management was cited by 36 per cent of firms as the next most important governance consideration when contemplating an investment. Supply chains have become understandably unstable during the pandemic, while many large global manufacturers previously diversified some of their supply chains out of China to cheaper countries in the region (South Korean conglomerate Samsung shifted its mobile phone manufacturing to Vietnam).

With rising regulatory pressure, emerging focus on reputational risk and increasingly complex supply chains, respondents said it was now vital that organisations take third-party risk management seriously.

The future

ESG and technology will be central to the success of all infrastructure projects in the coming years. Investors and project leaders can meet their environmental requirements through the use of renewables and hydrogen.

The future of renewables – Renewable energy trends are catching on in Asia-Pacific and are increasingly supported by governments in the region. It is hoped that renewable energy zones and the adoption of solar energy practices will open up new opportunities for investors in the future. Sixty-four per cent of survey respondents agree that the financial closure of a significant number of renewable energy projects in Asia-Pacific in 2021 will have a positive influence on other infrastructure investments across the region.

Renewable energy projects will increase because countries have set targets to be met within the next few years to reduce their carbon emissions. Since announcements have been made, they will have to think about the means to fulfil these targets. Nearly three-quarters agree that the generally lower capital cost of renewable energy projects compared to social and transport infrastructure makes them a relatively more attractive asset class in emerging Asian economies. Renewables trends will catch on as more investors are focused on adopting strong ESG principles.

Meanwhile, a pointer to where the market is headed can be seen by how quickly the oil majors are looking to make the transition into renewable and low-carbon projects. For example, in October 2020, Shell announced it would increase its spending on low-carbon energy to 25 per cent expenditure by 2025; around the same time, its rival BP vowed to grow its investment in low-carbon energy tenfold to US$5 billion per year by 2030.

Hydrogen: The wave of the future – Given the potential to reduce the cost of energy generation and usage in Asia, 16 per cent of survey respondents intend to invest in hydrogen as a non-carbon transportation fuel. For a region that is still largely dependent on oil imports and is struggling to quit its addiction to coal, hydrogen offers Asian countries a ‘clean’ alternative and a crucial boost in their transition towards developing sustainable economies.

China and Japan are the two largest net importers of fossil fuels in the region. But the Japanese government has set an ambitious target to have a complete hydrogen society by 2050. This includes reducing the price of hydrogen by 90 per cent, which would make it cheaper than natural gas. Meanwhile, South Korea unveiled its ‘roadmap for a hydrogen economy’ in 2019, with a vision to sharply increase production of hydrogen-powered vehicles and electricity generation by hydrogen. Like Japan, it has made clear its intention to import clean hydrogen from countries that can produce it competitively and reliably. Investors have realised the higher value there is to gain from renewable energy generation practices. The use of battery and hydrogen storage will form a major part of renewables projects.

Sustainable Investing – EU Regulations

The Sustainable Finance Disclosure Regulation (SFDR):

This article serves to help investors understand the SFDR and why it is important as at 10 March 2021 with update as at 17 March 2021.

What do Investors want?

Investors increasingly want to take a more environmentally and socially conscious – or sustainable – approach to investing. The good news is that the choice of sustainable products is growing; however, the wide range of products and a lack of common standards across the sustainable finance industry can make it difficult to compare sustainable investing options.

What is the purpose of the SFDR?

The European Union Sustainable Finance Disclosure Regulation (SFDR) is designed to make it easier for investors to distinguish and compare between the many strategies that are now available, and by extension, to support the move to sustainable investing. The SFDR helps investors by providing more transparency on the degree to which financial products have environmental or social characteristics, invest in sustainable investments, or have sustainable objectives. This information will now be presented in a more standardised way.

The SFDR requires specific firm-level disclosures from asset managers and investment advisers regarding how they address two key considerations: Sustainability Risks and Principal Adverse Impacts. In addition, it helps investors to choose between products by classifying funds into three distinct groups, according to the degree that sustainability is a consideration and binding investment criteria, with specific disclosures required for each. These disclosures are determined based on the type of fund:

  • “Article 6” strategies either integrate environmental, social or governance (ESG) considerations or explain why sustainability risk is not relevant, but do not meet the additional criteria of Article 8 or Article 9 strategies.
  • “Article 8” strategies promote social and/or environmental characteristics, and may invest in sustainable investments, but do not have sustainable investing as a core objective.
  • “Article 9” strategies have a sustainable investment objective.

