GA Personal Investment Plan

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.

Statement on Due Diligence Policies Our Sustainability Policy

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

Article 9

Funds table

Funds Table

Fund Name	SFDR Category	Website Link
Aviva Pension US Equity	Article 6	SFDR Periodic Disclosure not required for Article 6
Aviva Pension Japan	Article 6	SFDR Periodic Disclosure not required for Article 6
Aviva Pension Pacific	Article 6	SFDR Periodic Disclosure not required for Article 6
Aviva Pension Mixed Investment (40-85% Shares)	Article 6	SFDR Periodic Disclosure not required for Article 6
Aviva Pension European Equity	Article 6	SFDR Periodic Disclosure not required for Article 6
Aviva OLAB With-Profits	Article 6	SFDR Periodic Disclosure not required for Article 6