Statement on principal adverse impact of investment decisions on sustainability factors

Financial Advisory – Wealth Management
June 2023


Pursuant to Article 4(5) of Regulation (EU) 2019/2088 on sustainability-related disclosures in the financial services sector (“SFDR”), as further described in Article 11 of the Commission Delegated Regulation (EU) 2022/1288 (“SFDR Delegated Regulation”), this statement provides information on how Saxo Bank A/S (“Saxo Bank”) considers principal adverse impacts of investment advice on sustainability factors.


Principal adverse impacts are described as the negative material effects on sustainability factors, such as environmental and social matters, caused by or directly linked to the bank’s investment decisions in clients’ portfolios. The SFDR Delegated Regulation defines 18 mandatory principal adverse impact indicators and a number of additional voluntary indicators that financial advisers are required to report on, when considering principal adverse impacts of investment decisions on sustainability factors.

No consideration of principal adverse impacts of investment advice on sustainability factors

Saxo Bank A/S (“Saxo Bank” or the “bank”) does not, in its capacity as a financial advisor, consider principal adverse impacts of investment decisions on sustainability factors. There is currently a lack of comprehensive and standardised data reported in the market by fund manufacturers and the measurement of this data is a complex endeavour, therefore Saxo Bank is currently in the process of acquiring additional data from a 3rd party to meet reporting obligations under the SFDR. Additionally, this PAI data needs to be considered differently across the in-scope products that Saxo Bank provides advice on due to their distinct features and attributes.

As more data becomes available and a framework is established, Saxo Bank will enhance current methodologies to measure and monitor principal adverse sustainability impacts in current client investments with the current ambition to have this in place by end of 2023.

Nevertheless, when providing investment advice, Saxo Bank will treat each client in accordance with its individual investment needs (including a client’s investment objective, sustainability preferences, risk tolerance, ability to bear risks and knowledge and experience of financial matters.

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