AIMA has provided feedback to the European Commission’s proposal amending MiFID2 level 2 suitability requirements in relation to ESG considerations.

AIMA acknowledges and welcomes the growing trend and interest in sustainable and responsible investments. As our members are acting as agents for their clients, we recommend however that these considerations remain subject to the clients’ choices and preferences, both in terms of priorities of investment objectives and in terms of the definition of environmental, social and/or governance investments.

We also request that a possibility be left for portfolio managers not to consider ESG factors if the client so wishes, or that financial returns be still considered as a priority over ESG factors in case of negative financial impact of ESG factors on a client’s portfolio’s performance.

Should members have any comments or questions about this response, please contact Marie Adelaide de Nicolay.