Legal and regulatory

Quilter International Ireland dac is required to prepare and publish a Solvency and Financial Condition Report (SFCR) each year for the Irish Regulator under the Solvency II regulations. This report details the financial position of the organisation and will enable a comparison with other life assurance firms’ financial positions. Read the Solvency and Financial condition report here.

Under EU and Ireland rules we provide certain disclosures regarding our Irish insurance business, where investment is being made in shares traded on a regulated market. Quilter International Ireland dac (Quilter International) is the product provider for our range of portfolio bonds.

Within these products customers are able to select from a wide range of funds, equities, bonds, and exchange-traded instruments, as permitted by the relevant product.

Quilter International does not have its own investment strategy per se; instead it invests in line with the instructions received from its customers.

A: Shareholder engagement policy

The portfolio bond products, made available by Quilter International, are ‘open-architecture’ insurance-based investment products which enable customers to select the assets to which the returns of their policies can be linked.

Subject to product specific restrictions, the available range of exchange-traded instruments may include:

• Equities
• Investment Trusts
• Exchange Traded Funds
• Exchange Traded Commodities

The nature of the ‘open-architecture’ portfolio bond products Quilter International makes available is such that the customer has the ability to determine their own investment strategy and select the assets to which the returns of their policies can be linked. Quilter International does not:

• have an investment strategy;
• actively monitor investee companies;
• usually have dialogue with investee companies;
• usually exercise voting rights;
• usually consider the voting position of other companies within the Utmost group of companies;
• usually contact customers with details of generic investment notifications, although it will usually notify customers of corporate actions where there is action required to be taken;
• usually vote on fund events and corporate actions where there is a direct connection to the Utmost group of companies, where there are actual or potential conflicts of interests.

B: Investment strategy and arrangements with asset managers

Also under the EU and Ireland rules we are required to provide the following public disclosures regarding our arrangements with asset managers:

The nature of the ‘open-architecture’ portfolio bond products Quilter International makes available, is such that the customer has the option to determine their own investment strategy and select the assets to which the returns of their policies can be linked. The customer can request the appointment of an asset manager to select and manage the assets on their behalf. In such arrangements, the asset manager will manage the assets in accordance with the customer’s investment strategy, time horizon, and any relevant parameters. The asset manager is incentivised to grow the value of the assets being managed as their sole remuneration is obtained from the fees charged for providing these services, which is deducted from the customer’s policy. Quilter International does not monitor portfolio turnover costs. The arrangements with the asset manager will continue until such time as is determined by the customer.

The above statements will be reviewed on an annual basis and updated in the event of any material changes.

Regulation (EU) 2019/2088
No consideration of sustainability adverse impacts

Under EU rules we are required to provide sustainability risk disclosures regarding investment decisions related to Quilter International Ireland dac (Quilter International) and the products which we make available.

Sustainability Risk is defined as an environmental, social or governance event or condition that, if it occurs, could cause an actual or a potential material negative impact on the value of the investment.

Transparency of Sustainability Risk Policies

The portfolio bond products made available by Quilter International are primarily ‘open-architecture’ insurance-based investment products which enable customers and their fund adviser, or appointed discretionary asset manager (where relevant) to select the assets to which the returns of their policies can be linked.

Quilter International does not have an overarching investment strategy, nor does it determine how and where investments are to be made; instead it invests in line with the instructions received from its customers and their fund advisers, or the discretionary asset manager (where appointed). Consequently, Quilter International does not have a prescribed policy in relation to the integration of sustainability risks in the investment decision-making process.

Transparency of Adverse Sustainability Impacts at Entity Level

For the reasons set out above, each customer with the help of their fund adviser, or the discretionary asset manager (where appointed) can select the assets to which the returns of their policies can be linked. The requirement to consider adverse impacts of investment decisions on sustainability factors is therefore not relevant to Quilter International.

Transparency of Remuneration Policies in Relation to the Integration of Sustainability Risks

To the extent that the Quilter International Remuneration Policy is relevant in the context of the portfolio bond products which it makes available, it is consistent with it, and promotes sound and effective enterprise risk management, including risks related to conducting responsible business and adapting to regulatory change.

The above statements will be reviewed on an annual basis and updated in the event of any material changes.