Sustainable Finance Disclosure Regulation (SFDR) Disclosure Document

How Cornmarket Group Financial Services Ltd. (Cornmarket) approaches sustainability risks and adverse sustainability impacts in the advice we give you about savings, investment and pension products.

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

Cornmarket Group Financial Services Ltd. (Cornmarket) is authorised as an insurance intermediary by the Central Bank of Ireland. In this document when we say ‘we’ or ‘our’ we are referring to Cornmarket Group Financial Services Ltd.

Cornmarket Group Financial Services Ltd. holds written agency appointments with product providers (please see Appendix on page 26 of our Terms of Business Document for full details), who work with investment managers, for the provision of savings, investment and pension products and we provide advice to customers in relation to these products. The Cornmarket approach to sustainability risks and sustainability factors in its advice processes is driven by the products and investment options of these product providers in relation to the investment funds it makes available.

1.       How Cornmarket Group Financial Services Ltd. (Cornmarket) approaches the integration of sustainability risks when we give you advice about our products.

When we say ‘sustainability risk’ here we mean an environmental, social or governance (ESG) event or condition that could cause an actual or a potential negative impact on the value of a product we recommend to you.

We give advice on products provided by those product providers that we hold written agency appointments with. You can see how each product provider approaches sustainability risks for their investment products in their product disclosures and on their websites.  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.

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

2.       How we consider principal adverse impacts on sustainability factors in the Cornmarket advice process

 Sustainability Factors are defined as environmental, social and employee matters, respect for human rights, anti-corruption and anti-bribery matters. Financial Advisers, such as Cornmarket, have an option to consider the principal adverse impacts of investment decisions on sustainability factors in its advice processes. Currently Cornmarket has decided not to consider such impacts separately from our overall risk framework. This decision has been made based on the information available to Cornmarket from the product providers. Under the SFDR, Cornmarket must publish a statement explaining its due diligence policies regarding the principal adverse impacts of investment decisions on sustainability factors by 30th June 2021. Cornmarket will actively monitor its position, and update its processes, as more information becomes available from the product providers.

As explained in Section 1 above the funds made available to our customers are provided by the product providers. They will monitor and report on the principal adverse impacts of its investment decisions on sustainability factors.

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.

 

3.       How we integrate sustainability risk into our remuneration policies

 Cornmarket Group Financial Services Ltd. has its own remuneration policy. This policy ensures that we follow effective risk management and includes specific reference to the integration of sustainability risks. We do individual performance assessments with employees which consider risk management and control factors.