This post explains the SFDR and the importance of this new regulation and how it will impact asset managers, advisers and investors alike. The disclosures, effective from 10 March 2021, apply to many financial products, including UCITS, AIFs and segregated mandates.

Why important?

Re-orienting capital towards sustainable growth

European Union (EU) governments and business leaders realise that one of the best ways to achieve the sustainability goals is to encourage capital to flow towards efforts that promote a more sustainable economy. Many investors also want to support a more sustainable economy, but often lack enough information to assess and compare investment options on the basis of standards. To that end, the EU has put together a sustainable finance action plan (EU Action Plan on Sustainable Finance).

This action plan is a major step towards redirecting capital to the sustainable economy. The plan features a series of interlinking regulations designed to encourage sustainable investing, including the SFDR.

Helping clients make better sustainable investing choices

The primary goals of the SFDR are to provide greater transparency on sustainability within the financial markets and create standards for reporting and disclosing information related to sustainable investing.

Increasing transparency and introducing standards promotes two important additional effects. First, it makes it hard for private banks and asset managers to “greenwash” their products – in other words, they cannot simply brand a product with an ESG or sustainable label, without actually having the process and portfolio to back it up.

Second, investors enjoy a significantly improved ability to compare investment options in terms of sustainability and ESG factors, which helps them make informed decisions that align with their investing goals.

Who is affected and what types of products and services does it apply to?

The SFDR applies to all financial market participants and financial advisers based in the EU. A financial market participant is any firm creating investment products, or generally, an asset manager. Financial advisers are individuals providing investment or insurance advice.

Investment managers or advisers based outside of the EU, who wish to market their products to clients in the EU under Art. 42 AIFMD, will also need to follow the SFDR disclosures.

Disclosures will apply to UCITS, AIFs, separately-managed portfolios, sub-advisory mandates and financial advice.

The UK is currently out of the scope of the SFDR and the UK as yet does not intend to adhere to the regulation as set out by the EU. In time, the UK may decide on a different set of sustainability disclosure rules for UK legal entities and products, or elect to replicate the SFDR requirements. We will need to wait and see.

What are the new sustainability and ESG product categories and disclosures?

Investors are navigating record-breaking growth in assets and product choices

Sustainable and ESG investing are among the fastest growing types of investment strategies. 2020 was a record-breaking year: assets under management in European sustainable funds rose over 50% to reach EUR 1.1 trillion; meanwhile over 500 new sustainable funds were launched and over 250 repurposed or rebranded, bringing the total number of European sustainable funds to almost 3,200 at year end according to Morningstar, European Sustainable Funds Landscape: 2020 in Review, 3 February 2021.

The tremendous growth in products spans all asset classes and product ranges – from equities to bonds and from ETFs to separately managed accounts. Even more critical for investors is the wide range of how sustainability and ESG strategies are managed. Some strategies are explicitly focused on sustainability and have specific impact goals. At the other end of the spectrum are passive ESG ETFs. In between are thousands of strategies with widely varying levels of sustainability or ESG integration into their investment processes.

Differentiating between Article 6, Article 8 and Article 9 products

One of the goals of the SFDR is to help investors better differentiate between the many sustainability and ESG products by creating classifications and disclosures. The SFDR specifies three distinct categories for investment products with regards to sustainable and ESG considerations:

Article 6 products are “other” investment products that either integrate considerations or explain why sustainability risk is not relevant, but do not meet the additional criteria of Article 8 or Article 9 strategies. Article 6 products will need to disclose the manner in which sustainability risks are integrated into their investment decisions as well as an assessment of the likely impacts of sustainability risks on the returns of the financial products.

Article 8 products promote environmental and/or social characteristics, and may invest in sustainable investmentsbut do not have sustainable investing as a core objective.

