Sustainable Related Disclosures

EU entity level sustainability risk disclosure


The statement is based on the requirements as set out in the Regulation (EU) 2019/2088 ("SFDR") of the European Parliament and of the Council of on sustainability-related disclosures in the financial services sector.


This statement applies to TD Greystone Global Real Estate Irish Portfolio (the "Fund") which is managed by TD Asset Management Inc. ("TDAM"). The Fund is currently designated as an article 6 fund.

No consideration of adverse impacts of investment decisions on sustainability factors

For the purposes of Article 6 of the Disclosures Regulation, the AIFM, in consultation with the Investment Manager, has determined that sustainability risk is not currently likely to have a material impact on the returns of the Fund. The Investment Manager places primary emphasis on the financial strength, income quality and role that any potential or current investment plays in a globally diversified portfolio.

The Investment Manager and the AIFM do not currently consider the principal adverse impacts of investment decisions on sustainability factors, due to the lack of information and data available to adequately assess such principal adverse impacts. For the purposes of the Regulation 2020/852 (the Taxonomy Regulation), it should be noted that the investments underlying the Fund do not take into account the EU criteria for environmentally sustainable economic activities.

Article 5 Disclosure - Transparency of remuneration policies in relation to the integration of sustainability risks

TDAM has remuneration plans and policies that support our strategic priorities, promotes sound and effective risk management, discourages excessive risk taking, avoids conflicts of interest, and is aligned to the interests of our clients and shareholders in promoting long term results. In line with SFDR, these frameworks integrate sustainability risk.

Article 30 Disclosure - Managing conflicts of interest

TDAM considers conflicts of interest with respect to sustainability risk by ensuring that the structure of remuneration does not encourage excessive risk taking with regards to sustainability risk, amongst others. TDAM has established and implemented a culture of risk management that permeates all functions of the business. TDAM has implemented effective risk related policies and procedures to identify, measure, manage and monitor all risks relevant to the fund's investment strategy on an ongoing basis. These policies and procedures ensure the Fund is managed in a way that is consistent with the integration of sustainability risks and prevent any activities that give rise to greenwashing, miss-selling or misrepresentation of strategies.

Article 40 Disclosure - Risk Management

TDAM recognises the importance of Environmental, Social and Governance ("ESG") risk factors. After due consideration is given to the underlying investment's financial strength and the Fund's role within a globally diversified portfolio, ESG factors are taken into consideration. We believe that the global diversification of the Fund's investments - from a geography, property type and risk perspective help mitigate risks that might arise from local negative sustainability events.

Sustainability risks may arise and impact a specific investment made by the underlying funds or may have a broader impact on an economic sector, geographical regions, or countries, which, in turn, may impact an underlying fund's investments. TDAM acknowledges that sustainability risks may impair the value of the investments made by the underlying funds, including in extreme cases the loss of the entire amount invested. These risks may be relevant as standalone risks but may also be linked to other risks to which the assets of the underlying funds are exposed. Laws, regulations, and industry norms play a significant role in controlling the impact on sustainability factors of many industries, particularly in respect of environmental and social factors.

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