In compliance with EU Regulation 2019/2088 (“SFDR”) relating to sustainability disclosures in the financial services sector, Europa Risorse SGR S.p.A. (hereinafter also the “SGR”) publishes the required regulatory information below.
Art. 3 – Transparency of policies regarding sustainability risk
By providing the collective savings management service, the SGR, in the interest of its stakeholders, makes choices aimed at creating sustainable value (in environmental, social and governance terms) and lasting growth in the medium and long term, in order to produce a positive impact in the context in which it operates.
The SGR is convinced that attention to environmental and social aspects, in addition to promoting sustainable economic development, also contributes positively to financial results, making them sustainable in the medium and long term, while reducing the riskiness of investments.
The SGR has oriented its approach by taking inspiration, among other things, from the Sustainable Development Goals (“SDGs”), approved in 2015 by the United Nations, contributing to 6 of the 17 SDGs particularly relevant to real estate activities and for which the work of the SGR, through its business, can provide an active contribution to achieving them.
In this context, the SGR has integrated its governance, equipping itself with a Sustainability Policy and the figure of the Sustainability Manager.
The SGR’s sustainable approach to investments is achieved through the integration of ESG principles to decision-making processes, including:
- For new investments in core assets, already profitable and/or which do not require substantial redevelopment interventions, selection of properties with high energy efficiency performance, already certified and/or for which it is possible to enhance this aspect over a defined time horizon;
- In the case of new real estate developments and/or assets that require substantial redevelopment or reconversion interventions, the so-called brown-field approach is favored and the insertion of the intervention in an urban redevelopment context, also considering the environmental and territorial impacts connected to the specific location and evaluating the impacts from an economic and social point of view while respecting both the reference context and the urban and historical value;
- In general, good environmental and social practices promoted by international sustainability standards (such as LEED®, WELL®, Wired Score®, etc.) are taken into consideration and the possibility of obtaining the aforementioned certifications compatible with the purposes is evaluated. and the extent of investments;
- In general, the areas of investigation of technical, environmental and legal due diligence are integrated with sustainability issues, orienting the analysis towards the identification and evaluation of the related risks and the definition of opportunities for improvement and valorisation from an ESG perspective.
Furthermore, when selecting new investments, the SGR excludes a priori real estate assets with the following characteristics:
- Real estate developments in protected natural areas;
- Real estate developments with negative impacts on cultural heritage;
- Real estate developments intended for the extraction and production of fossil fuels.
With regards to the selection of tenants to whom the real estate assets under management will be leased, the SGR adopts an exclusion criterion based on the activity carried out by the tenant.
In particular, the exclusion concerns companies linked to the production and/or marketing and/or related to:
- Pornographic material and prostitution;
- Weapons banned by international treaties.
Furthermore, the SGR reserves the right to evaluate the ESG profile of the tenants, in order to proceed with the exclusion of further activities carried out and/or specific companies.
The risk management policy was also modified in order to map, monitor and manage ESG issues.
Article 4, paragraph 1, letter. b), of Regulation (EU) 2019/2088 “SFDR” and Article 12 of Delegated Regulation (EU) 2022/1288)
The Company communicates that although, in general, it takes into consideration the main negative effects on sustainability factors in its investment decisions, it currently does not take into consideration the negative effects of investment decisions on sustainability factors.
Europa Risorse SGR S.p.A. (hereinafter also the “SGR” or the “Company”) publishes this communication in compliance with the provisions of article 4 of Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 so-called SFDR (Sustainable Finance Disclosure Regulation) on ESG (Environmental, Social and Governance) sustainability factors and the provisions of the Delegated Regulation (EU) 2022/1288.
The SFDR Regulation requires the SGR to publish the ways in which it takes into account the potential negative effects of its investment decisions on ESG sustainability factors or, alternatively, reasons for the impossibility of considering such impacts.
The Company, in compliance with art. 4 SFDR, co. 1, letter. b) and art. 12 of the Delegated Regulation (EU) 2022/1288, does not currently take into consideration the main negative effects of its investment decisions on sustainability factors (so-called PAI), in consideration of the limited availability of reliable and structured data.
The SGR, although not basing the identification of investments on the basis of consideration of the PAI, has adopted investment selection criteria which take into account, however, the level of sustainability does not exclude, in the future, also including the evaluation in this process of the negative effects on sustainability factors.
In this regard, activities are underway aimed at adequately collecting the necessary information in order to process data on the indicators of negative effects on sustainability as defined in Annex I “Declaration form of the main negative effects on sustainability” of the Delegated Regulation (EU) 2022/1288.
Art. 5 – Transparency of remuneration policies in relation to the integration of sustainability risks
The SGR has a staff remuneration policy at all levels which, as of today, does not provide any compensation of a variable nature, but limits itself to granting staff, including key personnel, exclusively a fixed remuneration.
Should the SGR decide in the future to recognise any form of variable remuneration, it will be structured in accordance with regulatory provisions, including the SFDR.
