The Sustainable Finance Disclosure Regulation (”SFDR” or “the Regulation”) applied from 10 March 2021. The Regulation requires financial market participants and/or financial advisers such as Wilshire (the “firm”) to provide information to investors with regards to the integration of sustainability risks, the consideration of adverse sustainability impacts, the promotion of environmental or social characteristics, and sustainable investment. Set out below are the following website disclosure requirements contained in the Regulation:
The Sustainable Finance Disclosure Regulation (”SFDR” or “the Regulation”) applies from 10 March 2021. This Sustainability Risk Policy specifically addresses the obligation in Article 3 of the Regulation which requires either financial market participants and/or financial advisers (as applicable) to:
“…publish on their websites information about their policies on the integration of sustainability risks in their [in the case of financial market participants] investment decision‐making process or [in the case of financial advisers] investment advice or insurance advice [(as applicable)].”
“Sustainability Risks” as defined in Article 2(22) of the Regulation: “an environmental, social or governance event or condition that, if it occurs, could cause an actual or a potential material negative impact on the value of an investment”.
Sustainability Risks include (but are not limited to) the following:
Wilshire is a signatory to the Principles for Responsible Investing (PRI) and includes environmental, social and governance issues (ESG) in decision-making, investing, and monitoring processes where appropriate. ESG related factors are one of many factors that Wilshire may consider when evaluating an investment decision. In addition, Wilshire incorporates ESG-related questions in its due diligence on managers. Specifically, Wilshire includes in its private markets funds operational due diligence questionnaire inquiries regarding: (i) the manager’s ESG-related policies and investment beliefs; (ii) how the manager identifies and manages material ESG-related risks and opportunities; and (iii) how the manager contributes to the portfolio companies’ ESG-related risks and opportunities.
Wilshire continues to invest in its ESG resources and capabilities. Led by our Senior Vice President for Responsible Investment, a firm-wide ESG and Diversity Committee, designed to provide coordination of ESG initiatives, monitor emerging trends and share best practices across the firm, meets regularly.
This Sustainability Risk Policy will be reviewed regularly and amended as appropriate by the ESG and Diversity Committee.
The Sustainable Finance Disclosure Regulation (”SFDR” or “the Regulation”) applies from 10 March 2021. This Principal Adverse Sustainability Impacts Statement specifically addresses the obligation in Articles 4(1)(b) and 4(5)(b) of the Regulation which requires financial market participants and financial advisers respectively to publish and maintain on their websites:
“[in the case of financial market participants] where they do not consider adverse impacts of investment decisions on sustainability factors, clear reasons for why they do not, including, where relevant, information as to whether and when they intend to consider such adverse impacts…[and, in the case of financial advisers]…information as to why they do not to consider adverse impacts of investment decisions on sustainability factors in their investment advice or insurance advice, and, where relevant, including information as to whether and when they intend to consider such adverse impacts”.
“Sustainability Factors” are defined in Article 2(24) of the Regulation as: “environmental, social and employee matters, respect for human rights, anti‐corruption and anti‐bribery matters”.
Wilshire does not currently consider the adverse impacts of its investment decisions on sustainability factors.
Given the nature of Wilshire’s business generally, Wilshire does not currently consider adverse impacts on Sustainability Factors with respect to any of its products that fall within the Regulation. Given the obligations contained in the Regulations (including the technical methodologies and data capture requirements this would reasonably entail) compliance with the Regulations is not assured among the different portfolio managers that many of the Wilshire products will invest with. As such, there is no assurance that Wilshire will have access to clear, comparable and consistent data with which to report on principal adverse impacts of investment decisions on Sustainability Factors. This decision will, however, be kept under regular review.
as of December 12, 2022
The Sustainable Finance Disclosure Regulation (”SFDR” or “the Regulation”) applied from 10 March 2021. This Remuneration Policy (Sustainability Risks) specifically addresses the obligation in Article 5 of the Regulation:
“Financial market participants and financial advisers shall include in their remuneration policies information on how those policies are consistent with the integration of sustainability risks, and shall publish that information on their websites.”
“Sustainability Risks” as defined in Article 2(22) of the Regulation: “an environmental, social or governance event or condition that, if it occurs, could cause an actual or a potential material negative impact on the value of an investment”.
Sustainability Risks include (but are not limited to) the following:
Among other forms of remuneration that are provided on a fixed basis, the firm may award employees variable discretionary bonuses on an annual basis. Remuneration levels are attributable to, among other factors, performance of the relevant individual and of Wilshire and the total amount of variable remuneration may reflect a combination of the assessment of the performance of the employee and the overall results of Wilshire, as well as the conduct of the employee under any relevant internal procedures, policies and compliance requirements. The remuneration policy does not consider sustainability risks with respect to the determination of the remuneration.
Wilshire has been applying highly tested theories and approaches to our client solutions since 1981.
Our clients rely on us to improve investment outcomes for a better future.