Greenfin label : France finance verte : criteria guidelines
Auteur moral
France. Ministère de la transition écologique et solidaire
;France. Ministère de la transition énergétique (2022-...)
Auteur secondaire
Résumé
Le référentiel définit les critères pour la labellisation des fonds candidats. Un critère décrit une exigence mesurable du label. Des déclinaisons et des sous-déclinaisons de critères précisent ceux-ci pour certains types d'unité de certification. A chaque critère et sous-critère est attaché un indicateur, quantitatif ou qualitatif permettant d'évaluer la réalisation du critère.
Descripteur Urbamet
moyen de financement
;transition écologique
Descripteur écoplanete
Thème
Administration publique
Texte intégral
FRENCH MINISTRY FOR ECOLOGICAL TRANSITION
AND TERRITORIAL COHESION
FRENCH MINISTRY FOR ENERGY TRANSITION
Criteria Guidelines
January 2024 version
This English version is a courtesy translation. Only the French version shall prevail.
Greenfin label Criteria Guidelines 2 / 32
Contents
Foreword 3
Description and structure of the Criteria Guidelines 4
1. Eligibility criteria for candidate funds 5
2. Label criteria by pillar 7
Appendix 1 - Definition of activities falling within the scope of the energy and ecological transition 13
Appendix 2 ? Excluded companies 26
Appendix 3 - Portfolio allocation thresholds between the various allocation categories 27
Appendix 4 - Information to be submitted regarding environmental impact measurements 30
Appendix 5 - Requirements for the use of derivative instruments within the framework of a Greenfin fund 31
Appendix 6 - List of documents to submit 32
Greenfin label Criteria Guidelines 3 / 32
Foreword
As a result of the discussions that took place at the Banking and Finance Conference on Energy
Transition of June 2014 a label has been created that makes it possible to specifically identify investment
funds contributing to the energy and ecological transition.
The creation of such a label is one of the public policies called for by Article 2 of Energy Transition for
Green Growth Law of August 2015.
Its creation has been guided by a desire to promote "green" funds in order to further steer savings
towards energy and ecological transition and the fight against climate change, either by drawing attention
to existing investment funds or by giving rise to the creation of such funds. It is a guarantee, for investors
and individual savers in particular, of the quality and transparency of the environmental characteristics of
the funds distinguished in this way and of their contribution to the energy and ecological transition and the
fight against climate change.
As a public label, the Greenfin Label must be ambitious. In addition, although covered by French legal
standards, this label can be applied to financial funds from other countries in the European Union or
non-member countries.
To successfully create the label, a working group bringing together the representatives of all the
stakeholders worked from October 2014 to August 2015 to draw up a general system and a draft Criteria
Guidelines, plus a draft framework inspection and monitoring plan applicable to the Greenfin Label.
The first version of this Criteria Guidelines resulting from this work was submitted for public consultation
from 22 September 2015 to 11 October 2015 by the French Ministry in charge of environment. Revisions
to update and improve the Criteria Guidelines will be planned as often as the Label Committee considers
necessary.
Greenfin label Criteria Guidelines 4 / 32
Description and structure of the Criteria Guidelines
The Criteria Guidelines sets out the criteria for the labelling of candidate funds. A criterion describes one
of the label?s measurable requirements. These are stipulated by sets and sub-sets of criteria for some
types of certification unit. For each criterion or sub-criterion there is a quantitative or qualitative indicator,
making it possible to evaluate whether or not the criterion has been met.
The methods used for the assessment and approval of the principles and criteria, whether compulsory
or discretionary, are described in the requirements summary chart and in the monitoring framework plan.
The Criteria Guidelines centres on the following concepts:
? Eligibility criteria in terms of scope;
? Pillars ? Label criteria;
? Definition of the activities falling within the scope of the energy and ecological transition and the fight
against climate change;
? Strict and partial exclusions;
? Requirements for the use of derivative instruments within the framework of Greenfin management.
Greenfin label Criteria Guidelines 5 / 32
Content of the Criteria Guidelines
1. ELIGIBILITY CRITERIA FOR CANDIDATE FUNDS
Title Requirements Information required, standard to be met
Checks to be carried out during the
certification request
I. Eligible
funds
Are eligible:
i. Funds falling under UCITS V Directive1;
ii. Alternative Investment Funds (AIFs) having no major leverage
effect2 as defined in the AIFM Directive3. For fundsmarketed in
France, this means all Alternative Investment Funds falling
under section 2, chapter IV, title I, of section II of the French
Monetary and Financial Code excluding, at the present time
Sociétés d?Epargne Forestière (SEF) [Forestry Investment
Companies];
iii. In formation private equity and infrastructure AIFs.
Prospectus, Key Investor Information
Document [KIID] and fund regulations (for
funds in formation).
Verify that funds marketed in France have been registered / approved in the
AMF?s GECO [Gestion Collective (Collective Management)] database and
in the equivalent databases for funds marketed in other European Union
countries.
Verify that the fund is:
- Either a UCITS falling under the scope of UCITS V1 Directive;
- Or an Alternative Investment Fund falling under the scope of the AIFM
Directive, authorised for marketing in the European Union, the substantial
direction of a fund?s leverage effect being assessed using the definition
given in the Commission?s Delegated Regulation (EU) No. 231/2013 of
19 December 20123.
II. Funds?
assets
Fund assets are comprised of securities issued by issuers or claims
on issuers of which majority have their registered head office in the
European Union, with the exception of bond fundsto which this
geographical constraint does not apply.
Debt securities issued by States, local and regional authorities and
government or international public agencies can be
included in eligible funds insofar as the rules set out under criterion
1.2 b) are strictly adhered to.
Investment rules and types of eligible
assets.
Audit the fund?s assets for existing funds or the fund?s regulations for funds
in formation in order to verify the registered office of the asset issuers.
In the case of bond funds, verify that the fund management company is
aligned with the ?Green Bond Principles? set out by the International Capital
Market Association (ICMA).
In the case of private debt funds, verify that the fund management company
is alignedwith the ?Green Loans Principles? set out by the ICMA.
1 Directive 2014/91/EU of the European Parliament and of the Council of 23 July 2014 amending Directive 2009/65/EC concerning the coordination of the legal, regulatory and administrative provisions pertaining to certain
Undertakings for Collective Investment in Transferable Securities (UCITS) as regards depositary functions, remuneration policies and sanctions, known as the UCITS V Directive.
2 The Commission?s Delegated Regulation (EU) No. 231/2013 of 19 December 2012 supplementing Directive 2011/61/EU of the European Parliament and of the Council concerning special dispensations, general operating
conditions, depositories, the leverage effect, transparency and monitoring.
