How Invesco Ltd trading as Acumen & Trust approach sustainability risks and adverse sustainability impacts in the advice we give you about savings, investment and pensions products

Regulation (EU) 2019/2088 on sustainability-related disclosures in the financial services sector (“SFDR”)


Invesco Ltd is authorised as an investment and insurance intermediary by the Central Bank of Ireland and provides advice to clients on a number of different types of insurance products, including insurance-based investment products. Certain disclosures are requested to be made under the SFDR in relation to sustainability related matters.

As part of the research and assessment of products, Acumen & Trust examines the Product Providers’ literature to compare financial products and to make informed decisions about these products. Acumen & Trust will at all times act in the client’s best interests and keep clients informed accordingly. The consideration of sustainability risks can impact on the returns of financial products.


How Acumen & Trust approaches the integration of sustainability risks when we give you advice about our products:


A ‘sustainability risk’ is defined as an environmental, social or governance event or condition that, if it occurs, could cause an actual or a potential material negative impact on the value of the investment. In other words, the risk of something taking place which causes a fall in the value of a product we recommend to you. When we give you advice, we use a range of information to help you make an informed decision; this includes:


  • How long you want to save or invest your money for
  • Whether you need your money in an emergency
  • Your attitude to investment risk – i.e. the potential for losses and gains and the volatility of investments
  • Explaining to you how the funds we may recommend are invested and their features, including how sustainability risks are considered in the management in relation to those funds.


Acumen & Trust does not currently take specific account of sustainability risks in its advice process. How we include sustainability factors in our advice process which will develop over time. This will be largely driven by the products and investment funds available from the Product Producers and how these products factor in sustainability risks.


Consideration of principal adverse impacts on sustainability factors in the advice process


Sustainability Factors are defined as environmental, social and employee matters, respect for human rights, anti-corruption and anti-bribery matters. Acumen & Trust have an option as to whether to consider the principal adverse impacts of investment decisions on sustainability factors in its advice process. Currently Acumen & Trust has decided not to consider such impacts separately from our overall risk framework. This decision has been made on the basis of the information available to Acumen & Trust from the Product Providers.

Under the SFDR, Product Providers are obliged to publish a statement explaining their due diligence policies with respect to the principal adverse impacts of investment decisions on sustainability factors by 30 June 2021. Acumen & Trust will actively monitor its position and update its processes, as further information becomes available from Product Providers.


You can also find information in relation to both sustainability risks and the principal adverse impacts of investment decisions on sustainability factors on the websites of the Product Providers and investment managers which we work with.


Remuneration Policies and the integration of sustainability risks


Acumen & Trust has its own Remuneration Policy in place. We follow effective risk management and include specific reference to the integration of sustainability risks where relevant. We do individual performance assessments with employees which consider risk management and control factors.