Integration of Sustainability risks in investment decision-making process (Article 3 SFDR)

WEALINS S.A. acts as a distributor of unit-linked life insurance or capitalisation contracts and advisor. We offer the following products: external (UCITS, etc.) and or internal collective funds, dedicated and/or specialised insurance funds set up and managed in accordance with Luxembourg regulatory provisions, and in particular the provisions of circular letter LC 15/3 of the Commissariat aux Assurances (the Insurance Supervisory Authority in Luxembourg). We facilitate, promote, and support the development of ESG investment strategies through our life insurance or capitalisation contracts. In such role, we do not manage the underlying assets of the contracts, and therefore we refer to each respective partner (asset manager, or other) requirements in accordance with SFDR categorization.

Investment approach of WEALINS S.A. own funds

In line with our mother company, the Foyer Group, our approach to sustainability and investments is characterised by embedding sustainability risks considerations.

Foyer Group applies an UN Global Compact inspired screening, involving checks related to breaches of the following principles: Human rights, Labour, Environment and Anti-Corruption. Information regarding controversies of investee companies based on their level of intensity is also collected and the controversy intensity level is ranked from 1 (lowest intensity) to 5 (highest intensity). The controversy level specifies the negative intensity of company-related events on the environment or society, and risks to the company itself.

In 2024, while tracking the PAI for our internal portfolio (see below section) we have also started to use this work as an opportunity to set sustainability targets at group level that will ensure we can continue tracking while moving forward on our ambition in line with the Sustainable Development Goals.

Integration of Sustainability risks in Insurance Advice (Article 3 SFDR)

In our role as insurance advisor, we have devised an entirely digital approach, through which we capture the sustainability preferences of our clients. This approach is done through our e-Wealins platform and the methodology we have created internally to map out the sustainability profile of our clients with the investment products that we source through third parties.

Excerpt on our approach

In line with our responsibilities as a financial adviser, in accordance with the Insurance Distribution Directive (IDD) regulation 2021/1257 of 21 April 2021, WEALINS S.A. needs to take into consideration the sustainability preferences of our clients.
In order to take good note of these preferences and determine their impacts on investments, we devise a system that would allow us to seemingly define our clients’ preferences according to their risk appetite and match those with predefined sustainability ‘profiles’.

To this end we have drafted sustainability questions that enable an open exchange between clients and WEALINS SA in order to ensure our clients can make an informed choice on sustainability and help them establishing sustainability preferences (take into account principal adverse impacts on environmental and social matters, investment promotes environmental or social characteristics (article 8 SFDR), sustainable investment (article 9 SFDR), investment in line with Taxonomy Regulation (EU) 2020/852).

Each preference carries a particular weight which determines a match to meet a sustainability profile(s) (from 2 to 6) established by WEALINS SA.

Once those preferences have been established, the clients will be offered a set of specific products (external funds (UCITS, etc,) and or internal collective, dedicated and/or specialised insurance funds), that perfectly match the combination of their sustainability profile. We make our selection sourcing the information from the EET (European ESG Template) made available by our partners (asset managers, or other).

Statement on due diligence policies with respect to Principal Adverse Impacts of investment decisions on sustainability factors (Article 4 SFDR)

WEALINS S.A. offers a range of unit-linked life insurance and capitalisation products whose financial risks are fully borne by the policyholders.

The investments underlying WEALINS S.A. products provide access to up to four different types of funds, depending on the product and the target market. These may be external (UCITS, etc.) and/or internal collective funds, dedicated and/or specialised insurance funds set up and managed in accordance with Luxembourg regulatory provisions, and in particular with the provisions of circular letter LC 15/3 of the Commissariat aux Assurances (Luxembourg insurance supervisory authority). Through these external and/or internal funds, policyholders of WEALINS S.A. products can invest in a large number of strategies and investment profiles, most often managed by external and independent financial managers and sometimes, when the regulatory provisions of the policyholders’ countries of residence allow it, directly by the policyholders.

Investment decisions are thus taken by these external financial managers mandated by WEALINS S.A. in the case of internal collective or dedicated funds, or by the policyholders themselves, or at least with the confirmation of the policyholders, who may, if they so wish, seek investment advice. In all these cases, it is the responsibility of the independent investment managers appointed by WEALINS S.A., the investment advisors appointed by the policyholders or, if applicable, the policyholders themselves to integrate sustainability risks into their investment decisions and to assess the principal adverse impacts of their investment decisions on sustainability factors and investment returns.

WEALINS S.A., as a life insurance company mainly marketing unit-linked products¹ is not directly involved in the choice of underlying(s) for internal funds. In particular, this responsibility ‘is transferred to the financial manager, in accordance with the investment policy defined in consultation with the policyholder’. In accordance with our supervisors classification our role is therefore ‘limited’ in terms of being able to influence investment decisions for our clients investment choices, we can only limit ourselves to tracking them and assess how to be able to exert influence across the value chain.
We also provide access to the external fund list with the SFDR classification is available here.

Principle Adverse Impacts Statement

In 2022 we had already started tracking PAIs (Principle Adverse Impacts) in order to facilitate our role and succeeded in developing an approach (in alignment with the group) that allows us to align and further advance in our mission to bring more transparency into the business.
In 2024 we have therefore published our (clients’ investments) product related PAI available here and on Foyer Group website.

We have also chosen to publish our internal portfolio PAIs demonstrating our commitment to act sustainably creating alignment with our sustainability strategy and the composition of our internal investments portfolio which is managed by our Group. We take this opportunity to foster constructive exchange with our internal stakeholders while driving change from within.

Information on how the remuneration policy of WEALINS S.A. is consistent with the integration of sustainability risks (Article 5 SFDR )

The remuneration policy of WEALINS S.A. is part of the overall remuneration policy of Foyer Group, to which WEALINS S.A. belongs, which is summarised in the document Sustainability Statement published on the Group’s website.

Find the Sustainability statement of WEALINS in PDF here 20230711_Sustainability statement_WEALINS

Published on 26 July 2024.

---

1. According to NCA – CAA belonging to group 2 based on ‘Note d’information 24/9’ ↩︎