This policy applies to all Crystal Group subsidiaries

Sustainable investment is a major objective for French and European legislation, which seeks to include the awareness of environmental, social and governance (ESG) criteria along with the respect of Human rights and commitment to the fight against corruption alongside the accepted purely financial criteria. These indicators will become a genuine benchmark for investors and their intermediaries as regards the responsible approach presented by a given financial or insurance product.

This is why, compliant to the modified (EU) 2019/2088 regulation on the publication of information regarding sustainability in the financial services sector (the “Sustainable Finance Disclosure Regulation” or “SFDR”), Expert & Finance will make every effort to consider the principle sustainability risks when providing consulting for investment products.

According to the SFDR, a sustainability risk is an event or situation associated with the environmental, social or governance domains whose occurrence may have a real or potential serious negative impact on the value of an investment. These risks are evaluated individually for each product and integrated by the Crystal group in its evaluation processes which it applies before each consultancy operation and is always based on the available information and supported by the product designers.

Failing to consider the negative impact on sustainability factors: 

The Crystal group is evidently committed to this responsible approach and, where possible, integrates a sustainable development logic into its global operation.However, considering that the legal framework for sustainable finance is currently incomplete and constantly developing, the Crystal group is in some way subject to the behaviour of its partner product producers and is not currently in a position to allow for the principle negative impacts regarding the sustainability factors in question raised by investment decisions.

For the moment, this simply takes the form of a lexicon covering financial products related to SFDR: 

• “Article 8” products:  promoting sustainable characteristics. These integrate environmental and/or social characteristics without necessarily committing to a sustainable investment objective;
• “Article 9” products:  with a sustainable investment objective or, in other words, that invest in an economic activity that contributes to an environmental or social objective;
• “Article 6” products:  which do not qualify for the above two categories and which cannot be presented as sustainable.

However, until such time as the sustainable finance industry can agree on a common evaluative and analytical methodology for these negative impacts, the Crystal group commits to maintain its sustainability efforts and to adapt its policies in keeping with developments to the legal framework. Any major changes to our approach will be communicated on the websites of the various Crystal Group companies, compliant to the SFDR.

Concerning integration into payroll policy: 

The payroll policy applied by the Crystal Group does not encourage sustainability risks.