SFDR Website Disclosures
TRIBECA AIFM – SFDR WEBSITE DISCLOSURES (ARTICLES 3, 4 AND 5 SFDR)
Tribeca AIFM (Tribeca AIFM) qualifies as a “financial market participant” pursuant to Regulation (EU) 2019/2088 on sustainability‐related disclosures in the financial services sector (the SFDR). Under the SFDR, financial market participants are required to publish information on their website, including on their policies on the integration of sustainability risks in their investment decision-making process and on how they consider principal adverse impacts of investment decisions on sustainability factors.
Tribeca AIFM acknowledges the importance of environmental, social and governance (ESG) matters as a guiding principle to responsible investing. Sustainable investment is important in its decision-making processes.
In this section, the following definitions apply, in accordance with the SFDR:
"Sustainability risk" means an environmental, social or management situation or condition which, if it occurs, could cause an actual or potential material negative effect on the value of the investment.
"Sustainability factors" mean environmental, social and employee matters, respect for human rights, anti‐corruption and anti‐bribery matters.
2. SUSTAINABILITY RISKS INTEGRATION (ART. 3 SFDR)
Tribeca AIFM exclusively manages alternative investment funds (AIF) that invest in real estate assets (directly or indirectly).
Based on the sector in which it is active, the main sustainability risks that Tribeca AIFM considers are “climate risks”, which can be divided into physical risks (risks to the investments that arise from the physical effects of climate change) and transition risks (risks to the investments that arise from the transition to a low-carbon and climate-resilient economy, which include amongst others policy risks, legal risks, reputational risks, etc.), but also other sustainability risks are considered (reference is made to Tribeca AIFM’s risk management policy). Tribeca AIFM considers that it cannot be excluded that further risks will be included in the risk management process in the future.
Pursuant to Tribeca AIFM’s risk management policies, each potential new AIF managed by Tribeca AIFM shall be designated a risk profile. On that basis, an initial risk analysis of the AIF shall be carried out. This analysis shall at least include an initial assessment of (i) the market risk, (ii) the credit risk, (iii) the liquidity risk, and (iv) sustainability risks. This initial risk assessment shall be updated if and when necessary.
Before an AIF under Tribeca AIFM’s management start making investments, Tribeca AIFM carries out an in-depth risk assessment of the AIF, which includes appropriate quantitative and qualitative risk thresholds. This detailed risk assessment shall be updated if and when necessary, during the lifetime of the AIF.
All risks, including sustainability risks, will in particular be assessed in the following phases of the investment process:
• Screening phase: sustainability risks will be considered when screening new real estate acquisition projects.
• Acquisition phase: sustainability risks will be considered in the due diligence phase.
• Monitoring phase: during the management of the AIF, sustainability risks will be monitored and assessed on a regular basis, based on aforementioned risk thresholds.
3. PRINCIPAL ADVERSE SUSTAINABILITY IMPACTS STATEMENT (ART. 4 SFDR)
Financial market participants are required under the SFDR to disclose whether they consider principal adverse impacts of their investment decisions on sustainability factors and if this is the case, to disclose a statement on their due diligence policies regarding those impacts.
3.1 Principal adverse sustainability impacts indicators
In its role as financial market participant, Tribeca AIFM will consider principal adverse impacts of investment decisions on sustainability factors. Principal adverse sustainability impacts should be understood as impacts of investment decisions that result in negative effects on sustainability factors relating to environmental, social and employee matters, respect for human rights, anti-corruption and anti-bribery matters.
3.2 Responsible business conduct codes and internationally recognised standards for due diligence and reporting
For the moment, Tribeca AIFM does not formally adhere to any of the responsible business conduct codes and internationally recognised standards for due diligence and reporting.
4. INTEGRATION OF ESG RISKS IN THE REMUNERATION POLICY (ART. 5 SFDR)
Pursuant to the SFDR, Tribeca AIFM is required to explain how its remuneration policy is consistent with the integration of sustainability risks.
Tribeca AIFM’s remuneration policy considers sustainability risks in its remuneration policy by ensuring that performance is evaluated on a number of key principles, such as, for example:
• Remuneration should be consistent with and promote sound and effective risk management; amongst other through encouraging risk-taking approaches which are consistent with the risk profile (which will cover for example ESG risks) or articles of incorporation of the AIFs managed by Tribeca AIFM.
• Use of both quantitative (financial) as well as qualitative (non-financial) criteria for assessing individual performance, which will include ESG criteria (such as the integration of ESG risks into the investment decisions; and adherence to Tribeca AIFM’s sustainability policies and standards).
Last updated on 31 August 2021