ESG Sustainability Policy
Carregosa - Sociedade Gestora de Organismos de Investimento Coletivo, S.A. ("Management Company" or "Carregosa SGOIC") is a management company of collective investmentfunds, subject to the Portuguese law, whose activity is the management of real estate investment funds.
In order to disclose the commitments established and the approach in terms of responsible investment at the level of the Management Company and the real estate investment funds managed (the "Funds"), Carregosa SGOIC adopted an Environmental, Social and Governance Sustainability Policy (hereinafter the "Policy") that describes how it integrates Environmental, Social and Governance (ESG) factors and the framework of these criteria in its investment strategy.
In drafting the Policy, the Management Company complies with the legal and regulatory framework in force and observes, in particular, the provisions of Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 (on the disclosure of sustainability-related information in the financial services sector, referred to as SFDR - "Sustainability Finance Disclosure Regulation"), SFDR – “Sustainability Finance Disclosure Regulation”), with due suitability to the needs and challenges of the management activity of real estate investment undertakings.
The provisions of this Policy apply to the Management Company and the real estate investment funds under its management.
Currently, Carregosa SGOIC does not provide management services for real estate investment funds that promote, among others, environmental or social features (provided for in Article 8 of the SFDR) or that aim at sustainable investments (referred to in Article 9 of the SFDR).
The Management Company recognizes the importance of the issue of sustainability and ESG factors and understands the particularities of the management activity of real estate investment funds.
Carregosa SGOIC understands, therefore, that the development of its activity guided by the principles arising from this Policy is integrated in the duty to protect the interests of the Investors of the real estate investment undertakings under its management.
This understanding translates, on the one hand, into a guideline in the identification and interpretation of risks underlying the investments to be made and, on the other, in the increase of investment opportunities and the creation of long-term value for its Investors.
The mission and values of the Management Company are aligned with the valuation of investment criteria and sustainable decisions, in particular through the creation of value and active management by maximizing the binomial profitability/risk, the latter being, in this context, considered in its sustainability risk aspect.
Carregosa SGOIC is committed to including sustainability, social and governance criteria in the development of its activity, publicly binding itself to the principles of action contained in this Policy.
The ESG factors are considered within the scope of the management of the real estate investment entities and duly adapted according to their characteristics, described in the respective constitutional documents.
The Management Company admits, however, that the legal and regulatory framework relating to the integration of ESG factors is not (yet) complete and global, determining some fragmentation and asymmetry in the information accessible to potential investors.
In the European Union, for example, there are several ongoing regulatory reforms on the topic of ESG sustainability. In its turn, outside the European Union, there are no mandatory legal provisions comparable to those in force at the European level.
Added to this reality is the fact that the relevant specificities of the management activity of real estate investment funds are not sufficiently covered by the SFDR Regulation. the SFDR.
Nevertheless, Carregosa SGOIC adopts a responsible and aware stance of its role as Management Company and therefore weighs the risks in terms of sustainability and in relation to ESG factors, considering the nature, scale and complexity of its activity.
The information disclosed by Carregosa SGOIC on ESG matters must be truthful, transparent and objective.
The Management Company does not accept or allow distortions and/or exaggerations in the disclosure and contextualization of data, avoiding at all costs the risk of "green-washing", which occurs when an entity invests its resources in marketing actionsgreen-washing”, que sucede quando uma entidade investe os seus recursos em ações de marketing, in particular so that the general public associates it with sustainable practices instead of creating effective procedures for minimizing the negative environmental impacts of its activity.
Carregosa SGOIC makes sure that the approach on ESG matters and corresponding information are current, consistent and guided according to principles of truth and integrity.
Carregosa SGOIC is committed to incorporating sustainable practices in its day-to-day internal management and within the real estate investment undertakings that it manages.
The Management Company therefore aims to incorporate responsible solutions in ESG matters, allowing a continuous and balanced development in the use of resources, seeking to avoid its waste as far as possible.
a. Identification and definition of priorities with respect to the main negative impacts and sustainability indicators
The ESG objectives to which the Management Company pays special attention when making investment decisions, without prejudice to the specificities of the investment policy of each managed real estate investment undertaking, are as follows:
- At the environmental level - by adapting to climate change, preventing and controlling pollution and supporting the transition to a circular economy;
- At the social level - by ensuring equity, safety and health at work;
- In regards to governance - by ensuring effective internal control procedures in the fight against money laundering and terrorism financing, data and privacy protection, and ensuring the legality and compliance of investment decisions.
