Sustainability-related Disclosures

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.