Case — APG-AM | Dealing room

Get SFDR sorted in terms of data, framework and systems.

APG is one of the world’s largest pension investors, with offices in Heerlen, Amsterdam, New York and Hong Kong. End of 2024, the assets that APG manages for its pension funds and its 4.6 million participants (through its independent Asset Management unit) represented a value of approximately 616 billion euros. To manage its assets as responsibly as possible, APG aims to achieve attractive and sustainable investment returns for its customers.

What was the problem?
The Sustainable Finance Disclosure Regulation (SFDR) imposes mandatory Environmental, Social and Governance (ESG) disclosure obligations for asset managers and other financial markets participants with substantive provisions of the regulation. APG-AM wished to gain insight into the (disclosure) obligations on entity and product level and map out the gap between its current market data landscape and the ESG data necessary to be SFDR compliant.

Why did APG-AM ask for Varrlyn’s help?
Varrlyn contributes to APG-AM’s market and stakeholder engagement at 3 levels:

  1. Disclose obligations on an entity level. Varrlyn helped APG-AM to enrich its remuneration policies with information on how those policies are consistent with the integration of sustainability risks.
  2. Disclose obligations on a product level. Varrlyn helped integrate sustainability risks into APG-AM’s investments and assess the likely impacts of sustainability risks on the returns of APG-AM’s financial products.
  3. Varrlyn helped APG-AM gain information on its ESG data coverage.

How did APG-AM benefit from Varrlyn’s help?
In terms of framework, system and data, APG-AM got its SFDR requirements sorted: it was ready for the Level 1 disclosers. The baseline that Varrlyn helped create allowed APG-AM to start preparing the Level 2 disclosures.

Acount manager Martin Defauwes & Philip van den Emster