Transparency of negative sustainability impacts at entity level

Luxembourg, 21 August 2023

Regulatory framework

On 10 March 2021, European Regulation (EU) 2019/2088, known as the Sustainable Finance Disclosure Regulation (SFDR), came into effect for the financial services sector. The SFDR aims to enforce transparency requirements for sustainability at both entity and product levels.

Article 4 of Regulation (EU) 2019/2088 requires transparency on considering the negative impacts of investment decisions on sustainability factors.

Declaration of non-inclusion of main negative impacts

At the entity leel, Spuerkeess has not yet considered the principal adverse impacts (PAIs) of investment decisions and advice, in accordance with Article 4 SFDR. However, as a Transition Enabler with strong commitment to sustainable development, Spuerkeess plans to incorporate these PAIs at the entity level once the necessary tools are in place by 2023.

The reason for not including these PAIs at the entity level is the lack of maturity of the required data, which makes it difficult to obtain them for all the investments made by Spuerkeess.

Additionally, Spuerkeess offers products that address negative impacts in the context of sustainable characteristics and/or objectives, as stated in the specific product documentation. While sustainability factors are considered in investment decisions to manage sustainability risks, negative impacts as defined by Regulation (EU) 2019/2088 are not currently taken into account at the entity level. This position will be reassessed during the year, based on advancements in data regarding these PAIs.

Description of policies for identifying and prioritising principal adverse impacts

Principle of dual materiality

The analysis at Spuerkeess focuses on dual materiality, which is crucial. ESG analysis and trends can be divided into two closely related subcategories:

  • Sustainability risk: This refers to an environmental, social or governance (ESG) event that, if it occurs, could significantly impact the value of financing and investments. Sustainability risks may be risks on their own or have an impact on other risks such as market, operational, liquidity, or counterparty risks.
  • Negative sustainability impacts: These are the negative impacts of investment decisions from an environmental, social or good governance perspective. To measure negative impacts, we refer to the indicators defined in the technical standards of the SFDR.

Engagement policy

Spuerkeess Asset Management (S-AM) has developed a voting and engagement policy which outlines the principles it follows when exercising voting rights. This policy is available on the S-AM website.

References to international standards

In 2019, Spuerkeess became a signatory of the United Nations Principles for Responsible Banking. These principles provide a framework for a sustainable banking system and help the industry demonstrate the industry’s positive contribution to society. We are proud to be the first Luxembourg bank to sign onto these principles in October 2019. Our commitment includes being transparent and accountable for our positive and negative impacts, as well as our contribution to the Sustainable Development Goals and the Paris Agreements.

Spuerkeess also adheres to several standards and initiatives that promote sustainable finance, such as the Global Reporting Initiative (GRI), Sustainability Accounting Standards Board (SASB), AA1000 SES principles, ESR label of the National Institute for Sustainable Development and Corporate Social Responsibility (INDR).


If you have any questions about sustainable development, you can contact the Strategic and Sustainability Office through S-Net message, email or mail at the provided address:

Banque et Caisse d’Epargne de l’Etat, Luxembourg
Strategic and Sustainability Office
1 Place de Metz
L-2954 Luxembourg