Article 9 products have sustainable investment as their core objective. The SFDR defines sustainable investment as an investment in an economic activity that contributes to an environmental or social objective, provided that the investment does not significantly harm any environmental or social objective and that the investee companies follow good governance practices. Article 9 products must invest primarily in sustainable companies or companies that demonstrate improving sustainable characteristics that contribute positively to a particular outcome, such as a low carbon economy.


Principal adverse impacts of investment decisions and investment advice on sustainability factors

The EU’s Sustainable Finance Disclosure Regulation (“SFDR”) requires financial market participants and financial advisers to publish and maintain on their websites a statement on whether they consider principal adverse impacts of investment decisions and investment advice respectively on sustainability factors. Principal adverse impacts are not currently considered in relation to investment decisions or advice in accordance with SFDR as the corresponding regulatory technical standards have not yet been finalised. Ongoing monitoring for further regulatory guidance and the development of industry and market practice is in place and it is expected to consider such adverse impacts from 30 June 2021.

Outstanding points regarding SFDR

The first set of SFDR disclosures are effective 10 March 2021. There remain a few areas for investors to watch, where the guidance is not finalised:

  • The draft Level 2 regulatory technical standards (RTS) disclosures were released 4 February 2021. Approval for these proposed standards remains outstanding but is expected in the medium term.
  • Following the completion of Brexit, it is not yet known whether the UK will adopt the SFDR or a different set of regulations for UK-based asset managers and advisers.
  • Third party data providers, such as MSCI, which are not directly covered under the SFDR, will need to clarify how they will incorporate the new SFDR disclosures into their sustainability-related data, research and rankings.
  • Third party ESG related industry standards will need to the reviewed as they get updated to align with SFDR and the EU Taxonomy Regulation.
  • The adoption of amendments to the delegated acts (DAs) under the UCITS, AIFMD, MiFID II, IDD and Solvency II frameworks on the integration of ESG considerations remains outstanding, but is expected to be confirmed in the medium term.  Guidance for handling data requests from individual clients, such as insurance and sub-advised business, is not yet finalised.

Next Steps

The SFDR is a positive step in the growth and development of sustainable investing. As investor interest in sustainable investing continues to grow, the regulation offers clients clear comparisons and advice on sustainable investments, encouraging private banks, asset managers and advisers to help capital flow towards sustainable investment products. Commencing January 2022, this regulation will be followed by the EU Taxonomy Regulation. More information on this regulation, and how it interacts with the SFDR will made available in due course.

ESAs consult on bringing Taxonomy disclosures and SFDR disclosures together into one ‘rulebook’

On 17 March 2021, the European Supervisory Authorities (ESAs) published a consultation paper with an updated version of the draft SFDR RTS (updated from the version included in the previous 4 February SFDR Final Report) – but this time to include Level 2 provisions proposed under the Taxonomy Regulation.

I have been helping clients achieve their sustainable investing goals. If you would like further information or have questions about the SFDR, sustainable investing and/or ESG in general, please contact me at info@mirandabrawn.com.

Happy International Women’s Day 2021 – Choose to Challenge with Action

Will you choose to challenge with action? We can all play our part today and everyday in and out of the workplace.

The above photo is part of the Guildhall Art Gallery’s permanent Photography Exhibition by award winning artist Hannah Starkey. This was showcased to celebrate International Women’s Day 2020 where Dr Miranda K. Brawn Esq was personally chosen to be one of the 12 amazing women who have made a positive impact in the City of London. You can view the exhibition online or in person. It is a permanent fixture in the heart of the City of London for many future generations to view.

The Launch of #The60SecondCoach with Dr Miranda K. Brawn Esq on BBC Radio!

Welcome to the Launch of #The60SecondCoach! This is your opportunity to get “Success Building Made Simple” in 60 seconds. Each week a 60 second video will be available to give you a taster of Miranda’s coaching programs.

Success is not about luck or intelligence. It is about persistence, determination, discipline, and making good informed decisions. Your first good decision when it comes to becoming successful is investing in yourself, so invest in yourself TODAY, before it is too late! This may be investing your time which can be as little as 60 seconds to watch Miranda’s videos on success tips and/or to book a personal coaching session with Miranda for 30 or 60 minutes.

