The Management Entity is a management company of CIUs subject to Portuguese law.
With the objective of disclosing the commitments established and the approach taken regarding responsible investment, in accordance with sustainability criteria approved at the European level, the Management Entity has adopted this sustainability policy.
This Policy therefore aims to comply with the current regulatory framework and, in particular, with Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019, as currently in force (disclosure of sustainability-related information in the financial services sector or “SFDR”), adapted to the context of real estate, securities, and venture capital CIUs.
It should be noted that, at present, the Management Entity does not manage CIUs that promote environmental or social characteristics (products under Article 8 of the SFDR) or that aim to make sustainable investments (products under Article 9 of the SFDR).
It is the responsibility of the Management Entity to identify and monitor not only the more traditional risks (such as market, credit, liquidity, operational risks, among others) that may impact the value of investments, but also the aforementioned sustainability risks that may equally impact them.
The Management Entity embraces the requirements arising from the sustainability framework in terms adapted to the CIUs under management, according to their characteristics described in the respective constitutive documents.
The Management Entity assesses sustainability risks in light of the nature, size, and complexity of its activities.
The Management Entity does not meet the criteria that define large institutions as provided in paragraphs 3 and 4 of Article 4 of the SFDR.
The Management Entity recognizes that information disclosed on sustainability must be truthful, clear, and objective.
The Management Entity acts to prevent distortions in sustainability-related information, namely so-called “greenwashing.”
On the contrary, its approach to sustainability follows the principles of truth, integrity, and transparency.
The Management Entity implements mechanisms to provide information on its sustainability performance to its shareholders, participants/shareholders of the CIUs under management, and supervisory authorities.
The Management Entity’s commitment to sustainability takes into account its integration within the community in which it operates and a sense of accountability to all relevant stakeholders.
The Management Entity undertakes to keep the information regarding this Policy and its compliance up to date.
The Management Entity’s marketing communications may not contradict the information disclosed under this Policy.
Given that the sustainability regulatory framework is not watertight and is constantly evolving, the Management Entity undertakes to continuously consider, in light of the regulatory instruments in force at any given time, the sustainability principles it pursues, and considering the nature, size, and complexity of its activities, the best way to adapt to sustainability requirements.
The Management Entity will comply with the investment policy established for each of the CIUs under its management, seeking in this context to reflect its sustainability concerns.
The Management Entity recognizes that the management of CIUs entails environmental and social risks at the level of the investments made.
Accordingly, in defining its risk management policies and procedures, the Management Entity duly considers sustainability risks which, under the SFDR, consist of environmental, social, or governance (ESG) events or conditions, the occurrence of which could cause a significant actual or potential negative impact on the value of the investment.
Particularly relevant for this purpose are ecological impact, exposure to fossil fuels, or the energy efficiency of real estate projects, among others.
The decision-making process of the Management Entity in terms of investments is guided by the general principles referred to above, which are applied throughout the various stages of the decision-making process:
– Screening: In the process of identifying potential investment opportunities, based on publicly available information and/or third-party sources, including specialized service providers, exposure to sustainability risks will also be considered. As an auxiliary element, lists of sectors more or less exposed to such risks may be drawn up and updated from time to time.
– Investment Analysis: The information collected in the previous phase will be complemented, whenever appropriate, with additional information, namely from the target company itself, to more accurately assess the existence of such risks.
– Due Diligence: Whenever appropriate, due diligence processes, when conducted in collaboration with external consultants, should take such risks into account in the analyses carried out and suggest mitigation measures.
– Investment Decision: The information collected and analyzed in the previous phases, regarding sustainability risks, must be taken into account in the decisions to be made, including the implementation of appropriate mitigation measures if such risks are identified, such as through shareholder engagement with the target company.
– Portfolio Monitoring: Among the matters subject to regular monitoring throughout the duration of the investments, sustainability risks will be considered whenever relevant, and their respective mitigation measures will be reviewed, when appropriate.
Accordingly, the impact of these risks on the value and return of investments should be assessed on a case-by-case basis and, to that extent, integrated into the Management Entity’s investment decision-making process.
At present, the Management Entity does not have financial products that promote or pursue sustainable investment objectives under Articles 8 and 9 of the SFDR.
The Management Entity monitors the issue of sustainability in order to assess if and how the CIUs under its management may be qualified as sustainable, under the SFDR.
The Management Entity does not consider the adverse impacts of investment decisions on sustainability factors and does not meet the requirements of large financial market participants as provided in paragraphs 3 and 4 of Article 4 of the SFDR.
Without prejudice to its diligent and prudent conduct under the mandates assigned to it in accordance with the management regulations, the Management Entity does not take into account the adverse impacts of investment decisions on sustainability factors for the following reasons:
– It does not manage CIUs falling within the scope of Article 8, nor Article 9 of the SFDR.
– The underlying investments of the CIUs under management do not take into account the European Union criteria applicable to environmentally sustainable economic activities.
– Considering the type of investments made by our CIUs and the level of publicly available information on ESG, in particular regarding the indicators listed in Annex I of Commission Delegated Regulation (EU) 2022/1288 of 6 April 2022, such information is insufficient, which prevents a reasonable and adequate consideration of the adverse impacts of investment decisions on sustainability factors based on that information.
– Given the lack of sufficient public information sources in this area, the consideration of adverse impacts of investment decisions on sustainability factors would require obtaining such information externally, whether through service providers or investee companies, but even through these means, it is anticipated that in many cases the available information would be insufficient, considering the companies in which investments are typically made.
Thus, not only would this process entail excessive and disproportionate costs for the Management Entity, its CIUs, and its clients/investors, but it would also fail to ensure the necessary outcome for the effective consideration of such adverse impacts.
Should the circumstances described above change in the future, the Management Entity may reconsider this matter and, in such case, will inform its investors and other stakeholders in a timely and appropriate manner of any change, although it is not possible at this time to anticipate a specific date for such effect.
(For more information, please refer to the Portuguese version of this document.)