Website ESG Disclosures in accordance with SFDR
Last revised on August 29th, 2023
In the Property Technology world, AMAVI acts as a pioneer with a mission to revolutionize the real estate and construction sector, infusing it with innovation & digitization in order to increase (1) the efficiency and (2) the sustainability of the industry. On top of that, our commitment to societal obligations, encompassing environmental, social, and governance (ESG) concerns, is unwavering. The shift towards a more eco-conscious, resilient, and resource-effective economy holds implications for all economic players, including the entities within our investment portfolio. Our investment choices are driven by a keen awareness of sustainability dimensions, recognizing that embracing these factors extends beyond fostering a more sustainable economy and society. We firmly believe that overlooking sustainability aspects would be a disservice to prudent investment practices.
AMAVI, in its capacity of alternative investment fund manager (‘AIFM’), is subject to the disclosure obligations relating to environmental, social and governance (“ESG”) matters as set forth in:
- Regulation (EU) no. 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability-related disclosures in the financial services sector (“SFDR”);
- Commission Delegated Regulation (EU) 2022/1288 supplementing Regulation (EU) 2019/2088 of the European Parliament and of the Council with regard to regulatory technical standards specifying the details of the content and presentation of the information in relation to the principle of ‘do no significant harm’, specifying the content, methodologies and presentation of information in relation to sustainability indicators and adverse sustainability impacts, and the content and presentation of the information in relation to the promotion of environmental or social characteristics and sustainable investment objectives in precontractual documents, on websites and in periodic reports (“RTS”); and
- Regulation (EU) 2020/852 of the European Parliament and of the Council of 18 June 2020 on the establishment of a framework to facilitate sustainable investment, and amending Regulation (EU) 2019/2088 (“TR”).
AMAVI reserves the right to modify this information at any time, and will in such event publish a clarification on such amendment on this website.1. Sustainability risk policies
As currently AMAVI neither (i) promotes environmental or social characteristics, (ii) nor has sustainable investments as its sole purpose, we do not formally integrate an assessment of sustainability risks in our decision making process in accordance with article 3 of the SFDR. Having said that, we firmly believe that prudent investment practices that prioritize responsibility and minimize exposure to sustainability risks will augment the value of our investment endeavours. Certain events or circumstances linked to environmental, social, and governance (ESG) considerations possess the potential to adversely affect the value of our investments.
In light of this, we seamlessly incorporate an evaluation of sustainability risks into our decision-making framework when evaluating potential investments. We counteract these risks by meticulously handpicking potential entities for our investment portfolio, as well as thoughtfully considering the sectors in which they operate. Furthermore, our long-term investment approach within our portfolio entities empowers us to potentially influence their practices and policies related to sustainability, thereby reducing sustainability risks associated with our investments.
Moreover, when contemplating new prospective investments in portfolio entities, we exercise careful judgement and conduct comprehensive due diligence research on the entities in question. This exercise encompasses various aspects, with a particular focus on the entities’ adherence to relevant regulations, including those pertaining to ESG considerations. The conclusions drawn from our due diligence findings and the assessment of the entities’ alignment with (ESG) regulations play a pivotal role in our investment decision-making process.
Operating as an engaged investor, we actively pursue representation within the governance structures of the entities within our portfolio. Over the duration of our investment commitments, we diligently oversee the entities’ adherence to (ESG) regulations and human rights standards. Finally, we encourage our portfolio entities to embark on initiatives aimed at curbing carbon emissions, fostering a more sustainable and resource-efficient circular economy, and cultivating greater diversity.
2. No consideration of adverse sustainability impacts of investment decisions
At AMAVI, we embrace the profound influence that our investment choices and the endeavours of our portfolio entities can have over sustainability considerations. Yet, it’s important to note that, under Article 4 of the SFDR, we presently do not factor in the unfavourable repercussions of our investment decisions on sustainability aspects.
We wish to clarify the rationale underpinning this resolution, reflecting our dedication to transparency. Given our status as a compact organization operating with finite resources and personnel, we confront notable obstacles in accurately gauging the adverse effects of our investment choices according to the multifaceted criteria included in the SFDR and its implementing regulations. Moreover, our focus on investing in small and medium-sized entities, constrained by their dimensions and resource limitations, renders them incapable of furnishing the exhaustive data necessary for such an evaluation.
We grasp the significance of sustainability and the imperative of addressing unfavourable consequences. Although we are presently unable to fulfil the prerequisites of the SFDR, our commitment to progress endures. We are devoted in our pursuit of ways to elevate our sustainability practices, all while operating within the confines of our available resources and capabilities.
3. Integration of sustainability risks into remuneration policies
As a sub-threshold manager of alternative investment funds, AMAVI does not have an obligation to have a formal remuneration policy in accordance with article 40 and following of the Belgian law of 19 April 2014 on alternative entities for collective investments and their managers. Consequently, sustainability risks are not integrated in the remuneration policy.