Sustainable Finance Disclosure Regulation ASR Dutch Farmland Fund

In this SFDR statement we explain our approach to sustainability and how we have embedded sustainability in our strategy and in our investment decisions and thus adhere to the EU Sustainable Finance Disclosure Regulation (SFDR).

The ASR Dutch Farmland Fund (ASR DFLF) is a financial product that promotes environmental characteristics within the meaning of Article 8(1) of Regulation (EU) 2019/2088 on sustainability‐related disclosures in the financial services sector (SFDR). A description of the type of investment strategy used to attain the environmental characteristics promoted by the Fund is set forth further on in this statement.

Pursuant to Article 4(1)(b) of the SFDR, the ASR DFLF hereby states that at present it does not yet consider adverse impacts of its investment decisions on sustainability factors, because the regulatory technical standards as referred to in Article 4(6) and (7) of the SFDR concerning the content, methodologies and presentation of such disclosures have not yet been adopted by the European Commission. The ASR DFLF will reconsider whether to make disclosures on the adverse impacts of its investment decisions on sustainability factors in the manner set forth in Article 4(1)(a) of the SFDR once these regulatory technical standards have been adopted.

Sustainability policies

The ASR DFLF is managed by a.s.r. real estate which is part of the a.s.r. group headed by ASR Nederland N.V. ASR Nederland N.V. has group-wide sustainability, remuneration, tax and procurement policies. a.s.r. real estate applies these policies, also with a view to sustainable business operations. The remuneration policy https://www.asrnl.com/about-asr/governance-and-organization/policy-and-guidelines/remuneration-policy sets out how this policy is aligned with the integration of sustainability risks policy.

a.s.r. real estate has drawn up a corporate social responsibility (CSR) policy. This policy applies to all funds managed by the Management Company, including the ASR DFLF. The CSR policy of a.s.r. real estate comprises criteria, standards and procedures on different ESG (Environmental, Social and Governance) topics and aims to control and mitigate sustainability risks that could have an actual or potential material negative impact on the value of the investment. The CSR objectives are evaluated yearly in the CSR annual reports. The CSR policies are updated every year.

Additionally, the ASR DFLF has its own CSR policy, in line with the aforementioned a.s.r. real estate CSR policy, which sets out its specific sustainability objectives. This policy is also published on the website of a.s.r. real estate. The ASR DFLF’s vision of Corporate Social Responsibility (CSR) is to accommodate the interests of tenants and investors in the best possible way by creating and maintaining assets that have long-term value from both a financial and a social perspective, and to achieve this in a sound and responsible manner with engaged and aware partners and employees. To work towards these goals, each year the Fund develops a strategic Corporate Social Responsibility (CSR) policy around the following themes:

  • Sustainable productivity
  • Sustainable income
  • Resilience to climate change
  • Reducing greenhouse gas emissions
  • Partners: sustainable partners in long-term relationships
  • People: sound business practices and healthy and satisfied employees

While each theme focuses on a specific aspect of CSR, all aspects must work in tandem in order for the Fund to achieve its vision. Each theme has its own strategic objectives, which will be reported on to provide insight into progress made. The ASR DFLF does not use a benchmark to compare the results to those of its peers.

The following strategic objectives are taken into account in the management of the portfolio:

ASR DFLF CSR Objectives 2021 2023

Figure 1 - strategic objectives

Whilst the ASR DFLF will make reasonable efforts to achieve the strategic objectives as set forth above, no guarantee can be given that the strategic objectives can be realised. Due to various risks and uncertainties, actual results may differ materially from the strategic objectives set forth above.

The strategic objectives mentioned above are part of the Fund’s CSR policy and are monitored at portfolio level. This CSR policy has been drawn up under the responsibility of the management of the Fund and is part of the Three Year Business Plan (TYBP). This plan is updated and approved on a yearly basis by the Meeting of Investors, which represents all participants in the Fund. The management of the Fund is responsible for implementing the Fund’s strategic objectives as set forth above and for reporting on its deployment on a quarterly and yearly basis. The most important ESG impacts are taken into account by following and monitoring the CSR policy.

Integrating sustainability objectives in investment decisions

As an integral part of its strategy, all of the Fund’s activities must comply with its CSR policy. Investments and divestments are made as part of the deployment of the strategy. All investments and divestments are subject to due diligence. The results of this process are recorded in standardised investment proposals. The Fund’s CSR objectives set out above and the accompanying impacts of investments/divestments are included in the investment proposals as far as possible. Such investment proposals will include identified environmental, social or governance events which, if they occurred, could have a material negative effect on the value of the investment.

The ASR DFLF has identified four major climate risks, inter alia, that could have an impact on the investments. These risks are also taken into account in the decision-making process concerning the investments. The four climate risks are:

  • heat stress
  • flooding
  • drought
  • precipitation

Above all, and as mentioned above, the most important impacts of investments and divestments in this area are managed by following and monitoring the CSR policy.

All of the material Fund’s investment/divestment proposals are discussed in the Investment Committee of a.s.r. real estate, which includes the statutory board of a.s.r. real estate and managing directors of its business lines, supported by an independent analysis by legal, tax, compliance and risk officers. Above a certain threshold value specified in the Fund governance, investment/divestment proposals will be submitted to the Investment Committee of the Fund for approval.

The main sustainability risks for the sustainability targets will be mitigated in accordance with the other fund objectives by an integrated risk management system based on a risk control matrix and enterprise risk management. For further information with respect to the risk factors please see the Fund Prospectus.

Finally, CSR and sustainability in particular are rapidly developing areas of expertise in the real estate sector. a.s.r. real estate actively contributes to the development of market standards, for example by contributing to platforms such as IVBN, INREV, DGBC, RICS, GRESB and Neprom. The resulting advanced insights will be incorporated into the CSR policy of a.s.r. real estate and the ASR DFLF.