Sustainable Finance Disclosure

COIMA SGR - SFDR Statement

Regulation on sustainability disclosures in the financial services sector Articles 3, 4, 5 and 10



In compliance with regulation no. 2088/2019 (SFDR), COIMA SGR publishes below the required regulatory information.

Sustainability risk: our approach [Article 3]

Integrating sustainability risks into investment decision-making

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

COIMA SGR direct its approach is being inspired by the United Nations Sustainable Development Goals, approved (SDGs), issued in 2015 by the United Nations, contributing to 8 of the 17 SDGs through innovation paths, paying attention to people and to the management of natural resources.

To the traditional financial valuation analysis of investments, the Company combines ESG metrics in order to make better informed investment decisions. The approach adopted by COIMA SGR in pursuing and monitoring the set objectives set and in identifying and mitigating risks includes the adoption of a sustainable strategy through an assessment of scenarios that include technical and economic analysis. This allows to identify the aspects of greater value creation and the adoption of adequate governance structures aimed at overseeing all aspects related to the ESG approach.

The environmental and social sustainability characteristics of the product are pursued through an investment procedure that involves selection process articulated in several phases:

  • Screening and selection of investment opportunities: this step includes the application of the exclusion criteria identified for the funds, as set out in paragraph 4 of the Sustainability Risk Integration Policy in Investment Processes
  • Determination of the ESG profile of the investment: this activity, specific for the ESG funds, takes place through the measurement of specific KPIs examined in the Sustainability Checklist and through the activation of the COIMA Charter assessment
  • Due Diligence: objective of this step is to:
    • understand the investment and the associated ESG risks through the Sustainability Checklist
    • verify that the risk-return profile is in line with the fund's risk profile
    • analyse the areas where the ESG investment objectives identified in the Sustainability Checklist can be enhanced
  • Investment Monitoring: Once the investment transaction is completed, the Fund & Asset Management division take responsibility for the project management and development activities in accordance with the conditions defined in the underwriting or investment approval business plans.

COIMA SGR ESG governance structure includes the following components:

  • Board of Directors: it approves the Fund's investment strategy, the business plan and its evolution over the years, taking into account the Policy of Integration of Sustainability Risks in Investment Processes
  • Investment Committee: it manages the process of selecting and allocating each investment opportunity to the managed funds consistently with the ESG guidelines defined in the Sustainability Risk Integration Policy in investment processes
  • COIMA Sustainable Innovation Committee (SIC): it is a technical advisory and supervisory committee dedicated to the business management of the ESG agenda, to Impact Investing and to product innovation.
    The SIC makes recommendations to the Investment Committee and to the Board of Directors.
  • Control Functions: the risk management function is responsible of monitoring and evaluating the impacts of ESG factors on the fund's risk and financial performance

In addition to the governance components described above, some funds benefit from additional support from:

  • a dedicated Steering Committee: it is a strategic committee established to be a discussion forum around ESG themes at country level, to focus on emerging ESG needs and issues and suggest how to decline such themes in the Fund's investment decisions and to monitor the progress of the Fund's ongoing projects in respect of their ESG objectives
  • COIMA City Lab: it is a heterogeneous group of established professionals and architects established in 2019 that, operating in an integrated way with the SIC, elaborates on urban, product and project issues to inspire the development of cities and territories and aims to draw up guidelines for the creation of the urban spaces of the future, both with reference to the projects that will be promoted by COIMA, both as a cultural contribution to the development of the Italian territory

In order to provide transparency to the approach adopted and to the process of measuring and evaluating the ESG objectives achieved by the company and its portfolio of investments, Coima SGR publishes an annual non-financial disclosure, the "Sustainability Report"

For more details, see the group 'Sustainability Risk Integration Policy' at the following link: https://www.coima.com/en/disclosure/sustainable-investment-policy.

Identification and prioritisation of PAI [Article 4 (2) (a)]

COIMA Sgr, in compliance with Art. 4 of the EU Regulation 2019/2088, has adopted the "comply" approach to considering the negative effects of its investment decisions on ESG sustainability factors (Environment, Social, Governance).

Reckless investment choices can have negative effects on stakeholders, the environment and society.

COIMA is aware of this and has adopted a clear framework as a guide to its investment decisions in order to minimise negative effects. In fact, in its sustainable investment policy COIMA has adopted a very structured approach aimed at mitigating sustainability risks and the main negative impacts (PAIs) of investment decisions on sustainability factors, declined within the "Final Report on draft Regulatory Technical Standards".1 To this end, a screening and investment selection criteria based on two main exclusion factors applies:

  • developing real estate projects in protected natural areas
  • building new buildings 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, the COIMA Charter, calculates an ESG ‘as is’ score to various components to obtain order of relevance.

COIMA will start the monitoring period of the indicators which will be defined by the EU from 01 January 2022 and the subsequent disclosure in the reporting documents will be reported in the dedicated section of the website and in the periodic reports starting from January 1, 2023.

1 ESA’s Final Report on draft Regulatory Technical Standards, ANNEX 1, pag. 52

SFDR Regulation – Remuneration Policy [Art. 5]

COIMA SGR is aligned with EU regulation 2019/2088 and to best practices on the integration of ESG impacts and objectives in the remuneration and incentive policy. The remuneration policy includes a direct link between indicators of the sustainable evolution of the assets under management and the determination of the overall annual Incentives Pool, and the assignment to at least each member of its most relevant personnel of an individual incentive related to them.