3 Directive No. 2011/61/EU of the European Parliament and of the Council of 8² June 2011 concerning the managers of Alternative Investment Funds and amending Directives 2003/41/EC and 2009/65/EC in addition to
regulations (EC) No.1060/2009 and (EU) No. 1095/2010, known as the AIFM ? Alternative Investment Fund Managers - directive [FIA Directive in France]).
Greenfin label Criteria Guidelines 6 / 32
Title Requirements Information required, standard to be met
Checks to be carried out during the
certification request
III. Special
cases
a) Funds of funds or multi-management funds
Funds of funds must be invested 90% at minimum in funds having
the Greenfin label. The remaining 10% should not be invested in
non-label funds but in transferable securities or money market
instruments as defined in Article 50 (2)(a) of the aforementioned
UCITS Directive.
b) Feeder funds
Feeder funds are eligible for the label given that the master fundis
labelled.
Portfolio statement and prospectus.
Portfolio statement indicating, for each
fund, the name of the label obtained or
sought, and prospectus.
Check the composition of the portfolio in terms of the eligibility of the
underlying funds,namely:
- That the funds invested are labelled;
- The 90% Greenfin labelled funds ratio is being respected.
In the event that compliance with a quantitative standard is required and
the candidatefund does not have a history sufficient to demonstrate its
compliance with the standard, the criterion is considered to be met once
the candidate fund commits, within the framework of the internal monitoring
procedures put in place by the portfoliomanagement company to ensure
the fund?s compliance with regard to the Greenfin Criteria Guidelines, to
comply with the standard in the 12 months that follow the awarding of the
label.
In order to assess "long-lasting" compliance with a quantitative standard,
the certification body, examines the mean, arithmetical or geometrical as
appropriate, of the monthly averages for this standard for the 12 months
preceding the application for label request.
Greenfin label Criteria Guidelines 7 / 32
2. LABEL CRITERIA BY PILLAR
Criteria Information required, standard to be met
Checks to be carried out during certification
and renewal audits
PILLAR I - FUND?S OBJECTIVES AND METHODOLOGY FOR THE SELECTION OF ASSETS CONTRIBUTING TO THE ENERGY AND ECOLOGICAL
TRANSITION
Criterion 1.1 - The general,
financial and specific
environmental objectives sought
through the consideration of
environmental criteria as part of
the investment policy must be
clearly described in the
documents given to investors.
The candidate shall provide the following information or answer the following questions while specifying the
marketing materials in which this information appears (the term "marketing materials" should be understood in
its broadest sense: prospectuses, website, transparency code, etc.):
i. What are the general objectives (impact on companies) sought through the consideration of environmental criteria
in the investment policy, notably with regard to desired outcomes (see Pillar III)? How are these defined and described
to investors?
ii. Do you have any financial objectives (medium-term extra-performance, risk reduction, or profitability/risk arbitrage,
etc.) or objectives of any other type (ethical, etc.) linked to the consideration of environmental objectives? If the
answer is yes, what are these and how are they defined and described to investors?
iii. Which environmental objectives are sought by the consideration of environmental criteria in the investment policy?
How are these objectives defined and described to investors?
Check the accuracy, completeness, adequacy and
quality of the information provided by the candidate
with regard to the documentation required and the
questions asked.
Check that the documentation addresses points (i)
to (iii).
Any candidate fund that does not declare any
precise environmental objectives, notably those
specified under Pillar III, does not meet this
criterion.
Criterion 1.2 - The methodology
for evaluating the "green share"
of the portfolio must be described
clearly and coherently.
a) The candidate fund?s management company shall:
i. Provide the documentation accessible to investors describing the method for estimating the portion of turnover
supporting the energy and ecological transition for each existing or target portfolio constituent for existing funds
or funds in formation respectively;
ii. Describe how the implementation of this method influences its investment policy.
Check the accuracy, completeness, adequacy and
quality of the documentation provided by the
candidate with regard to the documentation
required and the questions asked.
Check that the method for estimating the "green"
share of turnover is accessible to investors and can
be understood by them.
Check that methodology is reviewed on an annual
basis at minimum.
A candidate fund that declares a methodology for
"green share? identification that does not make it
possible to achieve a selection of assets
contributing to the energy and ecological transition
does not meet this criterion.
Greenfin label Criteria Guidelines 8 / 32
b) The fund shall provide and publish a full and up to date inventory (including the number of securities and
the most recent valuations accepted) of its portfolio, notably specifying:
For private equity funds fully or partially invested in unlisted securities:
- That at least 75% of the fund?s total assets under management is invested in companies for which turnover supporting
the energy and ecological transition in accordance with the classification set out in appendix 1 is at least 50%.
- The source of the information used to answer the previous question.
For bond funds:
- That the percentage of assets under management invested in green bonds must be at least 75% of the fund?s total
assets under management. Within the meaning of the Greenfin label, a green bond is defined as being issued by a
company whose turnover contributing to the energy and ecological transition according to the taxonomy defined in
Annex 1 is strictly greater than 50%, or as simultaneously meeting the following three criteria:
? The bond must comply with the Green Bond Principles (GBP) set out by the International Capital Market
Association (ICMA);
? The bond must finance projects strictly falling under the classification set out in appendix 1;
? The obligation shall not finance any excluded activities (see appendix 2).
? The source of the information used to answer the previous question.
For private debt funds:
- That at least 75% of the fund?s total assets under management is invested in companies for which turnover supporting
the energy and ecological transition in accordance with the classification set out in appendix 1 is at least 50%.
- The source of the information used to answer the previous question.
For Reals Estate Collective Investment Schemes ? RECIS? (OPCIs):
- That at least 60% assets under management in green real estate defined by the reference in Appendix 1. The green
share is made up of 100% real estate assets (buildings, RECIS shares, listed real estate companies, companies owning
buildings);
- The remaining 40% should not finance excluded activities (see Appendix 2);
- The source of the information used to answer the previous point.
For Real Estate Investment Trusts ? REITs (SCPIs):
- That at least 90% assets under management in green real estate defined by the reference system in Appendix 1. The
green share is made up of 100% real estate assets (buildings, OPCI shares, listed real estate companies, companies
owning buildings);
- The remaining 10% should not finance excluded activities (see Appendix 2);
- The source of the information used to answer the previous point.
Special case of bonds aiming partly projects from the classification set out in appendix 1 and partly projects
with social or societal value-added
- The bond takes into account only projects from the classification set out in appendix 1 only.
Check that the method for estimating the green
share is transparent, clear and sufficiently
referenced to be verifiable (existence of evidence
and audit trails).
