Aviva Portfolio, Madelin Multi Portfolio and Nortia Alternatives Multi Portfolio

Sustainable Finance Disclosure Regulation

The EU SFDR (Sustainable Finance Disclosure Regulation) is designed to improve the standard and transparency of sustainability related disclosures made in relation to financial products.  This is to help investors understand the sustainability risks and impacts of those financial product

You will recall that on 29 March 2019 Aviva Life and Pensions UK Limited, (‘UKLAP’) the original provider of your policy transferred some of its insurance business to Aviva Life and Pensions Ireland Designated Activity Company (ALPIDAC), by way of a Court sanctioned insurance business transfer scheme under Part VII of the Financial Services and Markets Act 2000.  This transfer included your policy.

From the 29 March 2019 the provider of your policy is ALPIDAC.

ALPIDAC and UKLAP entered into a reinsurance treaty whereby UKLAP reinsured the transferred life assurance business on behalf of ALPIDAC.  This means the day-to-day administration of your policy is undertaken by UKLAP or one or more of its outsourced companies.

While your product(s) are not open to new business, Our Sustainability Policy and Statement on Due Diligence Policies explain ALPIDAC’s approach to the integration of sustainability risks into our investment process as well as also providing information on how the adverse impacts of investment decisions on sustainability factors are considered.  

Funds and their Sustainability Factors

Unit linked funds available to the transferred policies are offered, but many of our funds have underlying holdings in other funds which are managed by a different company. We also offer some products which invest directly into the funds of other fund managers.  We refer to both of these types of holdings as “External fund holdings”.  These holdings may be managed by a different company in the Aviva Group (for example Aviva Investors UK Fund Services Limited) or by another fund management company.

In the table of funds below, we have provided the name of the Aviva unit linked fund, plus the details of the underlying external fund holdings (where appropriate).  This is to enable you to view the periodic disclosure provided by those external fund managers.

The due diligence that we undertake is explained in Our Sustainability Policy and Statement on Due Diligence Policies.  Where you invest directly in an external fund offered by a third-party investment manager you should refer to that fund managers website for information relating to their approach to sustainability information in relation to those funds. 

Under SFDR, funds are categorised into specific types for assessing the environmental, social and governance (ESG) impacts of the investment process for each of them.

Funds and their SFDR criteria

The funds you’re able to invest in depend on the type of product you hold with Aviva and the country where it was originally sold in.  Not all the funds available to you have sustainable characteristics. We’ve listed the funds available according to product type in the tables.

We have included the relevant ISIN number (where appropriate) in the table together with the current web address of where you can find information relating to the funds available including information relating to sustainability (where appropriate).  ISIN (International Stock Identification Number) is a unique reference used to identify funds and other assets. 

Where a fund has underlying holdings in other funds which are managed by a different company, we have also provided the ISIN and fund name for each of the underlying fund(s) into which it invests.  The website links provided are for the place where the Fund Managers host their Periodic Disclosures.

Please note we are not responsible for the information provided by the fund manager nor for the web address where it is located, which could be changed at any time.  However, we will try to ensure the correct web address is listed here, though there may be a delay between when a fund manager changes it and us making changes to this webpage. 

Article 6

Funds that don’t integrate any binding sustainability characteristics into the investment process and so can include stocks that might be currently excluded by ESG focused funds such as tobacco companies. These are often referred to as SFDR neutral funds. 

We have also categorised some funds as article 6 where those funds are not subject to SFDR regulation even though they may have sustainable characteristics, for example, where the fund is UK based.  For information on whether a fund has any sustainable characteristics, please refer to the fund factsheets (where available) or contact customer services for more information.

Article 8

Funds that promote environmental or social characteristics and can integrate sustainability into the investment process in a binding manner.

Article 9

Funds that specifically have sustainable investments as their objective (for example investing in companies that aim to reduce carbon emissions)

Funds Table

*This  fund is a UK domiciled fund that does not have any Sustainable Environmental, Social and Governance Characteristics, and is not covered by the SFDR regulation.  It has only been classified as Article 6,  as this is the most appropriate EU SFDR classification, for a UK fund with no sustainability objectives

**This fund is a UK domiciled fund and has Sustainable Environmental, Social and Governance Characteristics, however, it is not covered by the SFDR regulation.  It has only been classified as Article 6, as Aviva are unable to provide the relevant disclosures to support its sustainability objectives.

The website links below, for the funds, may take you to an external site. 

