Sustainability
PIC Funds is a manager of alternative investment funds (“AIFM”), as determined by Regulation (EU) 2019/2088 of the European Parliament and of the Council, of 27 November 2019, concerning the disclosure of information related to sustainability in the financial services sector (Sustainable Finance Disclosure Regulation - “SFDR”).
Risk Management
PIC Funds has assumed a low-risk appetite for sustainability risks, i.e. an environmental, social or governance event or condition whose occurrence is likely to have a significant actual or potential adverse impact on the value of the investment, even though such risks are continuously monitored and measures are taken to manage and mitigate them. The integration of sustainability risks is performed via the following steps: (i) identification and assessment of sustainability risks during the process of screening new investment opportunities, based on the information available and made available by the selling entity; (ii) integration of sustainability risks into the investment approval process, with investments with high sustainability risks being subject to additional analysis; (iii) continuous monitoring of sustainability risks in investments made; and (iv) promotion of sustainability training to ensure that PIC Funds employees have the necessary knowledge to assess and integrate sustainability risks into the investment process.
No consideration of adverse impacts of investment decisions on sustainability factors
PIC Funds does not meet the criteria of the larger institutions provided for in Article 4, no. 3 and 4 of the SFDR, and does not consider the adverse impacts of investment decisions on sustainability factors.
Notwithstanding this, the Company does not disregard the impact of its activity on environmental issues, always verifying, in particular, the energy efficiency of the properties in which it invests, and also seeking to promote energy savings in its facilities and the reduction of plastic consumption. In addition, the Company shows a special concern for the well-being of its Employees, which is the social impact to which the Company devotes the most attention. Finally, the Company seeks to adopt the most appropriate governance policies to promote the sound and prudent management of its activity and of the Funds managed.
Given the Company's specific activity and the fact that the criteria for the consideration of adverse sustainability impacts are not yet sufficiently defined in a uniform manner for the real estate activity, the Company has so far not approved any due diligence policy to assess the adverse impacts of investment decisions on sustainability factors. Furthermore, in the absence of unified public information, the consideration of adverse sustainability impacts could result in a high and disproportionate cost for the Company and, consequently, for its investors, as the Company would have to resort to external sources of information and service providers. However, PIC Funds does not exclude adopting that policy once relevant criteria are defined with greater certainty.
Remuneration Policy
The Remuneration Policy approved by PIC Funds defines the principles of its’ remuneration system. The variable component of remuneration to be awarded to each employee is determined based on the individual performance appraisal, the results of the funds under management to which said employee is allocated (if applicable), and PIC Funds' overall results. Sustainability risks are indirectly considered when calculating variable remuneration, given their potential impact on PIC Funds’ financial performance, as well as on all funds under management.
Light Green and Dark Green Products
PIC Funds currently does not manage any Fund that promotes, among others, environmental or social characteristics or a combination of these characteristics (provided for in Article 8 of the SFDR) or that targets sustainable investments (provided for in Article 9 of the SFDR) but does not exclude the possibility of doing so in the future.