Regulations

Environmental, social and governance (ESG) criteria

Regulatory context

Article 173 of the Energy Transition for Green Growth Act no. 2015-992 of 17 August 2015 amends article L. 533-22-1 of the Monetary and Financial Code, which now states that: "Portfolio management companies shall make available to subscribers of each of the UCIs they manage information on how their investment policy takes account of criteria relating to compliance with social, environmental and governance quality objectives. They shall specify the nature of these criteria and the way in which they are applied, in accordance with a standard presentation laid down by decree. They shall indicate how they exercise the voting rights attached to the financial instruments resulting from these choices".

In accordance with article 173, 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 takes care to integrate socially responsible thinking into its investment analyses in response to the challenges of the property sector. Taking into account environmental, social and governance criteria leads to a better evaluation of investments in terms of usefulness and sustainability. HORIZON ASSET MANAGEMENT integrates the aforementioned criteria into its investment analysis and decision-making processes. We encourage real estate projects that respect the environment and where natural and renewable resources are used in the construction process. We pay particular attention to social criteria when selecting investments.
2. CONTENT, FREQUENCY AND MEANS USED TO INFORM CLIENTS
   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 changes to 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 173, 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.

1. GENERAL APPROACH TO TAKING ESG CRITERIA INTO ACCOUNT
   In its management approach, HORIZON ASSET MANAGEMENT takes care to integrate socially responsible thinking into its investment analyses in response to the challenges of the property sector. Taking into account environmental, social and governance criteria leads to a better evaluation of investments in terms of usefulness and sustainability. HORIZON ASSET MANAGEMENT integrates the aforementioned criteria into its investment analysis and decision-making processes. We encourage real estate projects that respect the environment and where natural and renewable resources are used in the construction process. We pay particular attention to social criteria when selecting investments.

Handling and monitoring complaints

This information has been prepared in accordance with Article 318.10 of the General Regulations of the AMF (Autorité des Marchés Financiers) and AMF Instruction No. 2012-07. It is intended to inform HORIZON AM customers about the procedure for handling complaints, applicable from 1 September 2012.

Only declarations expressing the customer's dissatisfaction with the professional are concerned, to the exclusion of requests for information, advice, clarification, service or provision.

Person in charge of handling complaints at HORIZON AM :
The RCCI or the Back/Middle Office manager

How to contact the person in charge of handling complaints at HORIZON AM :
HORIZON AM
21B Rue Jacques Cartier 78960
Voisins-le-Bretonneux

Complaints can also be sent to HORIZON AM :
by mail : This email address is being protected from spambots. You need JavaScript enabled to view it.
by phone : 01 73 00 59 20

To ensure that we have received your complaint, we recommend that you send it to us and request an acknowledgement of receipt.

Processing times for returns :
HORIZON AM undertakes to send the customer an acknowledgement of receipt within 10 days if the complaint cannot be dealt with more quickly. From the date of this acknowledgement of receipt, the request will be processed within a period that may not exceed 2 months.

Recourse :
If you are dissatisfied with the outcome of your complaint, you can contact the AMF Ombudsman by completing the mediation request form. The mediation charter is also available on the AMF website.

Contact the Mediation officer by post :
AMF
Miss Marielle COHEN-BRANCHE
AMF Mediator
17, place de la bourse 75082 PARIS CEDEX 02
Fax : 01.53.45.59.60

The procedures are confidential, free, adversarial and non-binding. Each party may terminate the proceedings at any time and retains the right to take the matter to court.

However, before referring the matter to the AMF Ombudsman, customers must first contact the person in charge of complaints at HORIZON AM.

Managing conflicts of interest

In the course of its activities, HORIZON AM may be faced with conflicts of interest that could potentially harm the interests of its clients. In accordance with the applicable regulations, the Management Company has taken all reasonable measures to prevent conflicts of interest, and has set up a system to manage proven conflicts of interest, where applicable..

HORIZON AM's Conflicts of Interest Management Policy is available on request from the Management Company.

Investment allocation

Where several investment vehicles set up or managed by Horizon Asset Management each have an interest in investing in the same investment opportunity, Horizon Asset Management will encourage co-investment between the vehicles concerned whenever this method can be implemented in practice for the project in question and is not excluded by the reference documentation of the investment vehicles concerned.

Where a project to invest in a real estate asset or a portfolio of real estate assets is carried out directly or indirectly by means of co-investment between several vehicles under management, their respective share of investment in this project will be determined in accordance with Horizon Asset Management's procedure for managing conflicts of interest on the basis of :

 the investment capacity of investment vehicles,

 tax, legal, regulatory and contractual constraints on investment vehicles,

 constraints on risk-splitting ratios and the influence of investment vehicles,

 the status of the investment vehicles concerned and the regulations to which they are subject,

 and the length of the investment period for investment vehicles,

 All the criteria used to analyse these situations will be documented and kept by Horizon Asset Management..

In the case of a co-investment, the transaction will be carried out on the same terms for all the vehicles participating in the transaction. The transaction will be carried out on a pari passu basis on similar terms depending on the nature of the investments or the securities that do or do not make up the capital (shares, bonds, warrants, convertible bonds, current account advances, etc.).

However, in certain situations, Horizon Asset Management may give priority to certain FIAs. To date, the following situations have been identified: the creation of a thematic FIA (whose investment target corresponds precisely to this theme), the need to close an investment period within a short timeframe, or a subscription in a company that has already acquired some of the FIA's assets.

Lastly, with regard to opportunities that may be offered directly to FIA investors or third parties, Horizon Asset Management ensures that its own collective investment vehicles/FIAs are given priority for investment, and that the presence of another investor in the round table is likely to promote the success of the transaction.

Best selection

HORIZON AM's Intermediary Selection and Evaluation Policy sets out the criteria used to obtain the best possible results for the client when executing orders.

The "best selection" policy implemented by HORIZON AM is available on request from the Management Company.

Presentation of the management company

Horizon AM is a portfolio management company authorised since 24 June 2016 by the Autorité des Marchés Financiers under number GP-1600018 and domiciled at 21B rue Jacques Cartier - 78960 Voisins-le-Bretonneux.

Further information can be obtained from
HORIZON AM 21B rue Jacques Cartier 78960 Voisins-le-Bretonneux
Or by filling in this form.

Voting policy

At the present time, HORIZON ASSET MANAGEMENT does not deal in shares. Consequently, it has not established a voting policy.