Responsible & Sustainable Investment (RSI) Committee

Industry challenge

Firms need to understand what is required of them under RSI.  This is not just UK, but EU wide. Firms are looking at TISA to develop recommendations for compliance with MiFID II suitability rules, disclosures to customers and the data required to ensure customers can make investment choices based on objective, comparable data.

Group purpose

The Responsible & Sustainable Investment (RSI) Committee aims to help firms understand, implement and develop industry good practice guides for ESG. Please see here for the most recent.

Areas of focus

The requirements for Responsible & Sustainable Investment (RSI) are known at very high level, but details, implementation timescales and reporting are not clear. The industry is seeking guidance on Understanding, Implementation, Good practice and Reporting disclosures

• Our active participation in the FCA’s Disclosures and Labelling Advisory Group continues. This is restricted membership group, to enable open industry dialogue with FCA, including feedback on Sustainable Disclosure Regulation (“SDR”) covering the planned regime and its future development. The labelling regime covers 4 labels, initially restricted to funds, but we should like to expand it to include portfolios and take account of advisory businesses and overseas funds as well as wealth managers and funds. In November 2023, the FCA published its final rules and guidance on sustainability disclosure requirements (SDR) and investment labels. The FCA has opted for a staggered approach to implementing its new rules and these include the anti-greenwashing rule which applies to all FCA regulated firms from 31 May 2024. There are recognised challenges with these rules, including consumer understanding and TISA is looking to develop Best Practice Guides.
• TISA responded to the FCA’s consultation on supporting guidance for the anti-greenwashing rule in January 2024 and the FCA’s consultation on Extending SDR to Portfolio Management Services.
• In May 2024, HMT published Sustainability Disclosure Requirements (SDR): Implementation Update setting out the next steps with respect to the UK’s sustainability disclosure framework.
• The work on investment factsheet, covering key regulatory disclosures, especially ESG, to sit above/replace KIIDs and above prospectuses has been moved into the Inclusive Investing workstream to ensure the correct considerations.
• Two working groups have been established – i) Reporting (including net zero transition); and ii) Labelling and Suitability. The working groups are looking to develop reporting templates, which the TISA groups have agreed to deliver, agree on the content and format of data requirements to enable funds and portfolios to be labels to be appropriately labelled, as well as Best Practice Guides. We will be developing our proposal for an investment factsheet covering key regulatory disclosures, especially ESG, to sit above/replace KIIDs and above prospectuses. The first drafts have been published and we have shared with the FCA who are keen to engage in discussions on the December 2023 Policy Statement with the first meetings scheduled shortly.
• FCA Market Intelligence and Engagement team in ESG have approached TISA to look at the extent to which ESG is incorporated into the investment advice journey in the UK – key meeting to take place with the FCA team
• TISA responded to the HM Treasury Consultation on ESG Ratings Providers, DP23/1 on Sustainable Disclosure and Governance, DP23/2 on Asset Management and IRSG/ICMA draft code on ESG Ratings and Data providers
• Conference held September 2023

Aberdeen Group
Aegon UK PLC
Altus Consulting
Ashurst Risk Advisory LLP
Association of Investment Companies (AIC)
Baringa Partners LLP
Broadridge Financial Solutions, Inc
Brooks Macdonald Asset Management Ltd
Canada Life
Charles Stanley & Co Ltd
Deloitte
Digital Moneybox Ltd
Dynamic Planner
EQ Investors
Ernst & Young
Evelyn Partners
Eversheds Sutherland (International) LLP
FE Fundinfo
Financial Software
Forester Life
Hargreaves Lansdown
Impact Investing Institute
Interactive Brokers (U.K.) Limited
Invesco

James Sharp
Kroll
L & G
Link Group
Lloyds Banking Group
M&G Investments
Marlborough Group
Marlborough Group
MFS International (UK) Ltd
Model Office
Morningstar UK Ltd
Northern Trust
Pinsent Masons LLP
Quilter Cheviot Limited
Rathbone Bros Plc
RBC Brewin Dolphin
Simmons & Simmons
Square 4 Partners Ltd
SRI Services
St James’s Place Wealth Management
The Investment Association
Virgin Money PLC
Wellhouse Consulting

Renny Biggins,
Head of Policy: Products & Long-Term Savings leads on this work

Chair: Philip Spyropoulos, Eversheds Sutherland

Deputy Chair: Gemma Woodward, Quilter Cheviot