The Quality Standard

The Quality Standard for Sustainable and Socially Responsible financial products was published on 7 February 2019.

It was developped at the initiative of Febelfin, in consultation with a diverse group of financial and civil society stakeholders.

Objective

The objective of the quality standard is to qualitatively and quantitatively increase the level of socially responsible and sustainable financial products, and to mainstream its principles towards traditional financial products.

Socially responsible and sustainable financial products are currently somewhat a niche market. Socially responsible investment products (SRI) have a market share of about 5-10% (depending on the scope and definition used), while socially responsible savings products have a share of about 1% of total savings.

It is evident that to have any meaningful impact on the transition towards a sustainable economy and society, the integration of sustainability considerations (ESG) should also go beyond this niche and into mainstream financial products and services.

This mainstreaming is already happening as more and more financial institutions implement group-wide ESG policies that are applicable to all their credit and investment decisions. Other notable developments are the industry-led Task Force on climate-related financial disclosures set up by the Financial Stability Board, the work of the High-Level Group on Sustainable Finance established by the European Commission, the EC Sustainable Finance Action Plan (e.g. Taxonomy and Disclosure regulations) and regulations on non-financial reporting (non-financial reporting directive 2014/95/EU, IORP 2, SRD 2, France’s Art. 173, etc.)

Approach

The benchmark for this quality standard are the needs of society and the expectations of the fast-growing group of savers and investors with a special interest in the responsible and sustainable character of their savings and investments.

Clients should be able to rely upon the assumption that the money they put into a 'socially responsible’ financial product shall not be used to finance activities and practices generally accepted as 'unsustainable', and shall, to a greater or lesser extent, be used to finance activities with a positive contribution to society.

With that objective, the quality standard requires exclusion of the financing of a limited number of practices that are widely regarded as unsustainable. The focus however lies on transparency and the provision of relevant and helpful information, by which potential clients can determine if the policy of a specific product is in line with their personal convictions.

The quality standard stipulates a set of portfolio and process level requirements which a financial product should at least fulfil to receive the label. However, distributors and product managers are strongly encouraged to formulate their own approach and objectives regarding sustainability that go beyond the minimal requirements stated in the standard.

The standard does not pretend to define or enshrine what it means to be a ‘sustainable’ financial product, as that would fail to acknowledge the evolutive and aspirational character of sustainability. Compliance with the principles of the standard should rather be interpreted as a sign that a product is on the road towards sustainability. The progress made on that road and so also the degree of sustainability will differ between products, depending on their strategy and level of ambition. However, being in line with the standard implies that a manager is taking up its social responsibility by having in his decisions particular and substantiated consideration for social, environmental and governance issues thus also safeguarding long term financial performance.

Practical implementation

The quality standard does not stipulate how the requirements should be fulfilled in practice: this is left to the expertise of the product manager. The product manager should put in place the internal organisation, processes and resources he deems necessary to be able to comply with the requirements, on a best effort basis. Based on his best judgement and expertise, he should select the most appropriate instruments, data providers, third-party exclusion lists, etc. This might, in some cases, lead to diverging interpretations by different product managers on the eligibility of a specific company. This does not however, need to be problematic, if the manager is accountable, open and transparent about his decision-making process.

Accountability is key. It is the preparedness to give an explanation or justification to stakeholders for one’s judgments, intentions, and actions. It is a readiness to have one’s actions judged by others and, where appropriate, accept responsibility for errors or misjudgements, and recognition for competence, conscientiousness and excellence. It is associated with responsiveness to the views of all stakeholders, which includes a willingness to explain, defend, and justify actions or decisions.

The quality standard uses a principles-based approach. Key characteristics and features that are essential for a credible socially responsible product are formulated. These principles are accompanied by implementing guidelines that specify how the principles should be interpreted and that give guidance when implementing them in specific portfolios, always keeping in mind the investors’ expectations that the money they invest in socially responsible financial products should not flow to or benefit unsustainable activities.

The standard provides a mix of exclusion, impact, engagement, transparency and accountability. The balance of these elements and the specific requirements associated, will evolve and be adapted over time to reflect the evolving expectations of investors and the needs of society, and the legislative translation of these needs and expectations. As such, the quality standard is not fixed and shall be evaluated regularly in a multi-stakeholder context, as to assure its relevance to society.

Review

A quality standard dealing with sustainability is dynamic and evolutive by nature. As such, it will need to be reviewed on a regular basis.

A first review is planned in 2020. This review will aim to fine-tune and upgrade the quality standard taking into account, among others:

  • the evolution of societal needs and client’s expectations
  • the implementation of the EU action plan on sustainable finance and specifically the EU classification system of sustainable economic activities ('taxonomy') regarding environmental and esp. climate-related indicators
  • new academic research and the increased availability of consistent, uniform and qualitative data on specific metrics
  • market conditions related to the segment of socially responsible and sustainable financial products

Text of the Quality Standard

The full text of the Quality Standard including all detailed criteria, can be consulted here.