The investment policy is developed in the management regulations of each real estate investment entity. Whilst fully respecting the legal and self-imposed limits of the constitutive documents of the Funds, the Management Company will give preference, whenever possible and appropriate, to investments and current management decisions that incorporate ESG factors.
As an example, if a property of a Fund has to be valued, it will be preferable, whenever feasible, to contract this service to an expert valuer who is close to the location of the asset, in order to reduce the emissions of pollutant gases caused by the expert's travel to the site.
Another example would be to consider the implementation of solar panels or other mechanisms that enhance the energeticefficiency of a building, increasing the value of the property and benefiting the local community environmentally.
These, like other initiatives of this kind, allow Carregosa SGOIC to integrate ESG factors in investment decisions.
The Board of Directors is responsible for approving and reviewing this Policy and for implementing investment and day-to-day management decisions of the Management Company and the Funds under its management. Thus, Carregosa SGOIC ensures the full integration of the contents of this document in its governance system.
Carregosa SGOIC seeks to accommodate sustainability risks by including them in the reflection on an investment of the Management Company or of each of the real estate investment undertakings under its management.
The Management Company will also create procedures to measure and mitigate sustainability risks to facilitate the integration of these criteria in the investment decision-making process.
The assessment of negative impacts of investment decisions on sustainability, social and governance matters will be carried out through due diligence, data collection and processing.
However, we emphasize the difficulty of a rigorous and measurable assessment of these impacts in the generality of real estate investment decisions, due to the scarcity of guidelines applicable to the mentioned activity.
It is thus admitted the existence of situations in which the Management Company will not be able to measure the negative impacts of investment decisions on sustainability factors, this obstacle not being prohibitive to the consideration of ESG factors in the taking of investment decisions and current management.
The Board of Directors appoints at least one ESG Officer with an advisory role in the Management Company on this issue, which may be cumulative with other positions held.
The ESG Officer supports the Board of Directors in the following tasks:
i. Defining and implementing the Management Company's strategy on ESG matters;
ii. Monitoring compliance with this Policy;
iii. Definition of the concrete procedures in execution of this Policy;
iv. Monitoring the implications of the Management Company's activity in terms of ESG;
v. Collecting and disclosing information on ESG factors;
vi. Disseminating good practices and fostering an internal culture aligned with ESG criteria.
Recognizing that the management activity of real estate investment funds is impacted by risks of an environmental, social or governance nature, Carregosa SGOIC includes sustainability risks in the risk matrices of the Management Company and each Fund under its management.
Also in the definition, approval and implementation of policies, procedures and risk management mechanisms, the Management Company considers the possible environmental, social or governance events or conditions whose occurrence may significantly affect the value of the real estate assets that at each moment are part of the portfolio of the real estate investment funds.
Based on the available information, the Management Company weighs the risks relating to events of an environmental, social or governance nature with an impact on the investments made in the short, medium and long term.
Risk identification, assessment and management functions are performed within the framework of the organization system of the Managing Company, which is the responsibility of the Risk Management department.
Internal and external risk management reports prepared by the Management Company include, whenever possible, the analysis of risks arising from environmental, social or governance events.
The Management Company includes ESG factors in its Remuneration Policy, submitted to the Supervisory Board and approved by the General Meeting. The general principles of the Remuneration Policy ensure, in turn, a governance system that ensures effective compliance with best practices in this area.
Carregosa SGOIC understands the Remuneration Policy as a central instrument to ensure the conditions necessary for the implementation of a fair, equitable and apt to attract, retain and motivate the managers and employees.
b. Balanced setting of remuneration structures and alignment with the long-term interests of the Company
Carregosa SGOIC adopts a remuneration strategy that allows the identification of factors, including ESG, relevant to its activity and compatible with its interest and long-term business vision.
Having identified the key metrics associated with remuneration, the Management Company carries out a weighting of objectives and benefits that ensure the balance, efficiency and diversity of its team.
c. Subjecting the remuneration structures to prudent risk management, particularly with regard to sustainability
The Remuneration Policy of Carregosa SGOIC contemplates remuneration structures that optimize financial results and promote sustainable development.
The Management Company also includes in its Remuneration Policy factors that mitigate possible risks to the development of the management activity of real estate investment entities.
The Management Company publishes the legal and relevant information to which it is obliged under applicable and current law.