Check, by sampling, that the "green shares"
estimated are statistically acceptable.
In order to assess "long-lasting" compliance with a
quantitative standard, the certification body
examines the mean, arithmetical or geometrical as
appropriate, of the monthly averages for this
standard for the 12 months preceding the
application for label request.
For private equity funds, calculations must be made
by comparing the prices of the investments (and not
their valuation) to the paid-up commitments.
For RECIS? and REITs (OPCI and SCPI) :
For buildings having an environmental certification
(or label), an energy certification (or label), a life
cycle analysis, in the context of a new
construction, renovation or operation, the
certification body verifies:
- that the certificate attesting to the obtaining of
this environmental certification / label was issued
less than 5 years ago by an independent
certification body;
- that the life cycle analysis has been carried out
or verified by an independent third party;
- that the energy certification (or label) has been
issued under a certification process based on the
completion of a thermal study and that energy
consumption is at least 30% lower than local
standards.
For building compounds having actions to improve
their performance, the certification body verifies:
- that the system for measuring and monitoring
final energy consumption and greenhouse gas
emissions is in operating phase (measuring and
verifying its actual performance) and at least once
a year;
- that the action plan for an overall reduction in
Greenfin label Criteria Guidelines 9 / 32
For all other funds invested in listed securities:
- That the percentage of assets under management invested in companies for which turnover supporting the energy and
ecological transition in accordance with the classification set out in appendix 1 is strictly above 50%, must be equal to
or greater than 20% of the fund?s total assets under management (Category 1);
- That the percentage of assets under management invested in companies for which turnover supporting the energy and
ecological transition in accordance with the classification set out in appendix 1 is strictly below 10% or invested inother
debt securities, must be equal to or less than 25% of the fund?s total assets under management (Category 3);
- That the portfolio?s remaining assets under management are comprised of companies for which turnover supporting
the energy and ecological transition in accordance with the classification set out in appendix 1, is within the range [10%;
50%] (Category 2);
- In the case of mixed funds incorporating green bonds, the assets under management for these bonds shall fall within
the Category 1 assets under management;
The source of the information used to respond to the four previous points.
final energy consumption and greenhouse gas
emissions during the operating phase is 40% in
2025, 55% in 2030 compared to 2013 (or at a
given later date);
- the action plan is budgeted and includes annual
intermediate objectives .
- an annual reporting of the achievement of the
intermediate objectives is verified by an
independent third party.
For green bond funds or mixed funds containing
green bonds, check that each of the fund?s bond
components is subject to an independent third-
party verification making it possible to ensure that
these components are aligned with the "Green
Bond Principles" of the International Capital Market
Association (ICMA) and the CBI [Climate Bond
Initiative] eligibility criteria where they exist
c) For funds in formation, the management company shall describe the investment policy that it intends to
implement for the candidate fund, notably specifying:
Special case of private equity funds in the process of fund raising:
- The percentage of anticipated assets under management in companies for which turnover supporting the energy and
ecological transition in accordance with the classification set out in appendix 1 is at least 50%. This percentage must
be at least 75% of the fund?s total assets under management.
Special case of deb-based infrastructure funds in the process of fund raising:
- The percentage of anticipated assets under management in green bonds (in accordance with the definition given in
1.2.b) must be at least 75% of the fund?s total assets under management.
Check the accuracy, completeness, adequacy and
quality of the documentation provided by the
candidate with regard to the documentation
required and the questions asked.
Check that candidate fund regulation complies with
the requirements provided for.
d) Special case of funds of funds or multi-management funds
The rules set out under the previous points shall apply.
Check that the method chosen to ensure
transparency allows for verification that criterion
1.2 is met.
Criterion 1.3 - Assets that run
counter to the energy and
ecological transition are
excluded.
No investment shall be made in companies, projects or activities pertaining to the excluded sectors set out in appendix
2, with the exception of their green bonds as defined above.
Check the accuracy, completeness, adequacy and
quality of the information required.
In order to assess "long-lasting" compliance with a
quantitative standard, the certification body,
examines the mean, arithmetical or geometrical as
appropriate, of the monthly averages for this
standard for the 12 months preceding the
application for label request.
Greenfin label Criteria Guidelines 10 / 32
Criteria Information required, standard to be met
Checks to be carried out during certification
and renewal audits
PILLAR II ? CONSIDERATION OF ESG CRITERIA IN THE CONSTRUCTION AND LIFE OF THE PORTFOLIO
Criterion 2.1 - Application of the
principles of corporate social
responsibility involves actively
monitoring the environmental(E),
social (S) and governance
(G) controversies of underlyings
and the fund shall demonstrate
their impact on the construction
and life of the portfolio
Issuers contravening the conventions on the prohibition of the use, storage, production and relocation of anti-personnel
mines and their destruction (known as the 1997 Ottawa Convention) and concerning cluster munitions (known as the 2008
Oslo Convention) are excluded.
For existing funds, the fund shall provide and publish:
- A description of the ESG controversy active monitoring and management process used and of the corresponding
resources mobilised. The fund shall notably specify its ex-ante and ex-post mechanisms for addressing controversy
and the measures taken (where appropriate, the fund shall distinguish between majority or minority holdings);
- The frequency with which these mechanisms are adjusted, if necessary;
- The list of the companies that have been excluded due to proven, serious and repeated controversies as well as the
duration of the exclusion;
- The list of companies under-weighted in the portfolio due to an ESG controversy and the magnitude of the under-
weighting with regard to the initial situation.
For funds in formation, the fund shall provide and publish:
- A description ESG controversy of the active monitoring and management process used and the corresponding
resources mobilised in the actual investment phase, in order to anticipate and manage ESG controversies. The fund
will notably specify its ex-ante and ex-post controversy mechanisms and the measures taken (the fund shall distinguish
between majority or minority holdings);
- A description of the commitments undertaken on the matter with regard to its subscribers;
- The frequency with which these mechanisms will, if necessary, be adjusted;
Check the accuracy, completeness, adequacy and
quality of the information required.
A candidate fund that has not put this type of
mechanism in place does not meet this criterion.
Criterion 2.2 ? Some of the
fund?s financial management
practices must be transparent
a) The use of derivative financial instruments must be limited to techniques allowing for the effective
management of the portfolio of securities in which the candidate fund is invested (see appendix 5 for the
detailed information required).
If the candidate fund uses derivative instruments, it should specify:
- Their type;
- The objective(s) pursued and their compatibility with the fund?s long-term management objectives;
- The potential limits in terms of exposure (in amount and duration).
