On January 22 2018 aba has submitted its reponse to the European Commission’s consultation on „Institutional investors and asset managers' duties regarding sustainability“. In its answer (presented here in both German and English), the aba welcomes that the EU Commission promotes the inclusion of ESG aspects in investment decisions and the risk management of IORPs. However, it is essential to note, that in making investment decisions ESG-criteria can only be one among many other factors.  

Further, the aba considers it is appropriate to require IORPs to explain in what ways ESG-aspects are part of their business and investment policy. However, such requirements must remain completely qualitative in nature. The same applies to the description of risks related to these factors (e.g. climate change).

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