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UCITS & AIFMD

Amendment AIFMD and UCITS

Practical implications- application from around October 2022

Operating Conditions

  • Consideration of sustainability risks in due diligence requirement (qualitative and quantitative terms)

  • If principal adverse impacts are considered, should be included in due diligence

  • Principle of proportionality

  • Necessary resources and expertise for the effective integration of sustainability risks

Conflict of Interest

  • 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 

  • Risk management policy must also consider exposures of funds to sustainability risks

General Organizational Requirements

  • Consider sustainability risks in decision-making procedures and organizational structures, establish adequate internal controls, maintain adequate and orderly records

  • Responsibility of Senior Management for the integration of sustainability risks