Pensions, the ESG criteria to be met and communicated

The Sustainability Observatory analyses the choices of pension funds (Fp) on transparency of Esg investments (Sfdr) and stewardship (Srd). Since pension funds are not subject to these provisions, attention was paid to how they communicate sustainable investments.

Data from the closed funds (33) and the top 20 open-ended and pre-existing funds by assets as of December 2023 (73 Fp) were taken into account; the funds considered represent 91% of the total assets managed by the three pension forms.

Entities integrate sustainability risks in heterogeneous ways that reflect the sustainability profile pursued. The sub-funds for which there is integration of sustainability risks are numerous (76% for negotiated LPFs, 94% for open-ended LPFs), so this choice is widespread among Article 6 sub-funds. Covip has pointed out that in some cases sustainability profiles have been found that the regulations do not require to be provided for this type of sub-fund. There is a possibility that the Fp may represent a different sustainability profile than the one actually pursued, with a potential risk of greenwashing.

On the Pai (the Principal Adverse Impacts) the employment and market Fp have opposite approaches, also due to an uneven regulatory environment. Among the former, only 3 entities have prepared a statement of consideration of Pai for 2023, in addition to 5 others that only consider Pai for certain sectors. A large part of the companies setting up open-ended GPFs (15) declared that they integrate Pai in their investment policy, however this choice is not always relevant for the GPF.

As of September 2024, entities offering Article 8 sub-funds grew by 3 to 28. Overall, there are 78 light green investment lines, representing 28% of the sub-funds open for subscriptions and 39% of assets. No Art. 9 sub-funds are offered.