The use of derivative instruments should not result in the significant or lasting alteration of the fund?s investment policy.
b) The fund shall calculate the rotation rate of its portfolio defined as:
Half of the sum of capital purchases and sales over the last 12 months from which we subtract the sum of redemptions
and subscriptions / the average of net assets over the period. A rotation rate above [2] must be justified by particular,
objective and quantified market conditions: Modification of the fund?s investment strategy, substantial market volatility,
substantial volatility of movements in the fund (subscriptions and redemptions), etc.
This criterion does not apply to private equity funds nor to funds in formation.
Check the accuracy, completeness, adequacy and
quality of the documentation provided by the
candidate with regard to the documentation
required and the questions asked.
Check the accuracy of the method used and the
information required.
Greenfin label Criteria Guidelines 11 / 32
PILLAR III ? HIGHLIGHTING POSITIVE IMPACTS ON ENERGY AND ECOLOGICAL TRANSITION
Criterion 3.1 - The fund must
have put in place a mechanism
for measuring the actual
contribution of its investments to
the energy and ecological
transition
The fund shall provide information on the organisation put in place to measure the environmental impact of its
investments. The fund shall specify:
i. The resources, in particular the human resources, deployed;
ii. The method for evaluating the impact and the impact indicators chosen;
iii. Where applicable:
? Assurance or verification certificates issued by an external third-party organisation for the indicators produced;
? A comparison of the indicators chosen with potential benchmarks, if they exist.
Details of the information to be provided are presented in appendix 4.
The fund shall specify, on the basis of the impacts recorded through the indicators provided, that the impacts obtained
are consistent with the fund?s objectives as described within the framework of criterion 1.1 above.
Check the accuracy, completeness, and adequacy
of the information required.
Check that the method for indicator development
is transparent, clear and sufficiently referenced to
be auditable (existence of evidence and audit
trails).
Criterion 3.2 - The fund shall
report on indicators of impacts
that benefit the energy and
ecological transition
a) For existing funds
The fund shall measure the actual contribution of its investments and comment on its development, in one of the four
areas below, not necessarily exclusively:
i. Climate change;
ii. Water;
iii. Natural resources;
iv. Biodiversity.
For more information on the proposed indicators, please see appendix 4.
b) For funds in formation
The fund will indicate which environmental impact indicators it intends to implement and monitor in at least one of the
four areas set out above.
Verify that the indicators provided are genuine and
indicate the corresponding level of assurance.
Greenfin label Criteria Guidelines 12 / 32
Activities directly or indirectly contributing to "green growth" through the development of renewable energies (wind, solar, geothermic, hydraulic, marine, from
biomass, etc.), the energy efficiency and the low carbon footprint of industrial buildings and processes, the circular economy, clean transport, agriculture and
forestry, infrastructure for adapting to climate change, and so forth, fall within the scope of the energy and ecological transition. These are "activities that produce
goods and services aimed at protecting the environment or managing natural resources, i.e. intended to measure, prevent, limit or address environmental
damage to water, air and soil and the problems surrounding waste, noise and ecosystems for the well-being of Mankind? (international definition from the
OECD and Eurostat).
The activities eligible within the context of the Greenfin label are those strictly appearing in the taxonomy as presented in this appendix.
This taxonomy is initially based on that of the Climate Bond Initiative4 (CBI).
4 https://www.climatebonds.net/standards/taxonomy2
Appendix 1 - Definition of activities falling within the scope of the energy and ecological
transition
https://www.climatebonds.net/standards/taxonomy2
Greenfin label Criteria Guidelines 13 / 32
?? Energy
Solar energy
Wind energy
N u c l e a r e n e r g y
Bioenergy
Hydraulic energy
Geothermal energy
Other renewable energies
Energy distribution and management
Energy storage
Carbon capture
Services
?? Building
Low carbon buildings
Energy efficiency
Energy capture systems
Services
?? Circular Economy
Technologies and products
Services
Waste energy valorization
Existing fossil fuels energy valorization
Waste management
?? Industry
Energy-efficient products
Energy-efficient systems and processes
Cogeneration, tri-generation, etc.
Waste heat recovery
Reduction of GHGs not linked to energy production
Reduction of pollution
Eco-efficient industrial processes
Services
Organic agro-food industry
?? Transport
Freight and railway transport system
Urban rail transport system
Electric vehicles
Hybrid vehicles
Alternative fuel vehicles
Bus Rapid Transit
Maritime Transport
Bicycle transport
Biofuels
Aviation biofuel
Transport logistics
?? Information and Communications Technology
Data centres running on renewable energies
Low-carbon facilities
Products and technologies running on smart grid
Substitution technologies
?? Agriculture & forestry
Organic agriculture
Sustainable agriculture
Forestry activities emitting less carbon and linked to carbon sequestration
Low GHG emission agriculture, sequestering carbon and climate resilient
?? Adaptation
Water adaptation
Infrastructures
Greenfin label Criteria Guidelines 14 / 32
1. Energy
Area Specific category and activity Description
Solar energy
Photovoltaic solar electricity Development, construction and operation of generation facilities
Concentrating solar power plant Development, construction and operation of generation facilities
Infrastructure and manufacturing
Operational production or production infrastructure entirely dedicated to the development of solar
energy
Transmission
Energy transmission facilities entirely dedicated to solar source electricity generationinfrastructures
listed in the classification
Wind energy
Wind farms Development, construction and operation of generation facilities
Infrastructure and manufacturing
Operational production or manufacturing facilities fully dedicated to the development of wind
energy
Transmission Energy transmission facilities entirely dedicated to wind power generation infrastructures
Nuclear energy
All economic activities enabling the production of energy from nuclear technologies, including fuel
cycle and radioactive waste management technologies (in accordance with current
European regulations (EURATOM directive 2011/70) or equivalent)
Bioenergy
Renewable feedstocks Bioenergy from sources that do not deplete existing terrestrial carbon pools
Infrastructure and manufacturing
Operational production or production infrastructure fully dedicated to the development of
bioenergy
Methanisation Anaerobic digestion of organic matter
Networks
Energy transmission infrastructure (power lines, transport lines, pipelines, etc.) entirely dedicatedto
bioenergy
Hydroelectricity
Run-of-river and small hydroelectric power stations
<15MW ("small project" threshold defined by the Clean
Development Mechanism - CDM ? established by the Kyoto
protocol)
Small hydroelectric facilities that require small or no reservoirs
Large hydroelectric facilities >20MW in temperate zones In accordance with the European regulations in effect5 or equivalent
Re-powering of existing major hydroelectric systems
New infrastructure applied to existing facilities in order to improve the efficiency and energy
production of existing hydroelectric facilities
Geothermal
Geothermal electricity Development, construction and operation of geothermal energy generation facilities
Geothermal Heat Pump (GHP) Technology
GHP used for energy storage, renewable energies, waste heat recovery, energy efficiency,intelligent
demand management/smart networks and district energy systems
Other renewable
energies
Sea and ocean-derived energy sources Development, construction and operation of generation facilities
5 Compliance Report assessing application of article 11 b(6) of the Emissions Trading Directive to these types of projects.