You can contact Miranda’s team to book a group or individual session for success using tried and tested proven formulas.

Follow on Instagram: https://www.instagram.com/the60secondcoach_/

These days everyone is a life coach. Simply attend a networking event and an endless stream of former something-or-others stand ready to help you find your authentic self, chase your passion, or strike balance in a lopsided world. Hire the right one for the right reasons and over time, you will make progress. You might even capture that ever-elusive ROI. Make a misstep however, and you will simply spin your wheels chasing an ill-defined ideal with a well-intentioned stranger.

So what should you do if you are short on time, patience, or financial wherewithal? What if you are focused on a specific goal and the thought of a broad-based, soul-stirring conversation leaves you motion sick? 

Contact Dr Miranda K. Brawn Esq to book a personal coaching session via www.mirandabrawn.com and/or info@mirandabrawn.com for more information on how she can help you achieve your goal of success!

So are you going to book Dr Miranda K. Brawn Esq for success? Be quick because there is an early bird rate if you book by 21st March for the 28th March group sessions which is available for both students and professionals! Alternatively, you can book Miranda for individual coaching sessions.

Further details can be located in the previous post which has been included below for ease of reference.

Dr Miranda K. Brawn Esq will also be on ‘BBC Radio’ to celebrate the launch of “The 60 Second Coach” on 7th March 2021! This will also be available globally on ‘BBC Sounds’ from International Women’s Day 2021 on 8th March 2021.

Success Coaching Sessions with Dr Miranda K. Brawn Esq: Group or One-to-One sessions available from Sunday, 28th March 2021 – Brawn University

Are you ready to build your success?

Dr Miranda K. Brawn Esq Coaching Sessions – Brawn University: You have an opportunity to get coached in person by Miranda Brawn. How would you like to ask her any question you want—finances, business, real estate, career—it is all on the table. Get on Brawn University and book your coaching session today!

Dr Miranda K. Brawn Esq will give you exclusive guidance to help you achieve your goals and take your life to the next level of success with her proven, tried and tested 20-plus years experience and results!

Build your confidence and much more to start and/or grow your success with the personal, direct, and highly intuitive motivational coaching of the one and only Dr Miranda K. Brawn Esq.

When it comes to building your success in an unconventional way, Dr Miranda K. Brawn Esq is the Queen! From her early days as a teenage investment banker to her time as an equity sales trader followed by banking lawyer, and now her work includes being an industry-leading international motivational keynote speaker, board advisor and consultant, Miranda has built her own form of success.

Miranda is helping thousands of people around the world achieve their goals and take their life to the next level of success through her coaching and international talks.

Her message resonates with so many people because of her story. She has built her success from her potential, competitive nature, and relentless drive for what she wants. By tuning out the people who told her no, she has become a significant award winning role model to anyone is wants to create a life that is so much more than others ever expected from them.

If you want to exceed expectations, Miranda’s coaching will make you soon realise that you to have the power and the responsibility to build your success and give back to the world so others can benefit from the legacy you leave behind you.

Book Dr Miranda K. Brawn Esq for success coaching session(s) – both group and individual sessions are available to students and professionals / executives etc across the globe.

Group Coaching with Dr Miranda K. Brawn Esq

What you get:

  • Group meeting up to 10 people with Dr Miranda K. Brawn Esq via Skype/Zoom.
  • Sit with Miranda and map out your success each week.
  • Miranda will help you to achieve your goals and create your plan.
  • Single or Six-Week Program: Group 60-minute coaching sessions with Miranda covering a range of key skills each week for success. An introductory “free” coaching session offer if you book the six week program.

Next group sessions will start on Sunday, 28th March 2021 at 3pm (GMT) for students and 5pm (GMT) for professionals / executives.

1-on-1 Coaching with Dr Miranda K. Brawn Esq 

What you get:

  • One on one face to face meeting with Dr Miranda K. Brawn Esq (or via phone/Skype/Zoom depending on schedules, country and COVID-19 lockdown government restrictions).
  • Sit with Miranda and map out your success and where you want to take it, how big do you want it to be, who’s going to be in it, what are the rules, and what are you willing to do to protect it.
  • Bring your biggest challenges in life and business and Miranda will help you BEAT them.
  • Single or Six-Month Offer: One-on-one 30-minute monthly coaching sessions with Miranda for 6 Months or on an individual basis.