Product Name Fund Name ISIN SFDR Category Article Website link
Aviva Portfolio Madelin
Multi Portfolio
Nortia Alternatives Multi Portfolio (France)
DNCA EVOLUTIF C FR0007050190 Art 8 Fund Link
  MONETA MULTI CAPS C FR0010298596 Art 8 Fund Link
  INDOSUEZ ALLOCATION 30 FR0010156539 Article 6 SFDR Periodic Disclosure not required for Article 6
  OFI INVEST ISR ACTIONS EURO A FR0007022108 Article 8 Fund Link
  CPR CROISSANCE REACTIVE P FR0010097683 Article 8 Fund Link
  EUROSE C FR0007051040 Article 8 Fund Link
  OFI INVEST ACTIONS AMERIQUE I FR0007017488 Article 6 SFDR Periodic Disclosure not required for Article 6
  CPR SILVER AGE E FR0010917658 Article 8 Fund Link
  R CO VALOR F EUR FR0011261197 Article 8 Fund Link
  CARMIGNAC PATRIMOINE A FR0010135103 Article 8 Fund Link
  MANDARIN.UNIQ.SMAL.MID CAPS EUROP.R LU0489687243 Article 8 Fund Link
  VEGA MONDE RENDEMENT FR0010458216 Article 6 SFDR Periodic Disclosure not required for Article 6
  INDOSUEZ ALLOCATION 60 FR0010232074 Article 6 SFDR Periodic Disclosure not required for Article 6
  SEXTANT GRAND LARGE A FR0010286013 Article 8 Fund Link
  EDR FD EQUITY EURO CORE A EUR LU1730854608 Article 8 Fund Link
  OSTRUM SRI CASH PLUS TC FR0013311487 Article 8 Fund Link
  M&G (LUX) GBL DIVIDEND FD EUR A ACC LU1670710075 Article 8 Fund Link
  BNPP FDS SUST US MULTI FACTOR EQ N LU1956163619 Article 8 Fund Link
  OFI INVEST ISR MONETAIRE A FR0007437546 Article 8 Fund Link
  CPR FOCUS INFLATION P FR0010832469 Article 6 SFDR Periodic Disclosure not required for Article 6
  OFI INVEST EQUILIBRE MONDE FR0007032719 Article 6 SFDR Periodic Disclosure not required for Article 6
  OFI INVEST VALEURS FRANCAISES FR0000014268 Article 6 SFDR Periodic Disclosure not required for Article 6
  EDR SICAV TRICOLORE RENDEMENT A EUR FR0010588343 Article 8 Fund Link
  OFI INVEST ISR PATRIMOINE MONDE FR0007032743 Article 8 Fund Link
  OFI INVEST DYNAMIQUE MO FR0007032735 Article 6 SFDR Periodic Disclosure not required for Article 6
  ECHIQUIER AGRESSOR A FR0010321802 Article 8 Fund Link
  CGU VALEUR PLUS   Article 6 SFDR Periodic Disclosure not required for Article 6
  CGU EQUILIBRE FR0007004189 Article 6 SFDR Periodic Disclosure not required for Article 6
  INDOSUEZ EURO RENDEMENT P C FR0010232108 Article 8 Fund Link
  OFI INVEST OBLIG INTERNATIONAL FR0000097495 Article 6 SFDR Periodic Disclosure not required for Article 6
  TOCQUEVILLE VALUE EUROPE ISR P FR0010547067 Article 8 Fund Link
  TOCQUEVILLE SMALL CAP EURO ISR C FR0010546903 Article 8 Fund Link
  OPALE PATRIMOINE P FR0010013805 Article 8 Fund Link
  AI GBL EMG MKTS CORE FD B EUR CAP LU0280564351 Article 8 Fund Link
  CPR ACTIONS EURO RESTRUCTURATIONS P FR0010330258 Article 8 Fund Link
  SISF INFLATION PLUS B CAP LU0107768136 Article 6 SFDR Periodic Disclosure not required for Article 6
  SISF EURO SHORT TERM BOND B LU0106234726 Article 8 Fund Link
  OFI INVEST ESG SIGNATURES EUROPE FR0007066840 Article 8 Fund Link
  OFI INVEST CONVERTIBLES MONDE FR0000014292 Article 8 Fund Link
  OFI INVEST PATRIMOINE FR0000291536 Article 6 SFDR Periodic Disclosure not required for Article 6
  NORDEN SRI FR0000299356 Article 8 Fund Link
  OFI INVEST MULTIGESTION FR0007014444 Article 6 SFDR Periodic Disclosure not required for Article 6