Shareholder Engagement Policy at ASR Real Estate B.V.

In its role as manager of the ASR Property Fund FGR (‘ASR Property Fund’), ASR Real Estate B.V. (a.s.r. real estate) is licensed as an AIF manager. As a holder of an AIF manager licence, a.s.r. real estate pursues a socially responsible investment policy and operates as an engaged shareholder, in compliance with the requirements of the revised Shareholder Rights Directive (2017/828 EU).

ASR Property Fund’s legislative and policy framework

The shareholder engagement policy of a.s.r. real estate is based on:
• the Financial Supervision Act (Wet op het financieel toezicht, Wft)
• SRD II (Shareholder Rights Directive).

Other policy frameworks which relate to or overlap with the present policy are:
• the conflict of interest policy of ASR Nederland N.V. and a.s.r. real estate
• the CSR policy of ASR Nederland N.V.
• the CSR policy of a.s.r. real estate
• the CSR policy of ASR Property Fund


The portfolio management of ASR Property Fund’s European listed real estate portfolio has been outsourced to AXA Investment Management S.A. (AXA IM). This means that a.s.r. real estate follows the shareholder engagement policy of AXA IM. Full details of AXA IM’s shareholder engagement policy can be found on the AXA IM website. The voting behaviour of AXA IM during the past financial year can be found in the following report [in English].

Compliance testing

The activities of outsourcing parties are assessed by a.s.r. real estate at least once a year in accordance with DNB requirements. Through random checks, a.s.r. real estate also periodically verifies whether the policy pursued by AXA IM continues to comply with the investment policy adopted by the manager. Further information about ASR Property Fund’s investment policy can be found in the Key Investor Information.