The coaching programmes are designed to transform your life (or certain areas of it), not just add value to it. Miranda wants you to have total clarity of vision, unstoppable confidence in yourself, reach social mastery, become a remarkable leader, and operate on the highest level of performance possible – whatever it is that you need and want the most.

The aim is to provide not only world-class coaching, but also a coaching experience parallel to the Michelin-starred restaurant dining experience.

You would have direct access to Miranda over the course of the programme, and her large network would become your network.

For Miranda’s one-on-one coaching sessions, she works differently with everyone, simply because everyone she works with is different. She does not follow any templates because each time she will design a completely bespoke, perfectly fitted coaching programme for the person in front of her.

Miranda’s personal coaching sessions are a true investment in yourself. The price is dependent upon the complexity of what you will work on and consequently the length of the programme required. She brings enormous value and energy to her clients’ lives and she charges accordingly.

Her clients include students and young professionals to mature professionals / executives, CEO’s and start-up founders etc.

The pricing varies accordingly for students to professionals / executives etc and individual vs block bookings.

Early bird rates are available for those who book their coaching sessions by Sunday, 21st March 2021.

Email info@mirandabrawn.com for further details and to book your date for success today!

Dr Miranda K. Brawn Esq gives opening keynote address on “The Rise of Women within Technology and ESG in Pakistan” to Pakistan’s First Female University “Jinnah University for Women” (JUW) to celebrate International Women’s Day 2021 on 6th March in Karachi helping to close the gender gap globally!

Press Release for 1st March 2021: Founder and President of Foundation launches first “Black Women on Boards” Scholarship and Reverse Mentoring Programme to celebrate International Women’s Day 2021

On 1st March 2021, to help to celebrate International Women’s Day on 8th March 2021, The Miranda Brawn Diversity Leadership Foundation will launch a “Black Women on Boards” initiative and an innovative reverse mentoring programme with senior leaders.  

The “Black Women on Boards” initiative includes a scholarship for full-time student leaders who are from a Black African and Caribbean heritage including mixed race backgrounds. This is to increase the number of black women in the boardroom and within senior management. Other new diversity leadership scholarships launching for 2021/2022 will include “LGBTQ+” and “Disability”. The Miranda Brawn Diversity Leadership Foundation website has further information and the scholarship application process will open on the first day of International Women’s Month which is on 1st March 2021 via www.tmbdlf.com.  The closing date for applications is 31st July 2021.

This new initiative is due to the lack of black female directors at FTSE350 and Fortune 500 companies. The number of female directors at FTSE-100 firms has increased by 50% in the last five years, and mostly white women now hold more than a third of roles in the boardrooms of Britain’s top 350 companies, according to the Hampton-Alexander review. BoardEx data reveals that only around 3% of female board-level roles are held by women of Black, Asian or minority ethnic heritage in the UK’s 350 largest listed companies. Recent research also highlights that for the first time in six years, there are no Chairs, CEOs or CFO who are Black in the FTSE100. This data shows the scale of the challenge for companies to increase social and racial equity.  

Dr Miranda K. Brawn Esq., Financial Executive, Lawyer, Strategic Board Advisor, Founder and President of The Miranda Brawn Diversity Leadership Foundation said:  

There has been good progress promoting white women to the Boardroom and in senior management positions. However, there is still a lot more work to be done to make sure that we include women from all ethnic backgrounds. This is the rationale for launching the ‘Black Women on Boards’ scholarship.” 

We have also launched an innovative reverse mentoring programme to initially cover business, finance, law and politics. This will compliment our existing mentoring programme by allowing diverse students and our alumni leaders to act as mentors to senior leaders. Mentors will share their perspective and experiences and in so doing inform those making leadership and business decisions to help increase diversity, equity and inclusion. These will be leaders at the top of their profession who are CEO’s of global organisations, judges, managing directors, board directors, Members of Parliament and so on where everyone can learn from each other.”  

