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C. Voluntary ESG Disclosure Requirements

1. VARA may issue non-binding Guidance setting out “best practice standards” regarding the conduct of specified VASPs or classes of VASPs in respect of ESG issues. Such “best practice standards” could include considerations of sustainability that are consistent with such Entities’ investment management strategies [if applicable], and diversity and inclusion practices within a VASP.
2. VASPs who comply with the Voluntary ESG Disclosure requirements understand that any compliance with the Guidance issued in accordance with Rule V.C.1 of this Company Rulebook is voluntary, though encouraged. However, VARA may require relevant VASPs to provide transparency into their ESG practices on a Compliance ESG Disclosure basis.