Em conformidade com o disposto no Regulamento (UE) 2019/2088 do Parlamento Europeu e do Conselho de 27 de novembro de 2019 relativo à divulgação de informações relacionadas com a sustentabilidade no setor dos serviços financeiros, a Carregosa SGOIC procederá, assim que possível, à divulgação da (i) informação sobre as suas políticas relativas à identificação e definição de prioridades no que se refere aos principais impactos negativos e indicadores em matéria de sustentabilidade; e da (ii) descrição dos principais impactos negativos em matéria de sustentabilidade e das medidas planeadas
The Company integrates environmental, social and governing risks into its risk analysis processes when making investment decisions. To this end, it incorporates internal policies and related procedures in the CIUs’ wallet management, identifying and describing the main negative impacts in matters of sustainability through, namely, the following indicators:
- Regarding the climate and the environment, such as pollution, soil use and ecology, biodiversity, water and waste;
- Regarding the social and labor questions, the health and the well-being, the respect for human rights and the fight against corruption and bribery;
- Regarding the investments in sovereign and supranational organizations;
- Regarding the investments in real estate assets and its energetic efficiency.
Carregosa SGOIC monitors and orientates its action by responsible corporate codes of conduct and internationally acknowledged standards on due diligence and reporting, such as the Paris Agreement.
The Company will also be alerted to European legislative and regulatory changes, monitoring the development of technical criteria and rules to adopt.
It will also procure studies carried out by service providers specialized in the real estate segment, which will allow reputable and independent evaluation of the assets, identifying risks and opportunities and comparing the level of performance with that of its pairs and leading to the implementation of customized solutions. This measure will also make it possible to obtain transparent and comparable information and adopt corporate reporting practices based on robust financial and non-financial data, including environmental, social and governance indicators.
Esta informação foi atualizada a 21 de julho de 2023.
Declaração sobre a não consideração dos impactos negativos das decisões de investimento sobre os fatores de sustentabilidade
O Regulamento (UE) 2019/2088 do Parlamento Europeu e do Conselho, de 27 de novembro de 2019, relativo à divulgação de informações relacionadas com a sustentabilidade no setor dos serviços financeiros (“SFDR”), estabelece, no seu artigo 4.º, a obrigação de publicação e atualização, pelos intervenientes no mercado financeiro, nos seus sítios web, de uma declaração sobre as políticas de diligência devida relativamente a esses impactos, atendendo devidamente à sua dimensão, natureza, escala e aos tipos de produtos financeiros que disponibilizam ou, em caso de não consideração dos impactos negativos das decisões de investimento sobre os fatores de sustentabilidade, a exposição dos motivos claros para tal, incluindo, se aplicável, as informações sobre se e quando tencionam ter em conta esses impactos negativos.
A Carregosa SGOIC acompanha atentamente a evolução do quadro normativo em matéria de sustentabilidade e assume o compromisso de incorporação de práticas sustentáveis na sua gestão interna corrente e no âmbito dos organismos de investimento coletivo que gere.
No entanto, não considera os impactos negativos das decisões de investimento sobre os fatores de sustentabilidade pelos seguintes motivos:
– O enquadramento legal e regulatório relativo à consideração dos fatores de sustentabilidade não é ainda suficientemente claro, nomeadamente no que se refere a critérios de mensuração de alguns dos indicadores constantes do Anexo I do Regulamento Delegado (UE) 2022/1288 da Comissão, de 6 de abril de 2022 (“RD SFDR”), dificultando a produção de informação transparente e fidedigna;
– Os organismos de investimento coletivo geridos pela Carregosa SGOIC enquadram-se no art.º 7.º do Regulamento (UE) 2020/852 do Parlamento Europeu e do Conselho de 18 de junho de 2020 relativo ao estabelecimento de um regime para a promoção do investimento sustentável (“Regulamento da Taxonomia”);
– A Carregosa SGOIC tem a obrigação de cumprir as Políticas de Investimento dos organismos de investimento coletivo sob sua gestão, compreendendo que a proporcionalidade e racionalidade dos custos são dimensões que não pode deixar de acautelar e optando, atualmente, pela realização gradual de investimentos relacionados com a sustentabilidade.
Sem prejuízo do acima exposto, a Carregosa SGOIC reafirma a intenção de continuar a integrar os fatores de sustentabilidade na tomada de decisões de investimento e ponderará a consideração dos impactos negativos das decisões de investimento sobre os fatores de sustentabilidade assim que as circunstâncias suprarreferidas se encontrem ultrapassadas e tal se demonstre exequível.