For this year’s International Women’s Day, I would like to dare everyone to ‘choose to challenge’ with action not just on the 8th of March, but every single day. With collaborative efforts, we can increase the number of black and mixed-race women in the Boardroom and in senior management leadership roles. We all have a role to play in making a difference and pushing for progress.”  

Dr Miranda K. Brawn Esq in the boardroom of an investment bank in the City of London
The Voice Newspaper – https://www.voice-online.co.uk/news/sponsored-news/2021/03/01/foundation-launches-first-black-women-on-boards-initiative-to-celebrate-international-womens-day/
Brixton Blog – https://brixtonblog.com/2021/03/scholarship-to-boost-black-women-business-leaders/

Dr Miranda Brawn’s Education and Diversity Charity TMBDLF teams up with Hogan Lovells for her 5th Diversity Leadership Annual Lecture on Inclusion & Black Lives Matter

Press Release

The Miranda Brawn Diversity Leadership Foundation (TMBDLF) Education and Diversity Charity and Hogan Lovells join forces for Inclusion and Black Lives Matter

The Miranda Brawn Diversity Leadership Foundation and International Law Firm Hogan Lovells (https://www.hoganlovells.com) have teamed up to work towards helping our next generation of diverse student leaders and closing diversity gap in the workplace with a focus on Inclusion and the Black Lives Matter movement.

The fifth Miranda Brawn Diversity Leadership Annual Lecture will be the Charity’s first virtual event which is being sponsored and hosted by Hogan Lovells on the evening of 1st October 2020. Further details will be available via https://www.tmbdlf.com/copy-of-mentorship This is in partnership with Hogan Lovell’s “National Inclusion Week” event and to celebrate the first day of UK Black History Month. 

National Inclusion Week via Inclusive Employers takes place from 28th September to 4th October 2020. The week is designed to celebrate everyday inclusion in all its forms! Sharing, promoting and inspiring inclusion practices and culture: together, we will build and develop the inclusion momentum, everyday. The theme for National Inclusion Week 2020 is Each One, Reach One. It is about the opportunity that we all have to connect with someone else, or another organisation, to help them understand the opportunity of inclusion and connect. It is about individuals and organisations connecting and inspiring each other to make inclusion an everyday reality. Together, we will build the biggest inclusion chain ever.

Founder and CEO of the Miranda Brawn Diversity Leadership Foundation, Dr Miranda Brawn Esq said: “I am delighted that our founding supporter Hogan Lovells are sponsoring and hosting our fifth Miranda Brawn Diversity Leadership Annual Lecture event. This year is extra special because we are five years old and this is in partnership with their National Inclusion Week event. The theme “Each One, Reach One” is in line with my Charity’s ethos “Together we can change the world” hence the perfect fit. This year, my diversity leadership lecture will be focused on inclusion and the Black Lives Matter movement as this was one of the main reasons why my Charity was launched in the first place. We are continuously looking for ways to continue and lead in an innovative way while partnering with other organisations and individuals to help make positive changes.

The annual diversity leadership lecture events are inclusive of all diversity strands such as gender, race, LGBTQ+, disability, religion, faith, social mobility etc. This includes multiple industries and sectors such as finance, business, law, science, technology, engineering, arts, mathematics, politics, fashion, media, entrepreneurship etc.

The winners of the annual diversity leadership scholarships will also be announced during this event. I am looking forward to finding out who will be our top next generation diversity leaders this year joining the Foundation family.

The Miranda Brawn Diversity Leadership Annual Lecture is the perfect opportunity to (i) educate, empower and inspire our audience on education, career and diversity; (ii) celebrate the outstanding and inspiring achievements of our future diversity leaders; and (iii) raise the awareness of diversity and equality and the importance of action. 

​The lecture has an innovative concept with a strong focus on intersectionality which appeals to its diverse audiences. This consists of next-generation diversity leaders, their parents and current leaders in the workplace who wish to learn more about diversity and how they can make an impact by implementing our key tips in their schools, universities and workplaces. 

​The first Miranda Brawn Diversity Leadership Lecture made UK history in October 2016 as the first of its kind aimed at school children from a Black, Asian and minority ethnic background aged between 14 to 21 years old and continues to lead as a key annual diversity event in the UK.