Introduction

According to the Sustainable Finance Disclosure Regulation ("SFDR") Jupiter Capital is obliged to provide information on its website about the role of sustainability (environmental, social and governance) in its investment policy and investment decisions. The regulations aim to make the sustainability profile of funds more comparable and better understood by end-investors. In compliance with the SFDR, Jupiter Capital informs its investors by means of this publication about the manner in which it integrates sustainability risks in its investment decisions, whether it considers adverse impacts of its investment decision on sustainability factors and the way in which sustainability risks are incorporated into its renumeration policy.

Sustainable risk factors

In compliance with the SFDR, Jupiter Capital integrates sustainability risks into its investment decisions. A sustainability risk means an environmental (E), social (S) or governance (G) event or condition that, if it occurs, could cause an actual or a potential material negative impact on the value of the investment.

In managing the investment fund, certain types of investments are selected on the basis of the established investment policy. When selecting investments, numerous factors are taken into account that can affect the value of the investment. Because sustainability risks can also (negatively) affect this value development, these aspects are included to the extent applicable. ESG risk factors are integrated in the investment decision process (in the due diligence in the acquisition phase).

Sustainability risks in the ecological area include climate change, water scarcity and the use of natural resources. Currently, there are no material risks related to the environment to be identified for the fund managed by Jupiter Capital.

Social risks include product liability and respect for labour rights. Indirectly, the current fund managed by Jupiter Capital might face reputational risks as a consequence of social risks (S). For example, there is a risk that there are bad working conditions or insufficient labour rights for employees of local cooperating companies (such as the valuer, the contractor or property manager(s)). To manage the social risks, Jupiter Capital selects reputable, local parties which (in principle) publish information on ESG on their websites.

In the area of governance, risks may arise with respect to remuneration, stability and diversity of directors, business ethics and shareholder rights. Currently, the governance risks (G) are not applicable to the fund managed by Jupiter Capital, because the fund invests in real estate and not in companies. Jupiter Capital does not consider governance risks relevant in relation to its local cooperating companies.

No consideration of adverse impacts of investment decisions on sustainability factors

Within the meaning of SFDR, sustainability factors are environmental, social and employment issues, respect for human rights, and the fight against corruption and bribery. When carrying out due diligence in respect of potential regarding potential investments, Jupiter Capital does not consider adverse impacts of investment decisions on sustainability factors. Consequently, Jupiter Capital does not issue a principle adverse impact statement ("PAI-statement").

In line with the explain-mechanism of article 4(1)(b) SFDR, Jupiter Capital has the following considerations to not issue a PAI-statement. Jupiter Capital believes that there is currently insufficient reliable data available to determine the potential negative effects of investments in relation to sustainability. Where detailed data is available, it is (too) expensive to obtain and time-consuming to analyse. Much remains unclear about the exact scope and content of the PAI-statement and the investment required from Jupiter Capital to issue such PAI-statement. In addition, Jupiter Capital does not give specific priority to sustainability factors over other factors that are important in managing the investments. In this view, Jupiter Capital believes it is not proportionate in terms of time investment, costs and capacity to provide an PAI-statement. For this reason, Jupiter Capital does not explicitly take into account the possible negative effects of investments on sustainability factors in the investment process and has no intention to do so in the near future.

Renumeration Policy

According to article 5(1) SFDR, Jupiter Capital is obliged to publish information on its website about the consistency of the remuneration policy with integration of sustainability risks. Jupiter Capital does not have (and, considering the AIFMD-light regime, is not obliged to have) a remuneration policy in place. Therefore, it is not possible to include information on the consistency of the remuneration policy with integration of sustainability risks.

Sustainability in relation to the investment funds of Jupiter Capital

In line with the above, the fund managed by Jupiter Capital does not generally have a sustainable investment objective, nor does it seek to promote environmental or social characteristics as referred to in articles 8 and 9 of the SFDR.

Jupiter Capital reviews its policy on sustainability on a regular basis. If at any time Jupiter Capital, as fund manager, moves within the scope of SFDR (also considering underlying regulations and guidance from supervisory authorities), it will amend and supplement this sustainability statement as appropriate.