An update on the Financial Conduct Authority Sustainability Disclosure Requirements and Anti-greenwashing rules
Holden & Partners was formed over 20 years ago. Since our inception, we have placed an ethical and sustainable focus at the heart of our client proposition.
During this time there have been significant changes to regulation, charging and investment approaches across the industry. Nothing illustrates this more than the recent Financial Conduct Authority (FCA) Sustainability disclosure and labelling regime and anti-greenwashing rule which both come into effect in 2024.
The Sustainability Disclosure Requirements (SDR) policy statement (PS23/16) released by the FCA in November 2023 was implemented to set out their final rules and guidance to help consumers navigate the market for sustainable investment products. The initial set of rules are designed to be used by asset/fund managers whilst the ‘Anti-greenwashing rules’ set out as part of this policy (that were expanded upon last month) statement encompasses all FCA regulated firms – such as Holden & Partners.
Last month the FCA started the process of extending the entire set of rules especially those around the labelling of offerings to wealth manager’s such as Holden & Partners. This is done through a consultation paper (CP24/8) which will be released as a policy statement before their intended implementation on 2nd December.
As a firm we have already carried out considerable work on these new sets of regulations. We continue to review the proposals and rules ahead of their implementation (2nd December 2024 for Sustainability labelling and 31st May 2024 for anti-greenwashing).
We are supportive of the FCA’s desire to stop greenwashing and provide more clarity to consumers on investment solutions that make claims towards having a positive environment and social impact. In particular, we agree that any claims made around the sustainability of any recommended solution should be clear, balanced and suitably evidenced. Whilst we are also broadly supportive of the wider consultation on sustainability labelling, we await further developments and will need to closely consider the impact on client outcomes – particularly in the short-term – that this may lead to.
Crucially, our Investment Team have a documented and rigorous process for researching, analysing, reviewing and monitoring funds held within our model portfolios and this includes a focus on any potential sustainable claims that are made by the fund managers and the funds that they manage. Whether this is from a negative or positive screening viewpoint. When building portfolios, we have always deemed it integral to balance our fiduciary duty of risk adjusted returns with sustainability and this will remain the case.
The bedrock of our approach to sustainability has been the belief that long-term prosperity of individuals and the wider economy is inextricably linked to healthy ecosystems and a flourishing fair society. To us, sustainable investment strategies are those that support development opportunities that meet the needs of the present without compromising the ability of future generations to meet their own needs.
Updates will be provided in the coming months but if you would like any additional information in the meantime, please contact info@holden-partners.co.uk