Following the conclusion of the SFC’s consultation on the proposed amendments to the Fund Manager Code of Conduct (“FMCC”) in August 2021, fund managers are required take climate-related risks into consideration in their investment and risk management processes and make appropriate disclosure. In order to determine the scope and applicability, fund managers will have to assess the relevance and materiality of climate related risks to the funds as well as to assess whether they are responsible for the overall operation of funds. Requirements cover Governance, Investment Management, Risk Management and Disclosure.

Large Fund Managers with AUM of HK$8 billion or above are required to comply with the baseline requirement by 20 August 2022 and the enhanced standards by 20 November 2022. Other fund managers have to comply with the baseline requirements by 20 November 2022. The new requirement will only apply to Collective Investment Scheme but not discretionary account.

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