Management policy
ESG criterias

ENVIRONMENTAL, SOCIAL AND GOVERNANCE CRITERIA (ESG)

REGULATORY CONTEXT

The decree implementing Article 29 of the Energy-Climate Law (LEC) of 8 November 2019, published on 27 May 2021, aims to clarify and strengthen the extra-financial transparency framework for market players. This mainly involves: 1. Better integration of climate and biodiversity issues within investment policies; 2. Taking account of environmental, social and governance (ESG) criteria in risk management. The measures introduced by this decree will provide a framework for market participants and investors. It aims to contribute to the greening of finance, to the acceleration of the ecological and social transition, and to the implementation of the Paris Agreement. It also aims to reconcile the requirements of French and European law.

In accordance with article 29, investors are informed that HORIZON ASSET MANAGEMENT includes environmental, social and governance (ESG) criteria in its investment strategies.

1. GENERAL APPROACH TO TAKING ESG CRITERIA INTO ACCOUNT
   In its management approach, HORIZON ASSET MANAGEMENT ensures that its investment analyses include a socially responsible approach to the challenges facing the property sector. Taking into account environmental, social and governance criteria leads to a better assessment of investments in terms of their usefulness and sustainability. HORIZON ASSET MANAGEMENT integrates the aforementioned criteria into its investment analysis and decision-making processes. We encourage environmentally-friendly property projects that use natural and renewable resources in the construction process. We pay particular attention to social criteria when choosing investments.
2. CONTENT, FREQUENCY AND MEANS USED TO INFORM CUSTOMERS
   HORIZON ASSET MANAGEMENT communicates on its website (Regulatory information / ESG policy) and "ESG Investor information". This information is updated on an annual basis or in the event of a change in the ESG policy applicable within the portfolio management company.
3. OPC CONCERNED BY THE INCLUSION OF ESG CRITERIA
   Horizon Impact – Compartiment France Habitat  Part A : FR0013216397  Part B : FR0013216389  Part C : FR0013216405 In accordance with article 29LEC, HORIZON ASSET MANAGEMENT is not required to publish a specific annual report setting out how ESG information is taken into account for each fund, given that each of the funds under management has assets of less than 500 million euros.

Sustainability declaration

Although HORIZON AM incorporates the environmental or social characteristics of its investments into its investment policy, this analysis and the construction of the portfolio are not accompanied by specific objectives and constraints, particularly with regard to the sustainability risk of the portfolios.

Consequently, from 31/12/2023, individual appraisals and objectives will include qualitative elements relating to the environmental or social characteristics of investments and the sustainability risk of the portfolios managed (knowledge of specific regulations, in particular standards relating to Taxonomy, ESG, sustainability, PRI, SRI and, more generally, the principles of responsible investment. The appraisals and remuneration of the staff concerned will be determined on the basis of the achievement of this qualitative objective.

Pursuant to Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on the publication of sustainability information in the financial services sector (hereinafter the "SFDR Regulation"), material adverse impacts ("MAIs") are the most significant negative impacts of investment decisions on sustainability factors related to environmental, social and personnel issues, respect for human rights and anti-corruption. In application of the SFDR Regulation, financial market operators must publish and keep up to date on their website information on whether or not their investment decisions take into account sustainability PAIs. HAM has examined the conditions for implementing its obligations relating to the consideration of sustainability PAIs in the context of its real estate fund management and real estate advisory activities. In this context, HAM has chosen not to commit to systematically taking into account sustainability factors in its investment decisions. This absence of commitment is formalised in the terms of this declaration of non-inclusion of IAPs. However, HAM is aware of the importance of taking IAPs into account, and may therefore decide to take them into account in one or more of its investment decisions. In view of its size (< 500 employees), HAM is not obliged to include ILPs in its risk management policy. Consequently, IFAs and their quantitative and qualitative impact are not taken into account in the performance of products managed by HAM.