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 negative impact on the value of the investment, even though such risks are continuously monitored and measures are taken to manage and mitigate them.

PIC Funds does not meet the criteria of the larger institutions provided for in Article 4, no. 3 and 4 of the SFDR, but still considers the impact of its activity on environmental issues, always verifying, for instance, the energy efficiency of the assets in which it invests, and also seeking to promote energy savings in its facilities and the reduction of plastic consumption. Moreover, the Company has a special concern for the well-being of its employees and seeks to adopt the most appropriate governance policies to promote the sound and prudent management of its activity and of the Funds under management.

Given the Company's specific activity and the fact that the criteria for the consideration of negative 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 negative impacts of investment decisions on sustainability factors. Furthermore, in the absence of unified public information, the consideration of negative 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

Given its activity, PIC Funds does not incorporate, in any specific way, sustainability risks when calculating variable remuneration, without prejudice to the Company's risk management policy.

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.