Introduction

    European Regulation (EU) 2019/2088, known to industry professionals as SFDR – “Sustainable Finance Disclosure Regulation,” in force since 2021, requires various categories of financial market participants, including pension funds such as Previndai, to disclose information on how they integrate sustainability factors (ESG: Environmental, Social, and Governance) and related risks into their investment processes.

    Furthermore, a classification of financial products based on their ESG characteristics can be derived from this Regulation:

    • Article 6 products: In practice, these are products that do not promote ESG characteristics nor have sustainable investment as an “objective,” but for which sustainability risks are monitored.

    • Article 8 products: These are products that promote environmental or social characteristics, provided that the companies in which the investments are made follow good governance practices.

    • Article 9 products: These include products that have sustainable investment as their declared objective.

    Previndai takes ESG factors into account within its investment policies and risk management, but does not make them a subject of promotion nor an investment objective. The Fund’s primary objective remains the management of the resources contributed by members according to the most efficient risk-return combinations and within a time horizon consistent with the nature of pension benefits. Therefore, its sub-funds fall under Article 6 of the European regulation.

    More information on this approach is available in our Sustainability and Engagement Policy (adopted in 2021).

    (Updated as of June 17, 2025)

    Policies on the integration of sustainability risks in investment decision-making processes

    No consideration of adverse impacts of investment decisions on sustainability factors