CONSIDERATION OF THE NEGATIVE IMPACTS OF SUSTAINABILITY INVESTMENTS
Sustainability investment risks may either represent a risk in their own right or impact on other risks and consequently contribute significantly to risks such as market risks, operational risks, liquidity risks or counterparty risks. Sustainability risks may affect long-term risk-adjusted returns to investors. The assessment of sustainability risks is complex and may be based on hard-to-obtain and incomplete environmental data, considered outdated or otherwise materially inaccurate. Even when identified, there is no guarantee that such data will be correctly assessed.
With regard to climate, the management company has identified two types of risk borne by issuers: physical risks resulting from damage directly caused by meteorological phenomena and transition risks related to the effects of the implementation of a low-carbon economic model: legal, regulatory and political developments, changes in supply and demand, technological innovations and disruptions, and the perception by customers and stakeholders of the contribution to the transition.
Biodiversity-related risks are not assessed due to a lack of data and established methodology. The management company has analysed that in the short and medium term it is mainly the transition risks that could affect investors. If, however, the temperature rise were to be significant, the physical risks would become predominant. Transition risks related to the market or technology market or technology related transition risks are latent but could materialise very quickly.
The characteristics of sustainability risks are often difficult to reconcile with standard investment processes that are based on the The characteristics of sustainability risks are often difficult to reconcile with standard investment processes that are based on probabilities derived from the past. The management company The management company measures these risks for all portfolios and incorporates them into investment The management company measures these risks for all portfolios and incorporates them into investment decisions on an ad hoc basis according to its assessment of the occurrence of the risk.
With regard to sustainability risk management, the following risks have been identified:
i) Regulatory and legal risks for investments that do not comply with the investment policy or applicable legislation (country of location of assets);
ii) Liability claims for negative impact of the assets on human health (tenants, neighbours, municipality…) with possible impact on the profitability of the investment and risk regarding the liability of the management company;
iii) Orders to carry out upgrading work (environmental standards) on the assets (impact on the profitability of the investment) (impact on the profitability of the investment and possible risk concerning the liability of the management company);
iv) Prohibition to rent non-compliant assets (impact on the profitability of the investment; (impact on the profitability of the investment; possible risk concerning the liability of the management company).
The management company integrates ESG risk factors into its analysis. It does not have a specific It does not have a specific objective in this area.
The scope retained by the management company of the regulatory criteria for the definition of its policy determines the determination of the persons identified and the application of the proportionality principle.
The general obligation to have sound remuneration policies and practices applies to all management companies, regardless of their size or systemic importance. systemic importance.
Having regard to its size, internal organisation, nature, scope and complexity of activities and categories of staff, the the nature, scope and complexity of the activities and the categories of its staff, the management company shall apply the principle of proportionality1 with regard to appropriate to its level of risk.
The remuneration policy covers all aspects of remuneration including fixed components, variable components, variable components, retirement conditions and other similar specific benefits. similar specific benefits.
The long-term strategy of the management company takes into account the overall business strategy The long-term strategy of the management company takes into account the overall business strategy and quantified risk tolerance levels on a multi-year basis through the alignment of the remuneration policy with its interests and the interests of the AIFs under management and their investors and their investors, the prevention of excessive risk-taking and the risk-adjustment of the variable remuneration.
Severance packages that allow for the payment of significant amounts to identified individuals leaving the AIF in accordance with performance and risk of significant amounts to identified individuals who leave the management company are correlated with the performance over time and, in particular, the failure of the identified individuals concerned to achieve their objectives. objectives by the identified persons concerned.
These payments are set and approved in accordance with the governance structure to ensure that failure is not rewarded.
The fixed remuneration remunerates professional services rendered, in accordance with the level of education, hierarchical rank, level of expertise and skills required, difficulties and professional experience, as well as the relevant business sector and region.
The fixed remuneration is based on the definition of the objectives of the management company, the relevant business unit or the relevant managed AIF. It takes into account both the current and future risks taken by the employees, the business unit, the relevant AIF or the management company as a whole.
Variable remuneration includes predetermined risk and performance parameters2 . performance2 :
- Of the AIF under management
- Of the management company as a business unit
- The individual activities of the identified person
These parameters are weighted for each person concerned according to:
- The level of decisions taken
- The achievement of objectives (the objectives assigned must be achievable)
- Measures over which the person has some direct influence
In line with its sustainability risk management, the management company integrates ESG risk factors into its analysis. ESG risk factors in its analysis. It does not have a specific target in this respect.
1 Esma guidelines n°2013-232, version of 30-1-2014, point 20
2 ESMA guidelines no. 2013-232, version of 30-1-2014, point 101