Sustainability-related Disclosures

The following disclosures relate to CEE Kapitalverwaltungsgesellschaft mbH in its role as a financial market participant pursuant to Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability-related disclosure requirements in the financial services sector (“EU Disclosure Regulation”).

Background

The EU published the so-called EU Disclosure Regulation on 27 November 2019. The objective of this Regulation is, in particular, to reduce information asymmetries in the relationships between clients and agents with regard to the inclusion of sustainability risks, the consideration of adverse sustainability impacts, the promotion of environmental or social features and, in regard to sustainable investments, by obliging financial market participants and financial advisors to provide pre-contractual information and ongoing disclosures to end-investors when acting as agents on behalf of those end-investors (clients). This is mainly done against the background that the transition to a low-carbon, more sustainable, resource-efficient circular economy in line with the Sustainable Development Goals is considered one of the key issues for ensuring the long-term competitiveness of the Union’s economy. This is in line with the Paris Agreement concluded under the United Nations Framework Convention on Climate Change (“Paris Agreement”), which was approved by the Union on 5 October 2016 and entered into force on 4 November 2016.  The Paris Agreement aims to act more decisively against climate change by, among other things, aligning financial flows with a pathway towards low greenhouse gas emissions and climate resilience.

Information pursuant to Art. 3 (1) and (2) of Regulation (EU) 2019/2088

Invest in a sustainable and future-oriented manner – that is our claim. By investing in the development and generation of renewable energies, we not only achieve attractive returns for our investors, but also sustainably secure our future. Our goal is to accompany and shape the expansion of the market for renewable energies in the long term.

As an investment manager and operator of long-term renewable energy projects, we are committed to achieving risk-adequate returns that are in line with our investors’ objectives. We are convinced that the integration of ESG criteria has a real, positive impact on our environment as well as our business environment and thus on our actions.

CEE Kapitalverwaltungsgesellschaft mbH also takes into account corresponding sustainability risks as part of its investment decision-making processes, i.e. such events or conditions in the environmental, social or corporate governance areas that could have a significant negative impact on the value of an investment if they were to occur.

The review of sustainability risks is based on the respective investment strategy of the mandates as well as the type of assets to be acquired and is carried out on the basis of qualitative and/or quantitative factors. The results – as part of the risk assessment – together with the results of the other due diligence checks (including legal, technical and commercial) are included in the overall assessment of the project. Our asset managers accompany the projects right from the start of the due diligence process. This ensures a seamless transition from the acquisition to the operational running of the projects and thus also the direct integration into the operational risk processes.

The corresponding requirements are documented within the framework of the internal ESG, risk and asset management guidelines as well as further process descriptions.

In addition, the company has internal guidelines and requirements (in particular anti-corruption guidelines, code of conduct and ethics and employee remuneration guidelines) to take sustainability factors into account in our actions and activities as a financial market participant.

Information pursuant to Art. 4 and Art. 7 of Regulation (EU) 2019/2088

Significant adverse effects on sustainability factors are considered as part of the investment decisions and the underlying due diligence processes.

In this context, the audit includes qualitative and quantitative assessment criteria relating to the areas of energy, water and wastewater management, the handling of residual materials, potential climate risks as well as risk factors in the areas of ecology, human rights, occupational safety and corporate governance.

Information in accordance with Article 7 of Regulation (EU) 2019/2088 in relation to the financial products managed by the company is provided in the pre-contractual information. The timing and scope of the respective disclosures depend on the respective product category and classification in relation to Regulation (EU) 2019/2088.

Information pursuant to Art. 5 of Regulation (EU) 2019/2088

The company is subject to the regulatory requirements applicable to capital management companies with regard to the design of its remuneration system. The documentation takes place within the framework of a corresponding remuneration guideline. The supervisory board of the company is responsible for the adoption and maintenance of the remuneration policy and oversees its implementation by the executive board.

In doing so, the remuneration policy is designed not to encourage disproportionate risk-taking – especially in comparison to the investment policy of a mandate.

The remuneration includes both fixed and variable components. In the determination of variable remuneration components, the achievement of sustainable business development, the protection of society as well as the protection of the mandates managed and investors, also in relation to relevant ESG factors, are also taken into account in the assessment when determining target achievement as part of the personal performance assessment.

Information pursuant to Art. 6 of Regulation (EU) 2019/2088

Information in accordance with Article 6 of Regulation (EU) 2019/2088 in relation to the financial products managed by the company is provided in the pre-contractual information. The timing and scope of the respective disclosures depend on the respective product category and classification in relation to Regulation (EU) 2019/2088.