1. THE NEW DEMANDING INVESTMENT
ENVIRONMENTAND THE APPLICATIONOF ESG
CRITERIAIN OCCUPATIONALFUNDS’
INVESTMENTSTRATEGIES
Presenter:Justin Wray
Department:PolicyDepartment
Date:23 February2022
EIOPA REGULAR USE
3. WHY PENSION FUND INVESTMENT MATTERS?
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Source: Final Report, submitted to European Commission & Financial Services User Group
under the tender: Who owns the European economy? Evolution of ownership of EU-listed
companies between 1970 and 2012, page 4.
MARKT/2012/077/H
Breakdownof Investmentfunds/shares – EU-wide Q3 2021
4. For IORPs - included in the Directivebut not mandatory
Article 19(1)(b) IORP II:”within the prudent person rule, Member States shallallow IORPs to take into account
the potential long-termimpact of investmentdecisions on environmental, social, and governance factors”
For PEPP providers - included in the PEPP Regulation Proposal as mandatory
Article 41(1)(b) PEPP Regulation: “within the prudent person rule, PEPP providersshall take intoaccount risks
related to and the potential long-termimpact of investment decisions on ESG factors”
WHAT ARE THE ESG REQUIREMENTS AT EUROPEAN LEVEL ON
PENSION FUND INVESTMENTS?
5. WHAT ARE THE NEXT STEPS?
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“Ask EIOPA to assess the need to
review the fiduciary duties of pension
funds and investorsto reflect
sustainabilityimpacts as part of
investmentdecision making
processes,including stewardshipand
engagementactivities by 2022”
Source: EuropeanCommission,Strategy forFinancing the Transition to a Sustainable
Economy,6 July 2021
6. WHAT ARE THE ISSUES TO CONSIDER? (I) DOUBLE
MATERIALITY’
7. WHAT ARE THE ISSUES TO CONSIDER? (II) PRUDENT PERSON
RULE
Insurance: changes to the prudentpersonprinciple:
Integration of sustainabilityrisksinthe prudentpersonprinciple.
“When identifying,measuring,monitoring,managing,controlling,reportingandassessingrisksarising from investments,as
referredtoin the firstsubparagraphof Article 132(2) of Directive 2009/138/EC, insurance and reinsurance undertakings
shall take into account sustainabilityrisks. “[italicsadded]
Article 275A SolvencyII delegatedregulation
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8. WHAT ARE THE ISSUES TO CONSIDER? (III) DISCLOSURE
The Sustainable Finance Disclosure Regulation(SFDR)requires IORPsto disclose and act on their
environmentaland socialmateriality ina standardiseddue diligence statement onPrincipal Adverse
Impacts:
on a “comply or explain” basis forIORPs< 500 employees.
Disclosure onthe impact of investments on: energy efficiency,GHGemissions,gender diversity on boards
All pension schemes to disclose onthe manner they integrate sustainability risksininvestment decisions
The SFDR aims at preventinggreenwashing,by bringing in harmonisedrequirements,requiring pension
schemes,pensionproducts and PEPPs with a sustainability ambition to disclose ontheir sustainability
features,includinginformationon whetherinvestments are Taxonomy-aligned
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10. BENEFITS TO A EUROPEAN APPROACH ON PENSIONS
Internal market
Labour mobility
Sources of capital
Member protection
Transparency
Force for improvement
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11. OPINION ON COSTS AND CHARGES
NCAs are expectedto collect annual informationfromIORPs oncosts
using generic classification:investment costs,transactioncosts,administrative costs andcosts borne
directly by sponsors
templates to assist NCAs andIORPs to collect costs
NCAs shouldexpect IORPs to followa number of principles in compiling the cost information,most notably
the look-throughprinciple
NCAs are expectedto conduct comparativeanalysis ofIORPs’costs to feedinto the supervisory review
process
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12. OPINION ON DEFINED CONTRIBUTION RISK MANAGEMENT
Two aspects of risk assessment that are relevant forDC IORPs:
1. quantitative elements in operational risk management,supplementingthe guidance in EIOPA’s existing
opiniononoperational riskmanagement
2. projections of future retirementincomeinlong-termrisk assessment fromthe perspective of members
and beneficiaries,also ininteractionwiththe
determinationof the risk tolerance of members andbeneficiaries,and
design and review of investment strategies
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13. PENSION TRACKING SYSTEMS AND DASHBOARDS
Old-age dependencyratio(65+/20-64) in the EU is projectedto rise from
34.4% in 2019 to 59.2% in 2070
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16. ASSETS IN RETIREMENT SAVINGS PLANS (% OF GDP)
Retirementsavingsplans
as a percentageof GDP
Austria 6.6
Belgium 40.4
Czech Republic 9.5
Denmark 229.4
Greece 1.0
OECD 99.9
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Source: OECD Global PensionStatistics,websites andannual reports of reserve funds orother national
authorities
StatLink https://stat.link/qi2ev9