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Greenwashing risks in asset management

Staying one step ahead

Recent years have seen a proliferation of funds which describe themselves as sustainable or environmentally conscious. This increase has been boosted by a fast-growing sustainable finance regulatory framework in the EU and UK, alongside increasing investor demand.

Against this backdrop, regulators have become increasingly concerned about the risk of “greenwashing” – a situation where a firm makes misleading or exaggerated claims about the environmental benefit of its products or services. Conventionally seen as a conduct risk, i.e., an act of wilful misconduct through mis-selling or misrepresentation, greenwashing or the perception of greenwashing might also occur inadvertently. A lack of standardised and complete sustainability data and a new landscape of unfamiliar sustainability related terminology could result in end-investors not understanding funds’ objectives and strategies.

As regulators continually release new sustainability related regulations to tackle this concern, asset managers need to stay alert to the risk of greenwashing and our paper sets out the points along a customer’s asset management journey where the risk of greenwashing might occur and how asset managers can stay one step ahead of that risk. This includes specific actions for Boards, as well as different teams at asset management firms, including portfolio managers and control functions (such as compliance, risk and audit).

The paper discusses upcoming sustainable finance regulation in the EU and UK, as well as existing regulations that are relevant to greenwashing. Some of the regulatory initiatives discussed in the context of greenwashing are the EU Sustainable Finance Disclosure Regulation (SFDR), the FCA Sustainability Disclosures Requirement (SDR) and the FCA’s Dear AFM Chair letter on transparency.

The paper splits the asset management journey into three stages, identifies the key risks at each stage, and sets out the actions firms should take along the journey


Pre-contractual stage

  • Sustainability data
  • Special Feature: Lessons from other industries
  • Clear language and communications
  • Investment strategies
  • Special feature: conflicts of interest
  • Special feature: SFDR and greenwashing
  • Third party distribution
Read more here

Post-investment stage and ongoing reporting

  • Post-investment sustainability data
  • Ongoing reporting
Read more here

Complaints handling

  • How might greenwashing claims arise
  • How might asset management firms address claims
Read more here

About the EMEA Centre for Regulatory Strategy

The Deloitte Centre for Regulatory Strategy is a powerful resource of information and insight, designed to assist financial institutions manage the complexity and convergence of rapidly increasing new regulation.

With regional hubs in the Americas, Asia Pacific and EMEA, the Centre combines the strength of Deloitte’s regional and international network of experienced risk, regulatory, and industry professionals – including a deep roster of former regulators, industry specialists, and business advisers – with a rich understanding of the impact of regulations on business models and strategy.

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