Information from Raiffeisen Capital Management on the implementation of the ESMA guideline on fund names that use ESG or sustainability-related terms

From 21 May 2025, the new guideline of the European Securities and Markets Authority (ESMA) for the use of ESG or sustainability-related names for investment funds will apply. For the first time, this guideline sets out Europe-wide requirements for the conditions under which a fund name may contain sustainability-related terms and words such as environment, social and governance. The requirements apply to all EU-regulated funds, including specialised funds (alternative investment funds - AIFs). The aim is to ensure greater clarity and transparency for investors. The guideline regulates - with an environmental reference in the fund name - in particular the negative criteria in accordance with the EU regulation for Paris-aligned benchmarks (PABs), which means, among other things, that investments in companies that generate a certain proportion of their turnover from fossil fuels are not allowed. Fossil fuels are thus severely restricted by the EU Naming Directive, but not completely excluded. In addition, funds with the key term "sustainable" in their name must invest "significantly" in sustainable investments.

In accordance with regulatory requirements, Raiffeisen Capital Management has applied to the Austrian Financial Market Authority to amend the fund rules of all funds affected by the guideline and still classified as Article 8 under the Disclosure Regulation by 21 May 2025. In this context, Raiffeisen Capital Management is setting an example and will already bring forward ESMA-compliant investment by clarifying the prospectuses of the affected funds. There are currently no securities in the affected funds that contravene the ESMA guidelines (with the exception of a few non-tradable positions).

The following Raiffeisen Capital Management funds are particularly affected by the aforementioned prospectus amendments and the content requirements of the ESMA Naming Guideline:

• Райфайзен-ESG-Глобален-Облигации (R) VTA

• Райфайзен-Азия-Възможности-ESG-Aкции (R) VTA

• Райфайзен-Устойчив-Микс (R) VTA

• Райфайзен-Устойчив-Моментум (R) VTA

• Райфайзен-Устойчив-НововъзникващиПазари в-Акции (R) VTA

• Райфайзен-Устойчиви-Акции (R) VTA

• Райфайзен-Централноевропейски ESG Акции (R) VTA

Please note that some funds have special (“fund-specific”) notices (e.g., regarding higher price fluctuations, master feeder or umbrella fund structures). These can be found for each fund in the product sheet at www.rcm.at/fondsuebersicht

Raiffeisen Capital Management stands for Raiffeisen KAG.