Example description of net impact metrics based indicators in pre-contractual disclosures

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Upright is an impact data provider. The contents of this document do not constitute legal advice, are not intended to be a substitute for legal advice, and should not be relied upon as such. You should seek legal advice or other professional advice in relation to any particular matters you or your organisation may have.

The EU Sustainable Finance Disclosure Regulation (SFDR) requires financial undertakings (e.g. asset managers) to explain what indicators they use to measure the attainment of the sustainable investment objective (for Article 9 funds) or E/S characteristics (for Article 8 funds). The explanation ought to be included e.g. in pre-contractual disclosures for Article 9 funds.

Upright has created a template answer for providing this explanation as part of SFDR pre-contractual disclosures when using Upright data. The explanation, provided below, assumes that net impact is used as part of the binding elements of the investment strategy, but the answer could be easily worded differently to also support other binding elements.

Example text for pre-contractual disclosures section What sustainability indicators are used to measure the attainment of the sustainable investment objective of this financial product?

Attainment of the sustainable investment objective is measured by a combination of impact metrics that comprehensively capture investment's impacts on society, knowledge, health, and the environment, considering both positive and adverse impacts.

The metrics are based on the Upright Net Impact Framework. The table below provides an overview of the top-level impact categories included in the framework.

Dimension	Impact category
Society	Taxes
Society	Jobs
Society	Societal infrastructure
Society	Equality
Society	Societal stability
Knowledge	Scarce human capital
Knowledge	Knowledge infrastructure
Knowledge	Creating knowledge
Knowledge	Distributing knowledge
Health	Physical diseases
Health	Mental diseases
Health	Nutrition
Health	Relationships
Health	Meaning & Joy
Environment	GHG emissions
Environment	Non-GHG emissions
Environment	Biodiversity
Environment	Scarce natural resources
Environment	Waste