Greenfin label Criteria Guidelines 15 / 32
1. Energy
Area Specific category and activity Description
Energy distribution
Transmission and grid infrastructure
New or additional energy transmission and distribution infrastructure (power lines, transport lines,
pipelines etc.) required to connect eligible renewable energies to national grids and systems
New or additional infrastructure required to support the integration of renewable energies and
energy efficiency systems and their load-balance
Smart systems and meters Systems and meters that support improved energy management
Heating management Geothermal heat pumps
Energy storage
Hydroelectric energy storage systems Pumped Storage Hydroelectric Power Stations (PSHPS)
Geothermal heat storage Examples include molten salt heat storage; GHP technology for heat storage
New technologies
Technologies which increase energy storage options (hydrogen obtained through electrolysis for
example)
Carbon capture Carbon capture and storage Including the building sector
Services Energy services
Design and realisation of energy-related savings, renovation and risk management projects (of
the EDCS [Electronic Draft Capture Service] type)
Greenfin label Criteria Guidelines 16 / 32
2. Building
Area Specific category and activity Description
Low carbon
buildings
Tertiary
Building certified or labeled less than 5 years ago for new construction
Building having :
1) an environmental certification for new construction or an environmental label issued under a certification
process, recognized internationally or by a Member State of the European Union and issued less than 5 years
ago years by an independent third party;
2) a life-cycle analysis (according to the ISO 14 040 standard) carried out or verified less than 5 years ago by
an independent third-party organization, which makes it possible to characterize the various environmental
indicators of the project, in particular the impact on climate change (including greenhouse gas emissions), the
consumption of natural resources, the production of waste, and this over the entire life cycle analysis of the
building (from construction to deconstruction through operation phase);
3) an energy label issued in accordance with a certification process based on a thermal study, recognized
internationally or by a Member State of the European Union and issued less than 5 years ago by a independent
third party. This energy label certifies the achievement of energy performance above local standards: energy
consumption must meet the threshold of the local standard - 30%.
Building certified or labelled less than 5 years ago for renovation or operation
Building having :
1) an environmental certification for renovation or operation (or an environmental label issued through a
certification process), recognized internationally or by a Member State of the European Union and issued less
than 5 years ago by an independent third party;
2) an energy label for renovation or operation issued under a certification process, recognized internationally
or by a Member State of the European Union and issued less than 5 years ago by an independent third party.
This energy label attests to the achievement of energy performance aimed at minima a reduction of the overall
primary energy consumption of the building by 30% compared to its state before renovation.
A defined set of buildings (in its entirety) subject to improvement actions with:
1) a minimum annual measurement and monitoring of its final energy consumption and its greenhouse gas
emissions during the operating phase (measurement and verification of its actual performance);
2) an action plan for an overall reduction of its final energy consumption and greenhouse gas emissions in the
operating phase of 40% in 2025, 55% in 2030 compared to 2013 (or at a given later date). The action plan must
be budgeted and include annual intermediate objectives ;
3) an annual reporting of achievement of these intermediate objectives verified by an independent third party.
Greenfin label Criteria Guidelines 17 / 32
Residential
Building certified or labeled less than 5 years ago for new construction
Building having :
1) an environmental certification for new construction or an environmental label issued under a certification
process, recognized internationally or by a Member State of the European Union and issued less than 5 years
ago years by an independent third party;
2) a life-cycle analysis (according to the ISO 14 040 standard) carried out or verified less than 5 years ago by
an independent third-party organization, which makes it possible to characterize the various environmental
indicators of the project, in particular the impact on climate change (including greenhouse gas emissions), the
consumption of natural resources, the production of waste, and this over the entire life cycle analysis of the
building (from construction to deconstruction through operation phase);
3) an energy label issued in accordance with a certification process based on a thermal study, recognized
internationally or by a Member State of the European Union and issued less than 5 years ago by a independent
third party. This energy label certifies the achievement of energy performance above local standards: energy
consumption must meet the threshold of the local standard - 30%.
Building certified or labelled less than 5 years ago for renovation or operation
Building having :
1) an environmental certification for renovation or operation (or an environmental label issued through a
certification process), recognized internationally or by a Member State of the European Union and issued less
than 5 years ago by an independent third party;
2) an energy label for renovation or operation issued under a certification process, recognized internationally
or by a Member State of the European Union and issued less than 5 years ago by an independent third party.
This energy label attests to the achievement of energy performance aimed at minima a reduction of the overall
primary energy consumption of the building by 30% compared to its state before renovation.
A defined set of buildings (in its entirety) subject to improvement actions with:
1) a minimum annual measurement and monitoring of its final energy consumption and its greenhouse gas
emissions during the operating phase (measurement and verification of its actual performance);
2) an action plan for an overall reduction of its final energy consumption and greenhouse gas emissions in the
operating phase of 40% in 2025, 55% in 2030 compared to 2013 (or at a given later date). The action plan must
be budgeted and include annual intermediate objectives ;
3) an annual reporting of achievement of these intermediate objectives verified by an independent third party.
Energy efficiency
technology and
products
manufacturing and
supply
Operational performance will recognise the special purpose
products needed to ensure that the buildings meet industry
standards as LEED and BREEAM
Thermal insulation materials
High performance HVAC (Heating, Ventilation and Air Conditioning) systems
Centralised energy control systems; home energy displays and smart meters
Advanced, efficient appliances and lighting (e.g. LED)
Advanced materials (e.g. reflective roof materials/systems)
Energy capture
systems
Systems that increase overall energy efficiency Collective heating systems, district heating networks using at least 50% renewable energy, 50%
waste heat, 75% heat from cogeneration or 50% of a combination of these types of energy or heat
Services Energy services
Design and realisation of energy saving, thermal renovation and energy-related risk management
projects (of the EDCS type)
Greenfin label Criteria Guidelines 18 / 32
3. Circular economy
Circular economy activities must meet the eligibility criteria of the Greenfin label and be compatible with sectoralexclusions
Area Specific category and activity Description
Technologies and products
Products based on renewable resources,
biopolymers and biodegradable
Packaging materials, materials including secondary raw materials (from recycling), biobased products
...
Products from eco-design
Products / technologies based on an eco-design process (ISO 14 062 type) leading to proven
environmental gains
Durability, repairability and reuse of
products
Reconditioned products (such as household appliances), products whose repairability is guaranteed
...
