SFDR- Sustainable Finance Disclosure Regulation

Transparency of sustainability risk policies

Sustainability risk is defined as an event or condition of an environmental, social or governance type that, should it occur, could cause a significant negative impact on the value of the investment. Fabrica Immobiliare SGR intends to comply with the global framework for sustainable development defined by the United Nations General Assembly by directing its investment choices towards sustainable development objectives.

Consistent with this vision of integration of ESG issues within the management of the SGR and the investment portfolio, in 2020 Fabrica has embarked on a path to strengthen its commitment to sustainability also through the participation of some managed funds in the Global Real Estate Sustainability Benchmark (GRESB): a global standard for benchmarking and reporting on ESG aspects for real estate companies, funds, developers and investors operating directly in the real estate sector.

Fabrica, in line with the main national and international reference standards, is committed to considering, where possible, ESG principles in its investment choices in order to try to direct these choices towards assessments that also take into account environmental, social and governance criteria, in line with the most up-to-date regulatory requirements. This process is reflected in the modus operandi of the SGR in the management of FIAs, with reference to Social Impact Real Estate Investing Funds characterized by a strong social value such as Social Housing, Student Housing and Nursing Homes.

Fabrica Immobiliare SGR considers the integration of ESG factors in its investment process to be of fundamental importance in the conviction that these elements, as well as encouraging sustainable economic and social development, can make a positive contribution to the financial results of clients’ portfolios while reducing risk.

Fabrica undertakes to constantly develop its overall framework in the ESG sphere, according to the evolutions that will affect its business processes, as well as the investments that will be made. In particular, the Company undertakes:

• for all managed AIFs, to assess ESG performance through a specific set of qualitative and quantitative indicators that will be implemented soon;
• for the AIFs whose management regulations or by-laws provide for an explicit ESG strategy, to adopt further criteria and instruments for the identification, implementation and specific monitoring, as regards both objectives and results of ESG performance.

The results of the monitoring of individual AIFs will also be illustrated to Investors, where applicable, in accordance with the information procedures set out in the management rules of the relevant AIF.

Fabrica sets out its responsible investment strategy in the document “Sustainability Policy“, published in the “Sustainability” section of this website; please refer to this document for further details on how to integrate sustainability risks into investment decisions.

Statement regarding failure to consider adverse effects on sustainability factors

The Company, in compliance with Article 4 of EU Regulation 2019/2088 (“SFDR”) on sustainability disclosure in the financial services industry, has decided to adopt a “explain” approach to the consideration of the main negative effects of its investment decisions on ESG (Environment, Social, Governance) sustainability factors.

The Company informs that although, as a general rule, it takes into account the main negative effects on sustainability factors in its investment decisions, at present it is not able to provide the information referred to in art. 4, paragraph 1, letter a), of the SFDR, as detailed in art. 4, paragraph 2, of the SFDR. This is due to the fact that, at present, it has not been possible to identify, prioritise and, therefore, objectively measure the main negative effects of its investment decisions on sustainability factors (i.e. environmental, social and personnel issues, respect for human rights and issues relating to the fight against active and passive corruption), given the lack of precise indicators and metrics by means of which to verify the degree of probability of their occurrence as well as their intensity and possible irremediable nature.

The Company maintains a proactive approach in defining the indicators and metrics with which to determine the above-mentioned negative impacts, also monitoring the evolution of the reference regulatory provisions. The SGR will be responsible for providing timely updates on this aspect.

Transparency of remuneration and incentive policies in relation to the integration of sustainability risks

Fabrica’s Remuneration Policy is a fundamental tool in support of the SGR’s medium and long-term strategies and is designed with the aim of:

• create value over time and pursue sustainable growth for shareholders, staff and investors;
• attract, motivate and retain staff, creating a sense of identity and developing a culture linked to performance and merit;
• promote sound and effective risk management and discourage risk-taking that is inconsistent with the risk profiles and regulations of the managed AIFs and the SGR;
• assigning staff, where necessary, specific objectives that are consistent with the objectives, values and interests of the Company and the investors of the AIFs it manages, and in any case providing for measures to avoid conflicts of interest.

Fabrica is committed to ensuring that ESG aspects are taken into account by its personnel through the adoption of an incentive system that also links remuneration to sustainability objectives. Fabrica believes that these objectives can have a positive influence on the achievement of its strategic objectives and for this reason it incentivizes their achievement by providing for the future implementation of sustainability parameters and/or objectives to which variable remuneration is linked.

last update: March 10th 2021