
Purpose and scope
This Policy describes how the MWC Group integrates environmental, social and governance (ESG) considerations into our advisory, insurance and wealth‑planning activities across the group. Local addenda may supplement this Policy where laws or regulators require.
Principles
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Fiduciary duty first. Client objectives, risk tolerance and constraints drive all recommendations.
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Materiality‑led ESG. We consider financially material sustainability risks and opportunities that could affect long‑term outcomes.
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Client preference alignment. Where clients express sustainability preferences (including EU/UK labels), we reflect them in product selection and portfolio construction.
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Evidence over ideology. We use data from multiple providers, recognising limitations and inconsistencies, and we avoid box‑ticking.
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Stewardship through selection and engagement. We prioritise managers and products that demonstrate robust stewardship and transparency.
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Proportionality. ESG integration is tailored to mandate type, product universe and data availability.
Implementation
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Advice process. We assess how sustainability risks could impact returns and suitability; we document client sustainability preferences where relevant (e.g., SFDR Article 8/9 product selection in the EU).
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Product due diligence. We review managers’ ESG policies, governance, data sources, exclusions/tilts, stewardship records and disclosures.
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Portfolio construction. For ESG‑aware or sustainable mandates, we apply client‑aligned exclusions/tilts and prefer managers with credible frameworks; for standard mandates we integrate financially material ESG risks alongside other risks.
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Monitoring. We periodically reassess products/managers for ESG policy drift, controversies, and data quality; we escalate concerns and may recommend changes.
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Conflicts & incentives. Our remuneration and conflict controls (see Legal Library) are designed not to create incentives that would prioritise ESG labels over client outcomes.
Limitations and data quality
ESG data can be incomplete, lagging or inconsistent across providers and geographies. We use more than one source where practical, apply judgment, and explain trade‑offs to clients.
Governance
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Responsibility. The Group Investment/Advice leadership owns this Policy; local compliance oversees regulatory alignment.
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Training. Advisers receive periodic training on sustainability risk integration and local regulatory requirements.
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Review. This Policy is reviewed at least annually or when regulation or our business materially changes.
Contact
Questions: DPO@mwcgroup.ch.