Sustainable Finance Disclosure Regulation ASR Property 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 Property Fund (ASR PF) is a financial product that invests in listed real estate and promotes environmental characteristics and good governance 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 PF 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 PF 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 PF 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 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 PF. 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 PF 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. To work towards the goals set in the CSR policy, each year the Fund develops a strategic Corporate Social Responsibility (CSR) policy around four themes:

  • Planet: contribution to environment and society
  • Property: sustainable portfolio
  • Partners: sustainable partners in long-term relations
  • People: sound business practices and healthy and satisfied employees

While each “P” focuses on a specific aspect of CSR, all four 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 PF 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 PF CSR Objectives 2022 2024

Figure 1 - strategic objectives

Whilst the ASR PF 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 updated and approved on a yearly basis. 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 bi-annually basis. The most important ESG impacts are taken into account by following and monitoring the CSR policy.

Integrating sustainability objectives in investment decisions

The asset management of ASR Property Fund’s portfolio has been outsourced. The CSR objectives of the ASR PF, among other objectives, are part of the selection and evaluation process of the asset manager(s).
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.

Adverse impacts of investment decisions

Pursuant to Article 4(1)(a) of the SFDR, ASR DCRF hereby states that it considers adverse impacts of its investment decisions on sustainability factors. a.s.r. real estate promotes various environmental and social characteristics. The adverse impacts on sustainability are taken into account in its investment decision procedures.

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 PF.