No consideration of adverse impacts of investment decisions on sustainability factors

UBS Asset Management (Europe) S.A. (“UBS-AME”) does not consider adverse impacts of investment decisions on sustainability factors (“PAI”) at the legal entity level within the meaning of Article 4 of the Sustainable Finance Disclosure Regulation of the European Union (EU) 2019/2088 (“SFDR”). UBS-AME continues to manage products where PAIs are considered. 

  • In 2023 and 2024, UBS-AME voluntarily produced PAI reports on a consolidated basis across all products under its governance, based on the sustainability framework of UBS Group and UBS Asset Management. 
  • Effective 13 March 2025, UBS-AME decided it will no longer do so at the legal entity level, after careful consideration of several key factors including:
    • UBS-AME delegates the portfolio management function to portfolio managers outside of UBS-AME, who implement their own sustainability frameworks, which may take into account PAIs where appropriate, at the product level;
    • As PAI indicators and related planned actions are aggregated across all products under UBS-AME’s governance, UBS-AME believes that this information is not useful to investors; and
    • UBS-AME has seen a low level of interest in PAI statements at the legal entity level.

UBS-AME will continue to monitor relevant market developments and may adapt its stance in the future.

Since UBS-AME still had the disclosure on its web site about positive PAI consideration at legal entity level in the calendar year 2023, please find hereafter the related PAI statement as required under SFDR:

Summary document

No consideration of adverse impacts of investment advice on sustainability factors

Principal adverse impacts (“PAIs”) are the most significant negative impacts of investment decisions on sustainability factors relating to environmental, social and employee matters, respect for human rights, anti‐corruption, and anti‐bribery matters. UBS Asset Management (Europe) S.A. (hereinafter also known as “UBS-AME” or “the management company”) acknowledges the need for transparency of principal adverse impacts of investment decisions on sustainability factors. The management company may carry out investment advisory services exclusively in the meaning of marketing / distribution of funds. UBS-AME does not consider any adverse impacts of investment decisions on sustainability factors in its investment advice services, because UBS-AME considers PAIs already during the fund design and at the investment strategy level as outlined in the funds’ pre-contractual disclosures (funds which promote environmental and /or social characteristics (Article 8 SFDR) or which have sustainable investments as their objective (Article 9 SFDR)). The extent to which adverse impacts are considered depends on the individual product features and the client preferences obtained through the investment advisory assessment process.

UBS-AME is going to regularly review the above approach and may reassess its position in the future.