Products/technologies that reduce and
capture greenhouse gas (GHG) emissions
Recovery and valorization of methane from waste storage, methods of agricultural production aimed
at quantifiably and significantly reducing the consumption of fertilizers, technologies related to the
capture and storage of CO2 excluded fossil activities ...
Services Reparation
Economy of functionality
Any model leading to a billing / remuneration directly linked to a service rendered, leading to proven
environmental gains (at least 5% reduction of certain environmental impacts, without aggravation),
particularly in terms of preservation of resources and waste management.
Waste energy valorization
Incineration with level R1 energy capture in
accordance with the European Directive1 or
equivalent
Waste gasification
Gasification systems which use the heat emitted for cooling or heating, and where emission levels are
lower than a specified threshold amount
Existing fossil fuels energy
valorization
Mine gas
Production of electricity/heat from gas from mines that have ceased operations permanently
Waste management
Industrial recycling
Recycled products
Composting
Greenfin label Criteria Guidelines 19 / 32
4. Industry
Area Specific category and activity Description
Energy-efficient products
Manufacturers
Energy-efficient products
Energy-efficiency technological projects
Renewable energy products
Assets Industrial energy efficiency
Energy-efficient processes and
systems
Controlled and monitored compressed air systems
Valve tightening and improvement
Variable speeds; speed control
Insulation of distributed systems
Membrane reuse
Network security
Improvement in HVAC efficiency
Cogeneration/Tri-
generation/Combined Heat
and Power
Cogeneration from renewable energy, bioenergy, renewable gaseous and liquid non-fossil fuels
and liquid non-fossil fuels or geothermal energy
Waste heat recovery
Reduction of GHG not linked
to energy
Fugitive emissions
Reduction of pollution
Activities and technologies reducing
significantly polluting emission in the air, soil
and water, or improving significantly the
environmental quality of the air, water orsoil.
Industrial processes
Improvements in eco-efficiency / cleaner
production
For example, "green cement", cement produced with less clinker; automation comparing one
production technology with another
Services Energy services
Design and realisation of energy-related savings, renovation and risk management projects (of the
EDCS type)
Organic agro-food industry
Food transformation certified in organic
farming
Criteria on the supply in organic products entering the transformation : products in conformity withto
the European regulations relative to organic products and to their labeling or having a bilateral
recognition by non member countries of the European Union or controlled and certified by a third party
recognized and overseen directly by the European Commission.
Greenfin label Criteria Guidelines 20 / 32
5. Transport
Area Specific category and activity Description
Rail transport systems
(merchandise and
passengers)
Operations New developments and improvements
Infrastructure Rail tracks and assets
Manufacturing Non-diesel rolling stock production
Urban rail systems (metro,
tram etc.)
Operations
New developments
Improvements
Manufacturing Non-diesel rolling stock
Infrastructure Rail tracks and assets
Electric vehicles (private car
and fleets)
Infrastructure Charging infrastructure
Manufacturing
Electric-vehicle manufacturers or diversified manufacturers contributing specially to electric-vehicle
manufacturing
Fuel-efficient vehicles (private
cars and fleets)
Infrastructure Charging infrastructure
Manufacturing Hybrids
Alternative fuel vehicles
(private cars and fleets)
Infrastructure Charging infrastructure
Manufacturing Hydrogen, biodiesel, biogas-powered vehicles etc.
Bus with High Level of Service
[BHLS]
Operations
Components of any BHLS project with a Bronze, Silver or Gold BRT (Bus Rapid Transit) standard
(definition given by the Institute of Transportation and Development Policy) or equivalent
Infrastructure
Manufacturing
Maritime transport
Operations Use of electric, hybrid, biofuel, ammonia or hydrogen propulsion to significantly reduce
gCO2e/tonne/km
Infrastructure Shore power
Production or modernization Systems to limit pollution of the marine environment
Bicycle transport
Manufacturing Bicycles and spare parts (including electric bicycles)
Infrastructure
Bicycle infrastructure in cities, financing for bicycle development plans
Biofuels
Inedible feedstock
Minimum GHG savings rate must be specified
Feedstock must comply with international standards dealing with the following cases: land-use,carbon
footprint, food competition issues
Advanced biofuels
For example, gas from anaerobic digestion or from agricultural waste and sewage used to power
heavy-goods vehicles
Aviation biofuel Production and treatment facilities
Technologies dedicated to aviation fuels ? e.g. bio-kerosene production (subject to compliance with
feedstock standards)
Greenfin label Criteria Guidelines 21 / 32
Transport logistics
Systems and technologies that improve the scheduling and efficient movement of rail, river, maritime
or any other passenger or freight transport
6. Information and Communications technologies
Area Specific category and activity Description
Data-centres running on
renewable energies
Approved low carbon sources only, as appear in the classification
Low-carbon infrastructure
Renewable energy powered mobile base station
Products and technologies that
support smart grid applications
Products and technologies demonstrating lifecycle GHG emission savings
Substitution technologies
Conferencing software and centres directly dedicated to the reduction of business travel by air and by
road
Greenfin label Criteria Guidelines 22 / 32
7. Agriculture and forestry
Area Specific category and activity Description
Organic agriculture
Organic agriculture, including seeds and
fertilisers
Sustainable agriculture
The farm or the cooperative must be certified HVE or must respond to at least four of the six criteria
mentioned below. Regarding qualitative criteria, it has to demonstrate concrete actions toward this
objective.
- Maintenance of landscape structures (hedges?),
- Valorisation of organic fertilizers,
- Water savings,
- Reduction of GHG or carbon storage improvement,
- Intermediary consumptions / revenues < 30%,
- Utilised agricultural area not treated with herbicides > 65%.
Forestry activities that:
? Avoid or substantially
reduce carbon emissions
? Substantially sequestrate
carbon
Assets certified by international
standards
Forest plantation and sustainable forest management with internationally recognised certificates (Verified
Carbon Standard, Programme for the Endorsement of Forest Certification Schemes, Forest Stewardship
Council, etc.).
Reforestation and planting on degraded
and non-forested land
Subject to governance criteria and to compliance with international standards which ensure the
sustainability of investments
Replanting and reforestation on
previously forested land
Reducing Emissions from Deforestation
and Forest Degradation (REDD)
Agriculture that:
- Reduces GHG emissions
- Improves the sequestration
of carbon stored in soils
- Improves climate resilience
Reduced water usage Further research required to define the threshold
Verifiable reduction in fertiliser use E.g. fertiliser management system (with NO2 reduction)
No-till farming (verifiable) Reduced emissions or enhanced removal in terrestrial carbon pools
Pasture management (verifiable) Pasture management reducing CH4 emissions
Intensive agriculture efficiencies
E.g. Managing the manure of dairy cows (CH4); processes for milk in order to reduce the transportation
weight of agricultural products, etc.
