SFDR Disclosures

Commodus Real Estate Capital GmbH is an alternative investment fund manager within the meaning of the German Investment Code (Kapitalanlagegesetzbuch, KAGB) and as such publishes the following information on its website in light of the consideration of sustainability-related aspects in accordance with Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability disclosure requirements in the financial services sector (“SFDR”).

The following statements refer to the management and investment decision-making processes of Commodus Real Estate Capital GmbH.

I. Sustainability risk policies statement

Commodus Real Estate Capital GmbH addresses sustainability risks in their investment decision-making process. ‘Sustainability risk’ means an environmental, social or governance event or condition that, if it occurs, could cause an actual or a potential material negative impact on the value of the investment.
 

Restricted Sectors

We acknowledge and agree that we shall not invest, guarantee or otherwise provide financial or other support, directly or indirectly, to companies or other entities whose business activity consists of an illegal economic activity (i.e. any production, trade or other activity, which is illegal under the laws or regulations applicable to the Fund.

We regularly review our policies to ensure that they address new and emerging risks as well as investors’ concerns.

 

II.          Principal adverse sustainability impacts statement

Commodus Real Estate Capital GmbH addresses sustainability risks in their investment decision-making process. ‘Sustainability risk’ means an environmental, social or governance event or condition that, if it occurs, could cause an actual or a potential material negative impact on the value of the investment.

Commodus Real Estate Capital GmbH considers principal adverse impacts of its investment decisions on sustainability factors. The present statement is the consolidated principal adverse sustainability impacts statement of Commodus Real Estate Capital GmbH.

 

Description of principal adverse sustainability impacts

‘Sustainability factors’ mean environmental, social and employee matters, respect for human rights, anti-corruption and anti-bribery matters. The indicators related to principal adverse impacts on sustainability factors can be divided into three categories: (a) climate and other environment-related indicators; (b) social and employee, respect for human rights, anti-corruption and anti-bribery matters; (c) indicators applicable to investments in sovereigns and supranationals. The indicators are applicable to investments in investee companies. Indicators as stated in (c) are not relevant for Commodus Real Estate Capital GmbH however, as investing into sovereigns and supranationals is not part of Commodus Real Estate Capital GmbH’s investment strategy.

Commodus Real Estate Capital GmbH will identify the principal adverse sustainability impacts of investments as follows:

(a) Climate and other environment-related indicators

Commodus Real Estate Capital GmbH aims to consider the following climate and other environment-related indicators at a portfolio level:
 

  • Greenhouse gas emissions
  • Carbon footprint
  • Fossil fuels sector exposure
  • Share of energy consumption and production from non-renewable sources compared to renewable sources
  • Emissions to water
  • Hazardous waste production
  • Emissions of ozone depleting substances

 

Commodus Real Estate Capital GmbH considers the following principal adverse impacts other than climate/environment related as follows
 

  • Violations of UN Global Compact principles and OECD Guidelines for Multinational Enterprises
  • Lack of processes and compliance mechanisms to monitor compliance with UN Global Compact principles and OECD Guidelines for Multinational Enterprises
  • Unadjusted gender pay gap
  • Board gender diversity or the lack thereof