Products that promote environmental or social characteristics / have sustainable investment objectives [Art. 10]

Fund CECIF

Objectives of the Fund

The goal of the ESG City Impact fund is to provide long-term capital growth, while promoting ESG (i.e. Environmental, Social and Corporate Governance) features and integrating sustainability risk into the investment process.

Therefore, the Fund promotes environmental and/or social characteristics within the meaning of Article 8 of Reg. EU 2019/2088.



Environmental and/or social characteristics promoted by the Fund

The fund aims to maximize social impact and minimise environmental impacts and in particular the following macro-objectives have been identified:


  • Sustainable redevelopment of existing real estate assets and land
  • Creation of cohesive and resilient communities
  • Health and well-being in buildings and in the community
  • Promotion of culture and education


Indicators used to assess sustainable targets

The sustainability indicators used to assess the achievement of the sustainable targets that the fund has identified are measured through specific KPIs developed within the COIMA Charter.

The COIMA Charter is a proprietary tool that allows a quantitative assessment in the form of a rating articulated in three measurement areas:



  • Protection, in which environmental objectives and parameters are identified as:
    • De-carbonization of buildings and construction process
    • Applications of voluntary certifications (LEED®) of buildings and neighbourhood
    • Sustainable resource management (water, waste, etc...)
    • Environmental reclamation of buildings and sites
    • Inclusion, which summarises objectives and parameters in terms of integration and/or social impact such as:
      •  Direct and indirect contribution to the creation of jobs generated in the project development
      • Application of voluntary certifications on health and well-being (WELL Building Standard)
      • Development of attractive destinations or general interests, with attention to social inclusion and urban permeability
      • Integration of sustainable, electric and pedestrian mobility
      • Development and management of public spaces
      • Growth, in which objectives and parameters are represented in terms of economic regeneration:
        • Creation of direct, indirect added value generated by the real estate and land redevelopment process
        • Mitigation of climate risks in the development of buildings and of the territory
        • Economic activation of dismissed areas
        • Sustainable tourism promotion

      Thereby measuring the contribution of the investment to the sustainability dimensions indicated above.

      The fund will be subject to the Global Real Estate Sustainability Benchmark (GRESB) an independent global ESG rating that will provide a parallel valuation to the scoring returned by the COIMA Charter.



      Investment Strategy

      The environmental and social sustainability characteristics of the product are pursued through an investment process that involves several phases:

      • Screening and selection of investment opportunities: this activity is carried out on the basis of the exclusion criteria identified for the fund
      • Determination of the ESG profile of the investment and verification of the economic impact related to the achievement of the identified ESG objectives
      • Due Diligence: in this phase, following the estimate of the COIMA Charter selected KPIs, an "as-is" starting scenario and the "target" scenario are assessed identifying areas of potential improvement, which can be integrated into the valorisation and development process. The application of the COIMA Charter to the two scenarios leads to the determination of an overall rating based on a 0- 100 scale

      During the due diligence phase, a checklist is developed in which the sustainability risks for the specific investment are investigated in order to identify and evaluate their impact on the profitability of the fund.

      The investment strategy is monitored over time by the Fund Manager with the contribution of the Sustainable Innovation Committee (SIC).

      For more details, see the group 'Sustainability Risk Integration Policy' at the following link: https://www.coima.com/en/disclosure/sustainable-investment-policy.



      Binding elements of the investment strategy

      The binding elements of the investment strategy are:

      • Minimum Rating Target ESG COIMA Charter defined for the fund by the Board of Directors
      • Two exclusion criteria:
        • Development in protected natural areas
        • Construct new facilities for the extraction, storage, transport or production of fossil fuels


      How to monitor the implementation of the strategy

      The Fund's ESG investment strategy and process are monitored on an ongoing basis through the governance described below and in particular by the Fund Manager with the contribution of the Sustainable Innovation Committee (SIC):



      • Board of Directors: approves investment transactions
      • Investment Committee: is responsible for applying to the process of choosing each investment the ESG guidelines defined in the Sustainability Risk Integration Policy in Investment Processes
      • Investment Committee: has an advisory role in defining the proposals submitted to the Board of Directors on sustainable and responsible investment issues, aimed at ensuring the innovation of adopted methodologies and processes, monitoring compliance with the ESG indicators and how they are taken into account in the different products and services offered to customers
      • COIMA Sustainable Innovation Committee (SIC): a committee set up by COIMA, mainly of a technical – advisory nature, it conducts supervisory activities in relation to the business management of "ESG" (Environmental, Social & Governance), "Impact Investing" and product innovation
      • Steering Committee: it is a strategic committee that has the task of analysing the progress of the Fund's ongoing projects, the related ESG issues and organizing discussion sessions on ESG issues such as, current ESG issues at country level and their declination for purposes of the Fund's investments.
      • COIMA City Lab: - COIMA City Lab: it is a diversified group of established professionals and architects established in 2019 which, collaborating with the SIC, elaborates on urban, product and project issues to inspire the development of cities and territories and aims to draw up guidelines for the creation of the urban spaces of the future, both with reference to the projects that will be promoted by COIMA , and as a cultural contribution to the development of the Italian territory
      • Control Functions: the risk management function is responsible for monitoring and evaluating the impacts of ESG factors on the fund's risk and financial performance