Intelligent management systems
Infrastructure and methods for the efficient spreading of fertiliser (i.e. reduced NO2) and improved CO2
sequestration. E.g. intelligent machinery, geographical information systems (GIS)
Resilience Infrastructure to provide greater resilience in the face of more severe storms
Greenfin label Criteria Guidelines 23 / 32
8. Adaptation
Area
Specific category
and activity
Description
Water
Efficiency
Technology
Systems improvements ? e.g. for water utilities
Recycling
Infrastructure
improvements
Sufficient extra water capacity to cope with droughts
Efficient water infrastructure, for example with low leakage rates for pipe networks, water conserving fixtures, or grey water
systems, so as to maximize use of scarce water resources
Rooftop capture and storage
Design of water intakes for varying water levels and strengthening to withstand turbulent flows
Construction of reservoir overflows to avoid failures
Resilience infrastructure
Increased dam heights, enlarged floodgates, de-silting of gates and expanded installation capacity to accommodate increased
river flows at hydroelectric power plants; upstream land management to reduce erosion and siltation
Infrastructure
Bridges
Changes to address higher levels of flooding
Higher standards of design and maintenance to accommodate greater thermal expansion on expansion joints and paved
surfaces, and to prevent materials degradation
Rail
Provision for increased thermal expansion, and adapted maintenance procedures, warning systems and management
procedures where buckling of rail track movements might occur
Enhanced design standards for stations, bridges, viaducts, electrified tracks with overhead cables, train platforms, illuminated
signs and panels and other railway infrastructure for expected wind speed increases and heavy rain
Wind fences for railway infrastructure
Circuit breaker protection for overhead lines
Improved air conditioning, cooling and natural ventilation systems for underground tunnels, vehicles and metro stations,
including temperature monitoring, and adequate power supply
Signalling equipment and other electronic systems designed for increased occurrence of lightning strikes
Measures to deal with increased temperatures and heat waves such as large windows, tinted windows to protect from the sun,
white painted roofs, improved thermal insulation; cooling systems and air conditioning (ideally without fluorinated gases)
Vehicles with an improved power supply designed to respond to higher electrical demand (for air conditioning) and with the
capacity to withstand higher wind speeds
Greenfin label Criteria Guidelines 24 / 32
Adaptation
Area
Specific category
and activity
Description
Coastal floods/storm
surges
Infrastructure to protect
against strong rainfall
Greenfin label Criteria Guidelines 25 / 32
Appendix 2 ? Excluded companies *
Companies developing new projects for the exploration, extraction, transportation (of coal, oil or gas), and refining of solid, liquid or gaseous fossil fuels, as well
as new power generation capacity from solid, liquid or gaseous fossil fuels are excluded.
Companies excluded under a strict criterion (5%):
Companies generating more than 5% of their turnover from one of the following activities are excluded from the investment scope of labelled funds. The activities
excluded are:
- The fossil fuel value chain activities listed below:
? Exploration, extraction, refining and production of solid, liquid and gaseous fossil fuel products
? The production of products derived from solid, liquid and gaseous fossil fuels.
? Transport/distribution and storage of solid and liquid fossil fuels
? Energy production as electricity and/or heat, heating and cooling from solid, liquid and gaseous fossil fuels
? Supply of solid and liquid fossil fuels
Companies excluded under a loose criterion (30%):
Companies generating 30% [inclusive] or more of their turnover from one of the following activities are excluded from the investment scope of labelled funds. The activities
excluded are:
? Transport, distribution and storage of gaseous fuels
? Supply services of gaseous fuels
? Storage and landfill centres without GHG capture;
? Incineration without energy recovery;
? Energy efficiency for non-renewable energy sources and energy savings linked to optimising the extraction, transportation and production of electricity from fossil fuels;
? Logging, unless managed in a sustainable fashion as defined in appendix 1, and peatland agriculture.
? The production, transport and distribution/sale of equipment and services to/from customers in strictly excluded sectors (as defined above)
* The share of turnover to be considered is the one in the last published financial year document. Where the share of turnover of the business is unknown or is not representative
(one-off price or volume effect), the audited fund manager may present an estimated share based on physical indicators or historical prices and volumes.
Greenfin label Criteria Guidelines 26 / 32
Appendix 3 - Portfolio allocation thresholds between the various allocation categories
These thresholds define the rules on minimum allocation between three investment "categories", distinguished by the "intensity" of the "green share" of the
turnover of the issuers in which each "category" is invested. The "investment" category corresponds to the portion of the portfolio?s assets under management
invested in type I, II or III companies (see below).
? Type I companies: those in which over 50% of turnover comes from eco-activities, as defined by the chosen taxonomy (see Appendix 1);?
? Type II companies: those in which 10% to 50% excluded of turnover comes from eco-activities;?
? Type III companies: those in which less than 10% of turnover comes from eco-activities.?
Funds invested in unlisted securities
The labelling thresholds for unlisted funds regarding the green dimension are:
At least 75% [inclusive] of assets under management must be invested in Greenfin
companies (companies for which eco-activities represent at least 50% of
turnover).
Diagram of the various company/project company attributes and their anticipated weighting
in a labelled unlisted fund portfolio.
Special case of bond funds
A bond fund must invest at least 75% [inclusive] of its assets under management
in green bonds as defined in criterion 1.2.b. The remaining 25% can be invested
in other bonds or other debt securities provided these are inno way connected
to excluded activities, in accordance with criterion 1.3.
Greenfin label Criteria Guidelines 27 / 32
For funds invested in listed securities
The criteria and labelling thresholds for listed funds concerning the "green share" are, for the first year:
? A category comprising type I issuers, which should represent at least 20% [inclusive] of the portfolio?s assets under management;?
? A category comprising type II issuers, the portion of which, in terms of assets under management, depends on the two other categories;?
? A so-called ?diversification? category, comprising type III issuers or other debt securities, which must represent 25% or less of the portfolio?s assets under
management;?
? In the case of mixed funds incorporating green bonds, as defined in the second eligibility criterion (?Fund Assets?) and in the section regarding green bond
funds under criterion 1.2b) of the Criteria Guidelines, the assets under management pertaining to these bonds shall count against the assets under management
of the first category listed above.?
