Responsible Investment Policy

The Company carries out its investment management activities with the objective of creating value for the projects in which it invests on behalf of the AIFs managed, for the AIFS’ investors, and for all stakeholders.  Responsibility, sustainability and integrity of the value-enhancing actions implemented by the Company are key elements in the value creation process.In this context, the Company believes that such aspects must be considered, together with traditional financial measures, to provide a more complete view of the value, risk and return potential of investments. Promoting these principles also helps to reduce risk and increase the value of investments in the pursuit of sustainable performance over time. 

Integrating ESG criteria into the strategy can generate sustainable profits over time and, consequently, generate a solid prospect of value creation for all stakeholders. This also enables a more efficient management of risks - financial, environmental and social - which can negatively affect the value creation of the single investment.

The Company is committed to supporting the Sustainable Development Goals, promoted by the UN and adheres to the principles and guidelines defined for responsible investments by the United Nations - Principles for Responsible Investments (PRI)

The Sustainable Development Goals (SDGs) are the cornerstone of the "2030 Agenda" and address the most important economic, social, environmental, and governance challenges. The successful implementation of the UN Sustainable Development Goals requires that the actions of all market players support the pursuit of these objectives. 

Prelios SGR's commitment to contribute to the Sustainable Development Goals is realized through responsible business policies, integration of business models, investments, innovation and collaboration with all stakeholders involved in the value creation process. The Company focuses on supporting some specific objectives according to the direct and indirect impact of the actions pursued.

Furthermore, Prelios SGR actively participates in CSR and ESG initiatives promoted by Confindustria Assoimmobiliare and, in general, by the industry to which it belongs in order to contribute to the dissemination and consolidation of sustainable practices in all areas in which it operates.

Prelios SGR's Responsible Investment Policy is drafted in accordance with Regulation 2019/2088 (SFDR), art. 3, and aims to illustrate the selection and monitoring methodologies adopted by the Company in order to integrate the analysis of sustainability risks within the investment process related to AIF management services.

Environmental engagement

Environmental engagement concerns the impact the Company has on living and non-living natural systems, including ecosystems. Such matter includes the monitoring of environmental inputs (such as materials, energy, water) and outputs (such as emissions, effluents, waste), as well as performance related to biodiversity, environmental compliance, environmental spending, and the impact of products and services provided.

Environmental impact management is crucial to assess the investments made and managed by the Company. In addition to complying with applicable environmental laws and regulations, Prelios SGR aims to promote environmental awareness and knowledge, and to keep on continuously improving in environmental management and performance, including the review of short- and long-term environmental performance targets.

Direct environmental impact

Reducing the Company’s environmental footprint

As a financial institution, Prelios SGR's direct environmental impact is relatively limited. However, the Company aims to continuously reduce its environmental footprint. .

Actions implemented

• striving to reduce the direct negative impact of the Company’s activities on the environment; 
• being efficient in the use of resources and using renewable or recyclable materials; and 
• minimizing and recycling waste.

Indirect environmental impact

Investment decisions and how investments are managed

The greatest impact the Company, as an asset management company, has on the environment is indirect, through the investment decisions and how the investments made are managed.

Actions implemented:

• working with position statements and industry policies, focusing on sustainable business opportunities and risk mitigation; 
• continually improving investment and risk assessment procedures by further developing environmental and social considerations; 
• seeking environmental-friendly investment opportunities;
• taking into account the environmental performance of suppliers and contractors, as well as the environmental impact of products and services in the procurement process; and involving the suppliers in the application of sustainability policies.

Diversity, equity and inclusion

Prelios SGR, in line with the Group's policies, promotes diversity in all its forms in order to make the most of its opportunities and create value within the workplace.

In line with the 2030 Agenda for Sustainable Development Goals No. 5 (Gender Equality) and No. 10 (Reducing Inequalities), Prelios SGR and the Group recognize and embrace the value of the principles of diversity, equity and inclusion ("DE&I") as an integral part of its culture, values and business activities. In particular, Prelios SGR and the Group are committed to upholding the values of diversity and inclusion through the adoption of business, organizational and management processes marked by respect for people's rights and freedoms. The terms “Diversity”, “Equity” and “Inclusion” refer to:

• Diversity: means all the ways in which we differ. It includes differences such as gender, age, ethnicity, physical appearance, different abilities and nationality, as well as thinking styles, religion, affective-sexual orientation, gender identity, political and trade union views, health status, cultural background and family status
• Equity: means the adoption of unbiased practices and policies that ensure all people fair opportunities for enhancement and development
• Inclusion: means creating a working environment and culture in which all differences are valued and respected. Everyone has the opportunity to learn, develop, contribute and achieve in the workplace.

Prelios SGR operates in an impartial and fair manner and does not tolerate any form of direct or indirect, multiple and interconnected discrimination based on gender, age, affective-sexual orientation and gender identity, conditions of different abilities, medical condition, ethnic origin, nationality, political and trade union opinions, social category or religious faith. It also promotes conditions that enable the elimination of cultural, organisational and material barriers that limit people's full participation and full potential within the organisation.

