UCITS & AIFMD
Amendment AIFMD and UCITS
Practical implications- application from around October 2022
Operating Conditions
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​Consideration of sustainability risks in due diligence requirement (qualitative and quantitative terms)
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If principal adverse impacts are considered, should be included in due diligence
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Principle of proportionality
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Necessary resources and expertise for the effective integration of sustainability risks
Conflict of Interest
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The identification of conflicts of interest must also include those conflicts of interest that may arise as a result of the integration of sustainability risks
Risk Management
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Risk management policy must also consider exposures of funds to sustainability risks
General Organizational Requirements
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Consider sustainability risks in decision-making procedures and organizational structures, establish adequate internal controls, maintain adequate and orderly records
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​Responsibility of Senior Management for the integration of sustainability risks