Diagram of the various issuer attributes and their expected weighting in a labelled listed fund portfolio
Greenfin label Criteria Guidelines 28 / 32
Special cases for OPCIs and SCPIs
Diagram of the OPCI and SPCI pockets in a labelled fund
For RECIS? (OPCIs)
The fund invests at least 60% of its assets under management in green real estate
defined by the criteria guidelines in Appendix 1. The green part is madeup of 100%
real estate assets (buildings, OPCI shares, listed real estate companies,
companies with buildings). The remaining 40% may be invested in other bonds or
other debt securities provided that they do not relate to the excluded activities, in
accordance with criterion 1.3.
For REITs (SCPIs)
The fund invests at least 90% of its assets under management in green real estate
defined by the criteria guidelines in Appendix 1. The green part is made up of
100% real estate assets. The remaining 10% may be invested in other bonds or
other debt securities provided that they do not relate to the excluded activities in
accordance with criterion 1.3.
Greenfin label Criteria Guidelines 29 / 32
Appendix 4 - Information to be submitted regarding environmental impact measurements
The requested information below is accompanied, where appropriate, by indicator verification certificates produced by independent third-party organisations.
For each indicator provided, the fund must give:
? Its coverage in number of issuers and assets under management;?
? Its scope;?
? Its calculation method (indicating the potential changes in method or scope from one year to another);?
? The potential difficulties encountered in its creation and the reasons for which one or more additional indicators are being proposed;?
? An analysis of its trend over the past three years (however, it is accepted that for the first two years for which a fund is certified the indicators will only respectively concern the
year N, then N and N-1).?
For at least one reporting field, the fund must define its actual performance through the production of at least one of the indicators proposed below and through the comparison,
where appropriate, with the reference index, if one exists. The production of additional indicators, related where appropriate to an activity unit, which would be considered more
relevant, is encouraged.
Reporting
field
Objectives Suggested indicators
Climate
change
Measure the GHG emissions of investments
or
Ensure that portfolio composition is compatible with the "+2°C"
scenarios.
- Statement of scope 1 and 2 GHG standardised emissions + Tier one suppliers and products sold (annual tCO2eq, or other
GHGs if applicable) proportionally to turnover (tCO2eq/EUR million or USD million of turnover). If data for scope 3
emissions is not available, one will focus on scope 1 and 2 emissions to begin with;
- CO2 emissions avoided (in tonnes/year);
- Compatible with "+2° C" climate performance indicator.
Water
Reduce water consumption while maintaining its quality level
- Total water consumption equal to the total measured volume of withdrawn water less the total volume of discharge (liquids,
steam). It includes water which is also a raw material in products or manufacturing and conditioning processes. The results
can be provided in relation to an activity unit;
- Volume of reused water from collected and treated used water, in relation to, where appropriate, an activity unit.
Natural
resources
Preserve natural resources
- Consumption of natural resources including critical resources (t/EUR million or USD million of turnover);
- Share of renewable energies in the energy mix;
- Production of raw materials from recycling.
Biodiversity
Preserve the biodiversity of ecosystems
- Percentage of issuers disclosing their expenditure on biodiversity / number of companies represented in the portfolio;
- Average expenditure of issuers committed to biodiversity, compared to turnover.
- Land conversion area of all portfolio activities (specify type of conversion, eg grassland -> artificialization, or other);
- Surface rehabilitation and restoration of soil outside the regulatory obligations related to the sequence "avoid, reduce,
compensate?.
Greenfin label Criteria Guidelines 30 / 32
For bonds as for equities, the use of derivative instruments is permitted but under certain conditions. These derivative instruments are used as a supplement
to a portfolio invested in "Energy and Ecological Transition for the Climate" compliant securities.
Fund management entails two components:
? The selection of the securities in the portfolio,?
? The construction of the portfolio (management of the life of the fund).
Derivative instruments are primarily used to construct the portfolio.?
1. Bonds
For fixed income fund management, the use of derivatives does not respond to an investment logic but to a technical objective: the portfolio is invested in fixed-
income products that are screened as Greenfin compliant, then the fund managers use derivative instruments to adjust the portfolio (either temporarily orto fine
tune the duration of the fixed-income portfolio). Insofar as this concerns instruments for financial adjustment, derivatives on organised markets (futures contracts
and options) may be used in coherence with the fund?s policy. Regarding over-the-counter instruments, the fund manager must analyse the Greenfinquality of
the counterparties.
The bond portfolio (cash + derivatives) should not seek a net short position in fixed-income risk or in credit risk.
2. Equities
? Use of derivatives for hedging: this must be authorised in accordance with the fund?s policy on ?Energy and Ecological Transition for the Climate?. There must
be no conflict with the Greenfin nature of the fund. The portfolio is still invested in Greenfin screened securities but performance takes account of equitymarket
risk neutralisation.?
? Use of derivatives for exposure: use for exposure must only take place on a temporary basis. The fund?s reporting and the supplements potentially provided
must allow each management company to explain how it is proceeding and in particular to demonstrate the temporary nature of the use of derivatives for
exposure. Additionally:?
? Exposure to a security or to an index may be possible, notably in order to respond to a strong movement of liabilities (subscriptions or redemptions);
? In the case of a security, the underlying instrument should be Greenfin-compliant;
? In the case of an index, provisional exposure to the fund?s reference index may be possible, even when this index is not Greenfi n.
Using derivatives to sell short non-Greenfin securities (for example, naked put on non-Greenfin securities) is improper.
Finally, regarding over-the-counter instruments, the fund manager must analyse the Greenfin quality of the counterparties.
In order to show that the fund?s practices regarding derivatives comply with the present requirements, the fund must provide a technical document on the use
of derivatives which presents:
? For interest rate and credit derivatives, the interest rate and credit sensitivities (cash + derivatives) for the past three net asset values;?
? For equity derivative, the list of derivative transactions over the past three months, with an indication of the strategy followed for each transaction (hedging,
anticipated movement of liabilities, other exposure);?
? For over-the-counter derivatives, the Greenfinf analysis carried out on all of the counterparties used over the last 12 months.?
Appendix 5 - Requirements for the use of derivative instruments within the framework of a
Greenfin fund
Greenfin label Criteria Guidelines 31 / 32
Appendix 6 ? List of documents to submit
? The fund?s Prospectus, Key Investor Information Document and investment regulation (for funds in formation);?
? Marketing material, reporting (the most recent) and management report;?
? Itemised portfolio statement in accordance with the requirements set out in criterion 1.2 (excluding funds of funds);?
? For funds of funds only, the portfolio statement in accordance with the requirements set out in eligibility criterion III;?
? Summary document addressing the information requirements of criteria 1, 2.1, 3.1 and 3.2;?
? Technical document on the use of derivative instruments;?
? Technical document on the rotation rate.?