SFDR rules

REGULATION (EU) 2019/2088 OF 27 NOVEMBER 2019 ON THE PUBLICATION OF SUSTAINABILITY INFORMATION IN THE FINANCIAL SERVICES SECTOR (SFDR REGULATION)

As a portfolio management company duly authorised by the Autorité des Marchés Financiers to manage Alternative Investment Funds and provide investment advice, STAM France Investment Managers SAS is subject to the provisions of the SFDR Regulation.

From 10 March 2021, in accordance with Article 3 of these Regulations, financial market operators shall publish on their websites information about their policies for integrating sustainability risks into their investment decision-making process. These risks refer to any environmental, social or governance event or situation which, if it occurred, could have a significant actual or potential negative impact on the value of the investment.

The Organismes Professionnels de Placement Collectif Immobilier managed by STAM France Investment Managers SAS do not promote environmental and/or social characteristics and do not have sustainable investment as their objective, within the meaning of articles 8 and 9 of the SFDR Regulation.

STAM France Investment Managers SAS nevertheless considers environmental and social characteristics to be a source of information that complements financial criteria in the investment process. Consideration is therefore being given to the integration of sustainability risks into the management company’s investment decision-making process.

The management company does not take into account the main negative impacts in terms of sustainability, but it intends to carry out a review with a view to integrating a methodology for assessing the impact of its property investment decisions on sustainability factors, i.e. environmental, social and personnel issues, respect for human rights and the fight against corruption and bribery.

INTEGRATION OF SUSTAINABILITY RISKS INTO THE REMUNERATION POLICY

In accordance with regulatory requirements, STAM France Investment Managers has defined and applies a remuneration policy that promotes sound and effective risk management. It is determined in such a way as to avoid situations of conflict of interest and to prevent reckless risk-taking or risk-taking that is incompatible with the interests of clients.

The remuneration policy is reviewed annually and takes into account the general organisational and operational requirements of STAM France Investment Managers, as well as the nature, scope and complexity of its activities.

STAM France Investment Managers has included objectives relating to ESG issues among the professional objectives set for employees, thereby encouraging their commitment and the creation of a synergy in the collection, management and reliability of ESG data.