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) who works with us and has been pre-screened as per our Due Diligence process, ensuring that each investment and every partner meets all regulatory requirements.

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.

Regarding the UN Global Compact, we perform checks related to breaches of the following principles: Human rights, Labour, Environment and Anti-Corruption. We collect information regarding controversies of investee companies based on their intensity. 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. For more information, we refer to the available documentation (english translation available soon).

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.

For the same reasons, neither WEALINS S.A. as an insurer nor its life insurance or capitalisation products take into account the adverse impacts of investment decisions on sustainability factors. When active acting as an insurance distributor (direct sales), WEALINS S.A., considers adverse impacts of investment decisions on sustainability factors in the insurance advice it provides by ensuring that the policies and strategies of its third party funds are in line with its own sustainability considerations and Foyer investment policy. The fund list with the SFDR classification is available here.

Principle Adverse Impacts Statement

WEALINS distributes unit-linked life insurance and capitalization contracts, mainly through a network of insurance intermediaries (brokers, banks, family offices). These intermediaries are responsible for engaging in a relation with policyholders. They define the investment strategy and investment support(s) most suitable for each policyholder, considering the risk appetite, investment expectations and sustainability preferences of every specific client.

It is in the phase of direct exchange and discussion with the client that the intermediary takes charge of considering sustainability risks and, what they represent for the clients’ projects, while taking into account the adverse impacts of investment decisions on sustainability factors as part of the insurance advice.

Wealins’ role in this value chain and where we can exert the maximum influence is in the selection of the right partners (Asset Managers, Intermediaries) through our Due Diligence process. In establishing the correct collaborative framework with partners that share our sustainable vision and mission, we play our part to contribute to the European sustainable finance plan.

As we articulate our responsible investment policy and define a strategy and key targets, we can define actions and ways in which we can establish minimum requirements around expectations on the way our partners engage with the companies they invest in. We have already started tracking PAIs (Principle Adverse Impacts) in order to facilitate our role going forward and hopefully will be able to successfully elaborate a more granular analysis soon. This will enable us to prepare a set of plans to offset potential negative impacts allowing us to consider and monitor potential adverse impacts in a more direct way in the foreseeable future.

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 11 July 2023.

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