SUSTAINABLE INVESTMENTS
An investment is sustainable if it makes a significant contribution to achieving environmental and/or social purposes
(such as the use of renewable energy or the promotion of social integration), as provided
for by Regulation (EU) 2019/2088 of the European Parliament (Articles 3, 4, 5) and of the Council
of 27 November 2019 (the "SFDR").
The sgr adopts a comply approach, and therefore integrates sustainability risks into investment decisions at both the corporate and financial product level, through the application of negative exclusion criteria and positive selection criteria in accordance with the Sustainable Investment Policy published on this page.
SFDR ASPECTS
The regulation defines how information must be disclosed in relation to various aspects and stages of the investment process. Near sgr integrates sustainability considerations into investment decisions at different operational levels. The SFDR governs sustainability disclosure in the financial services sector, of which Near sgr is part in its capacity as an AIF manager. The regulation defines how information must be disclosed in relation to various aspects and stages of the investment process.
Integration of sustainability risks at corporate and financial product level (Art. 3, 6)
Principal Adverse Impact at corporate and financial product level (Art. 4, 7)
Remuneration policies and integration of sustainability risks (Art. 5)
Products promoting environmental and social characteristics, pre-contractual and periodic disclosure (Art. 8, 11)
Sustainable investments, pre-contractual and periodic disclosure (Art. 9, 11)
Sustainability disclosure via web (Art. 10)
Review of information (Art. 12)
Near SGR integrates sustainability considerations into investment decisions at different operational levels, both on behalf of the SGR and for the AIFs it manages, pursuant to EU Regulation 2088/2019:
- on the policy for integrating sustainability risks and opportunities adopted by Near sgr in investment decision-making processes (Art. 3 SFDR);
- where the Sgr takes into account the principal adverse impacts of investment decisions on sustainability factors (Art. 4 SFDR);
- on the integration of sustainability risks and opportunities into the remuneration policy (Art. 5 SFDR).
Art. 3 SFDR
The Company has adopted the Sustainable Investment Policy, in the awareness that environmental, social and governance (ESG) factors represent not only risks but genuine opportunities to achieve the impacts essential to pursuing the common benefit purposes that Near sgr, as a Benefit Company, inherently embodies.
Art. 4 e 7 SFDR
With regard to the required transparency on adverse sustainability impacts (PAI: Principal Adverse Impact) at both entity and financial product level, the Company applies the requirements set out in Commission Delegated Regulation (EU) 2022/1288 (the “RTS”), which supplements Regulation (EU) 2019/2088 of the European Parliament and of the Council with regard to the technical standards for applying the “do no significant harm” (DNSH) principle.
Art. 5 SFDR
The Shareholders’ Meeting has approved the Sgr’s Staff Remuneration and Incentive Policy which, including through the incentive plan, integrates sustainability risks in pursuit of social and environmental performance targets.
The Policy is designed to incentivise the achievement of annual and multi-year purposes, as outlined in the medium-to-long-term strategy, and to contribute to the creation of shared value for the Company and its shareholders, as well as for all stakeholders. In particular, Near sgr’s sustainability strategy aims to create value through, among other things, the integration of the SDGs and relevant ESG factors within the scope of the SGR’s activities and the AIFs it manages.
In greater detail, Near sgr has shaped its business strategy in line with its social impact vocation, pursuing real estate initiatives that contribute to increasing the supply of social housing (affordable housing), in the urban regeneration sector with social impact and/or content, in compliance with environmental sustainability, so as to create value for its various stakeholders, and in particular:
social value, through the promotion of inclusion grounded in social cohesion, social integration, and investment in human capital or in economically or socially disadvantaged communities;
environmental value, by promoting decarbonisation, the use of renewable energy and a positive impact on biodiversity and the circular economy, including through the responsible use of raw materials, water resources and land, alongside the reduction of waste production and greenhouse gas emissions.
In this context, both short-term and medium-to-long-term strategic purposes underpinning the incentive schemes are directly linked to the purposes described above.
SUSTAINABLE INVESTMENT POLICY
The Policy defines, at sgr level, the general rules for sustainability management, with particular reference to the process of integrating sustainability risks and opportunities. The Policy formalises, among other things, Near sgr’s approach to the regulatory requirements of the SFDR, adopting a “comply” approach.
SUSTAINABLE INVESTMENT POLICY 2025
risks
As part of its business activities, Near sgr drafts, implements and keeps updated a Risk Management Policy that enables the identification of all relevant risks to which the AIFs are or may be exposed.
The Policy includes a description of the instruments and procedures required to enable the Sgr to assess, for each AIF it manages, exposure to market, liquidity, credit, counterparty and sustainability risks, as well as exposure to any other relevant risk, including operational risk, that could have a significant impact on fund management. In 2023, the Policy was revised to incorporate an updated Fund Risk Assessment model, with the introduction of the Tenant Profile and Climate Risk indicators, designed to assess, for the assets held in the real estate portfolios of the AIFs managed by the Sgr, the risk arising from physical and transition risk, as well as from the progress of construction works.
Minimum safeguards
To meet the minimum safeguard criterion, Near sgr operates in compliance with corporate ethical standards and principles, in line with the adopted Model 231 Management and Code of Ethics. In this regard, alignment with the OECD Guidelines and the United Nations Guiding Principles on Business and Human Rights is ensured through negative ESG screening, that is, by excluding investments in activities and/or counterparties involved in controversial sectors. Near sgr has also been an active member of the United Nations Global Compact since May 2021, committing to operate in accordance with its 10 Global Compact Principles, which encompass, among other things, respect for universally recognised human rights, workers’ rights and the fight against corruption in all its forms, including extortion and bribery, as outlined below. To this end, Redo adopts an anti-money laundering (AML) verification procedure that, among other things, protects the Company from risks arising from unlawful conduct by counterparties.