ESG 5.2 Consumer-facing disclosures

A manager that is required to prepare and publish a consumer-facing disclosure under ESG 5.1.1R must include in the consumer-facing disclosure for the relevant product:

1. (1)

   where it uses a sustainability label in relation to a sustainability product, the information in ESG 5.2.2R; or

2. (2)

   where it does not use a sustainability label in relation to a sustainability product, but uses one or more of the terms in ESG 4.3.2R(2) in accordance with ESG 4.3.2R(1), the information set out at:

   1. (a)

      ESG 5.2.2R(1) to ESG 5.2.2R(4), ESG 5.2.2R(7)(a) and (b), ESG 5.2.2R(8)(b) and (c) and ESG 5.2.2(9); and

   2. (b)

      ESG 4.3.5R(3)(a) to (c).

For the purposes of ESG 5.2.1R, a manager must include the following information in the consumer facing disclosure which relates to a sustainability product:

1. (1)

   the manager’s name;

2. (2)

   the name of the sustainability product to which the consumer-facing disclosure relates;

3. (3)

   the date of the disclosure;

4. (4)

   the International Securities Identification Number (ISIN) or other unique identifier (if any) for that sustainability product;

5. (5)

   the sustainability product’s sustainability objective, clearly signposted as the ‘sustainability goal’ for that product, including a summary of:

   1. (a)

      any material effect (including expected effect) on the financial risk and return of the product as a result of the investment strategy the manager has adopted to pursue the product’s sustainability objective;

   2. (b)

      the product’s progress towards achieving its sustainability objective; and

   3. (c)

      any material negative environmental and/or social outcomes that may arise when pursuing the product’s sustainability objective, as identified under ESG 4.2.9R(1);

6. (6)

   the sustainability label which the manager is using in relation to that sustainability product, together with the relevant descriptor for that label, as follows:

   1. (a)

      for the sustainability label ‘sustainability focus’, the relevant descriptor is: ‘invests mainly in assets that focus on sustainability for people or the planet’;

   2. (b)

      for the sustainability label ‘sustainability improvers’, the relevant descriptor is: ‘invests mainly in assets that may not be sustainable now, with an aim to improve their sustainability for people or the planet over time’;

   3. (c)

      for the sustainability label ‘sustainability impact’, the relevant descriptor is: ‘invests mainly in solutions to sustainability problems, with an aim to achieve a positive impact for people or the planet’; and

   4. (d)

      for the sustainability label ‘sustainability mixed goals’, the relevant descriptor is: ‘invests mainly in a mix of assets that either focus on sustainability, aim to improve their sustainability over time, or aim to achieve a positive impact for people or the planet’ as appropriate;

7. (7)

   a summary of the manager’s investment policy and strategy in relation to the sustainability product’s sustainability characteristics (including, where relevant, the sustainability product’s sustainability objective) which uses plain English language to describe the policy and strategy effectively and accurately to retail clients and which:

   1. (a)

      is clearly signposted as the manager’s ‘sustainability approach’;

   2. (b)

      sets out the key sustainability characteristics of assets in which that sustainability product will and will not invest;

   3. (c)

      details any types of asset that the product invests in for reasons other than to pursue its sustainability objective and why the product invests in those assets; and

   4. (d)

      summarises the manager’s approach to investor stewardship in supporting the achievement of the sustainability product’s sustainability objective;

8. (8)

   a summary of the relevant metrics in relation to that sustainability product, calculated using the most up-to-date data available as at the time of preparing the consumer-facing disclosure, which is clearly signposted as the manager’s ‘sustainability metrics’ and sets out:

   1. (a)

      the product’s progress towards achieving the product’s sustainability objective, measured against the KPIs that the manager uses under ESG 4.2.4R(3);

   2. (b)

      any other metrics that a retail client might reasonably find useful in understanding the sustainability characteristics of the product; and

   3. (c)

      any relevant contextual information, such as an explanation of how the metrics in ESG 5.2.2R(8)(a) and (b) should be interpreted;

9. (9)

   details (including, as appropriate, hyperlinks) as to where a retail client can easily access the following information:

   1. (a)

      the relevant pre-contractual disclosure in relation to the sustainability product, including, where applicable, Part A of the public product-level sustainability report in relation to that product;

   2. (b)

      Part B of the public product-level sustainability report in relation to the product;

   3. (c)

      the manager’s sustainability entity report; and

   4. (d)

      other non-sustainability related information in relation to a sustainability product – for example, costs and charges that are associated with that product; and

10. (10)

    for a manager that uses the ‘sustainability mixed goals’ sustainability label, details as to the proportion of the sustainability product’s assets which are invested in accordance with each of the 2 or more sustainability objectives referred to in ESG 4.2.18R.

A manager must ensure that the information at either ESG 5.2.1R(2)(b) or ESG 5.2.2R(5) (as applicable), together with the information at ESG 5.2.2R(6), is located in a prominent place at the front of the consumer-facing disclosure.

A manager must ensure that a consumer-facing disclosure is clear, concise and can be easily read and understood by retail clients and that it does not exceed 2 pages of printed A4 paper in length.

A manager must ensure it keeps a copy of each version of its published consumer-facing disclosure for a minimum of 5 years and provides a copy to a retail client or the FCA on request.

1. (1)

   A manager must publish a consumer-facing disclosure on the relevant digital medium for the business of the manager in a prominent place on the specific webpage or page on a mobile application or other digital medium at which the sustainability product is offered.

2. (2)

   A manager must ensure that, in publishing a consumer-facing disclosure, it is easy for retail clients (including prospective retail clients) and distributors to:

   1. (a)

      identify the particular sustainability product to which the consumer-facing disclosure relates;

   2. (b)

      identify the relevant sustainability label (if any); and

   3. (c)

      access the information set out at ESG 5.2.2R(9).