ESG factors in the investment strategy and reporting

Integrating sustainability aspects affects all phases of investment process

The integration of ESG factors into the investment process is done through the implementation of:

• the ESG due diligence check-list to identify and manage ESG risks in individual assets as part of the ordinary investment process. The check-list can be integrated and/or modified to take into consideration the peculiarities of each investment, also possibly through the use of questionnaires. The results of the ESG analysis with any possible improvement actions are brought to the attention of the SGR Board of Directors; 
• quantitative tools for calculating and monitoring the ESG performance of the products, differentiated according to whether the AIF has an explicit ESG strategy or not; 
• specific Risk Management tools for the integration of ESG factors in the risk assessment criteria of individual investments. The Company has adopted an internal methodology in order to assess the sustainability risk for all managed AIFs which provides for the calculation of a total scoring risk calculated taking into account the environmental, social and governance aspects, in line with the reference legislation in force. The Risk Management analyses are presented to the Company's Board of Directors at least once a year.

Focus ESG performance

For all AIFs ESG performance is assessed by means of a specific assessment tool, developed internally, based on the 8 indicators and also possibly through the use of questionnaires. For each indicator a weighted percentage score is attributed corresponding to the cluster to which it belongs (i.e. high, medium-high, medium-low, weak/absent). The single AIF is then assigned a final percentage score determined by the average of the scores attributed to each indicator.

For AIFs with an explicit ESG strategy 

additional criteria and tools are adopted for the identification, implementation and monitoring of specific ESG performance objectives and results.

These activities can also be carried out with the support of specially appointed advisors.

Whether consistent with the ESG strategy of each individual AIF, considerations regarding sustainability will be integrated with the assessment of investments’ alignment to relevant requirements set out in Regulation (EU) 2020/852 ("Taxonomy EU") and its regulatory technical standards.

ESG performance monitoring and measurement activities are carried out at least once a year and the results, together with an overview of the ESG strategy implemented and the strategic action plan in terms of sustainability, are submitted to the Board of Directors of the SGR, and possibly to the Investors, where applicable, according to the procedures contained in the relevant Management Rules/By-Laws.

Measuring ESG impact

Prelios SGR measures the impact of its investments through a proprietary analysis tool based on the following ESG criteria

Governance of the Responsible Investment process

Each function and/or department manager is responsible for consistent implementation of the guidelines in the performance of activities

Chief Executive Officer (CEO)

Implements the SGR policies regarding sustainability and risk management system, with particular reference to implementation of AIFs management policies in accordance with the strategies and plans approved by the Company's Board of Directors.

Head of Sustainability (HoS)

Appointed by the BoD and reporting directly to the CEO, is responsible for the process of integrating sustainability principles regarding the Company and the managed AIFs, proposing ESG strategies also in the structuring of products and the action plan for the implementation of strategic decisions

Fund Management (FM)

• with the support of the HoS, identifies ESG objectives of the investments of managed AIFs;
• is responsible for the implementation of the related strategies and the monitoring of the results achieved at AIF level.

Asset & Development Management, Acquisition and Special Situations

Supports the Fund Management structure in identifying and monitoring the main ESG levers for the assets managed

Risk Management department

Has developed a methodology for the analysis of Sustainability Risks relating to the AIFs under management. The Risk Management analyses are presented to the Company's Board of Directors at least once a year

Sustainable Finance Committee (SFC)

Has advisory and propositional tasks vis-à-vis the BoD and the CEO, in the analysis and integration of ESG issues in the Company's decision-making processes. In particular:

Engagement and stewardship

The Company actively promotes engagement policies aimed at raising awareness of all stakeholders with respect to sustainability issues

The Company actively promotes both internally and externally engagement policies aimed at raising stakeholders' awareness of sustainability-related issues, with a view to positively influencing behaviour and increasing the degree of transparency of its own sector. 

Moreover, through an ongoing dialogue with the Target Companies on issues related to sustainability and through the exercise of the voting rights associated with the equity investment, the Company aims to positively influence the conduct of the Target Companies and increase the degree of transparency.

As regards private equity AIFs, engagement aims to increase the awareness of the management of the Target Companies towards a constant and lasting commitment to improving good governance practices and respect for environmental and social principles. The engagement approach is customized according to the investment policy of the individual private equity AIF, as well as the characteristics of the Target Companies. In defining the engagement strategy of each AIF, the following will be defined, inter alia:

• the objectives of the engagement;
• the tools and methods for implementing and monitoring engagement activities in order to pursue the objectives of engagement;
• planning of collaborative dialogue with Target Companies and other stakeholders (e.g. written communications, meetings with management, participation in shareholders' meetings, etc.);
• the possible adoption of a specific ESG Action Plan for the Target Companies.

Consistently with the investment policies of each individual private equity AIF, following the ESG due diligence process, the SGR will be able to evaluate the adoption of a specific ESG Action Plan, in order to improve the ESG performance of the Target Companies. The ESG Action Plan can be substantiated, for example, through:

• prompt identification of any situations that may generate a sustainability risk and identification of appropriate corrective measures;
• definition of the relevant target KPIs, as well as the methods of data collection aimed at assessing and monitoring ESG performance;
• implementation of sustainability policies or strengthening of any sustainability measures already provided for by the policies in force at the Target Companies.

Finally, the Company actively participates in CSR and ESG initiatives promoted by the industry to which it belongs in order to contribute to the diffusion and consolidation of sustainable practices in all the areas in which it operates.