As detailed in our other ESG briefings, with the aim of
furthering sustainable finance and ESG integration, the European
Commission (the "Commission") introduced
a package of legislative measures in 2018 that includes three key
Regulations: the Taxonomy Regulation, the Disclosures Regulation,
and the Low Carbon and Positive Impacts Benchmarks Regulation. The
underlying impact assessment to this legislative package also
demonstrated that it was necessary to make clear that UCITS
management companies (including self-managed UCITS) and AIFMs
(together "Management Companies") should take
sustainability risks and factors into account as part of their
duties towards investors. Accordingly, Management Companies should
be assessing not only all relevant financial risks on an ongoing
basis, but also all relevant sustainability risks. In addition,
their internal processes, systems and controls should also reflect
these risks. Therefore, following the publication of
