Invest Europe-PAE

Response to ESMA Consultation on Sustainability in AIFMD/UCITS

Positions & consultation responses

19 Feb 2019

In this response, we stress the need for ESMA to stick to a high-level principles-based approach, recognising the diversity among market practitioners and allowing a certain level of flexibility in implementation (according to the proportionality principle). In addition, it is important to avoid treating ESG as a standalone or overriding risk category in the deal process, but rather to consider it as a category of direct business risks, which should be incorporated in existing functions and processes.