
The FCA’s Sustainability Disclosure Requirements (SDR)
The FCA’s Sustainability Disclosure Requirements (SDR) apply to our UK domiciled investment funds within the RBS Investment Funds ICVC. The FCA are currently consulting on the Rules under SDR.
The information below details how, as investment manager, we support the fund’s compliance with these regulations, and we also apply these principles across our wider funds and portfolios.
ESG Considerations
Coutts believes that strong corporate governance practices and management of environmental and social risks contribute to the creation of long-term investment value. Accordingly, Coutts considers sustainability risks when making investment decisions. When investing in other funds or investing directly Coutts will have a bias for investments with stronger ESG characteristics and an approach to ESG investment which is consistent with that of Coutts when other factors such as expected performance and other risks are similar.
The following describes how Coutts integrates sustainability risks and other ESG factors into its investment decision making and on-going ownership processes:
Investment decision making
The Investment Manager integrates externally and internally produced ESG data into decision making and risk monitoring processes to consider sustainability risks throughout the investment process.
Ownership and stewardship
The Investment Manager uses proactive and reactive engagement with management and boards of issuers of bonds and equities to monitor their ESG practices and encourage best practice.
This approach is relevant to investments made both directly into bonds or equities and indirectly through collective investment schemes or ETPs.
Further detail on the Investment Manager’s approach to integrating Sustainability Risks and other ESG factors in its investment process is available here.
On this website you can also find the Investment Manager's engagement objectives and plan along with the Responsible Ownership Principles reports on its voting records and engagement activities.
Principle adverse impacts
This section summarises the current investment due diligence policies of Coutts, in respect of the principal adverse impacts of our investment decisions on sustainability factors.
It is divided into four key areas:
- Information about our due diligence policy on the identification and prioritisation of principal adverse sustainability impacts and indicators
- A description of the principal adverse sustainability impacts and of any actions taken or planned
- A brief summary of our shareholder engagement policy
- A reference to our adherence to responsible business conduct codes and internationally recognised standards for due diligence and reporting and the degree of our alignment with the objectives of the Paris Agreement.
Remuneration policy
The remuneration policy for NatWest Group Executive Directors includes environmental, social and good governance goals within the framework of a balanced scorecard of measures. These are detailed in the NatWest Group’s annual report and accounts. A balanced scorecard approach also applies to colleagues across the organisation and is used when setting the specific performance goals of individuals, including those involved in our investment management processes.
To encourage long-term thinking, the performance assessment takes into account our colleagues’ display of our values and core behaviours, ensuring that the assessment considers both what has been delivered and how it has been delivered.
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