Sustainable Finance Disclosure

Integration of sustainability risks in investment decision-making processes

COIMA SGR considers the integration of environmental, social and governance (ESG) factors into its investment process to be of fundamental importance, firmly believing that these elements, in addition to fostering sustainable economic and social development, can contribute positively to the financial performance of the funds and reduce their risks. Financial market participants committed to integrating ESG criteria into their strategy are seen as capable of generating sustainable profits over time and, as a result, of creating a solid prospect of value creation for all stakeholders. This enables more efficient management of risks, including environmental and social risks that negatively affect the valuation of individual investments. Identifying and managing such risks is part of the fiduciary duty to protect value created over time.

COIMA SGR shapes its approach drawing inspiration from the Sustainable Development Goals adopted by the United Nations in 2015, contributing to 8 of the 17 SDGs through innovation pathways, focusing on people and the management of natural resources.

Alongside the traditional financial evaluation of investments, the Company applies ESG metrics in order to make better-informed investment decisions.

The approach adopted by COIMA SGR in pursuing and monitoring its objectives and in identifying and mitigating risks includes the adoption of a sustainability strategy involving scenario assessment through technical and economic analysis, in order to identify the aspects of greatest value, together with the adoption of appropriate governance structures dedicated to overseeing all ESG-related matters.

Accordingly, during the investment phase, sustainability risk management is articulated into the following activities:

• □ Screening and selection of investment opportunities: this activity is carried out on the basis of specific exclusion criteria. The exclusion criteria considered are as follows:
• □ exclusion of the possibility of developing in protected natural areas;
• □ exclusion of the possibility of constructing new buildings intended for the extraction, storage, transport or production of fossil fuels.

• □ Due Diligence: due diligence is carried out with the aim of:
• □ Understanding the financial and sustainability risks of the investment
• □ Verifying that the risk-return profile is aligned with the fund’s risk profile

• □ Calculate the sustainability risk associated with the investment using COIMA ESG Metrics by analysing:
• □ “As is” situation: assessment of the risk associated with the investment at the time of acquisition;
• □ “Target” situation: assessment of the risk associated with the investment following refurbishment interventions or new construction of the property.

The main roles and responsibilities in the defined risk-management process involve the following parties:

• □ Board of Directors: the Board of the SGR, as the Strategic Supervision body, is responsible for decisions regarding the general policies and strategies for investment and divestment of the funds. Consistently with this, the Board defines and approves, on the proposal of the Risk Management Function, the Policy for the integration of sustainability risks in investment processes and the related measurement tools.
• □ Chief Executive Officer: the body with the Management Function has the task of implementing the company’s risk-management policies, as defined by the Board, verifying their adequacy and effective implementation. It is also responsible for integrating sustainability risks within the scope of activities relating to the implementation and review of the general investment policy for each managed AIF, the periodic review of internal investment procedures, and the definition and application of the remuneration policy.
• □ Sustainability and Innovation Committee: the SIC is an advisory and proposing committee that deals with ESG matters, “Impact Investing” and product innovation. The SIC pursues the short- and medium-term sustainability objectives set by the CEO in implementing corporate strategies and the long-term objectives defined by the Board of the SGR on ESG and Innovation matters.
• □ Sustainability Function: the Sustainability Function, reporting to the Head of Sustainability and Communication, coordinates impact and ESG topics with the support of the Sustainability Officer, who is responsible for identifying, defining and managing the main sustainability matters in the company, in particular regarding the investment/divestment process and the management of real estate portfolios, verifying the requirements necessary to comply with regulation 2019/2088 on sustainability-related disclosures in the financial services sector (Sustainable Finance Disclosure Regulation, or SFDR).
• □ Risk Management Function: the Function (RMF) integrates sustainability risk into all activities defined in the Risk Management Policy and the Policy for the Integration of Sustainability Risks in Investment Processes, in accordance with the operating methods defined in the “Risk Management Operating Process” and applying the approved assessment models. The RMF submits to the Board for approval the Policy for the integration of sustainability risks and the related measurement tools, previously agreed with the Sustainability Function.
• □ Operating Functions and Committees: operating functions are the first-line control in the identification, management and assessment of the sustainability risk to which the AIFs under management are exposed. Operating functions cooperate with the second- and third-line control functions to share information and coordinate the mitigation measures to be implemented. To ensure transparency in the approach adopted by the SGR and in the measurement and assessment of the ESG objectives achieved by the company and by the investments it manages, a non-financial disclosure, the “Sustainability Report”, is published annually, aggregating the relevant ESG information and performance.

For further details, please refer to the group “Policy for the Integration of Sustainability Risks in Investment Processes” at the following link: https://coima.com/en/sustainability/disclosure/policy-and-procedure.

COIMA SGR, in compliance with Art. 4 of EU Regulation 2019/2088, has decided to adopt the “comply” approach to the consideration of the negative effects of its investment decisions on ESG sustainability factors (Environmental, Social, Governance).

Imprudent investment choices can produce negative effects on stakeholders, the environment and society.

COIMA is aware of this and has adopted a clear framework to guide its investment decisions in order to minimise negative effects.

COIMA’s sustainable investment policy includes a structured approach to mitigate sustainability risks and Principal Adverse Impacts (PAI) of investment decisions on sustainability factors, outlined in the “Final Report on draft Regulatory Technical Standards”.¹

To this end, a screening and investment-selection criterion is applied, based on two main factors:

• □ Exclusion of the possibility of developing real estate projects in protected natural areas
• □ Exclusion of the possibility of constructing new buildings intended for the extraction, storage, transport or production of fossil fuels

These two exclusion criteria are used to address some of the most significant PAIs. COIMA also collects data on the impact of carbon emissions and other significant factors and, through a proprietary methodology, COIMA ESG Metrics, determines an ESG score at asset and AIF level and calculates the associated ESG risk.

Statement on the principal adverse impacts of investment decisions on sustainability factors 2026

Statement on the principal adverse impacts of investment decisions on sustainability factors 2025

Statement on the principal adverse impacts of investment decisions on sustainability factors 2024

Statement on the principal adverse impacts of investment decisions on sustainability factors 2023

COIMA SGR is aligned with EU Regulation 2019/2088 and with best practices regarding the integration of ESG-related objectives into staff remuneration and incentive policies. The remuneration policy includes a direct link between certain indicators of the sustainable evolution of the managed portfolio and the determination of the overall variable remuneration (the Incentive Pool), and the assignment of an individual target linked to them to at least each member of its most significant staff.