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Empira

PRI reporting framework 2020

Basic information [OO 01 - 09] Asset class implementation gateway indicators [OO 10 - 12] Peering questions [OO LE 01 - HF 01]

Strategy and Governance

Objectives and strategies [SG 05 - 06] Governance and human resources [SG 07 - 08] Promoting responsible investment [SG 09 - 11] Outsourcing to fiduciary managers and investment consultants [SG 12] ESG issues in asset allocation [SG 13 - 15] Communication [SG 19]

Direct - Fixed Income

ESG incorporation in actively managed fixed income [FI 01 - 12] Implementation processes [FI 01 - 03] (A) Implementation: Screening [FI 04 - 06] Fixed income - Engagement [FI 14 - 16] Outputs and outcomes [FI 17 - 18]

Direct - Property

Overview [PR 01] Fundraising of property funds [PR 02 - 03] Pre-investment (selection) [PR 04 - 06] Selection, appointment and monitoring third-party property managers [PR 07] Post-investment (monitoring and active ownership) [PR 08 - 14] Overview [PR 08] Property monitoring and management [PR 09 - 10] Property developments and major renovations [PR 11]

Confidence building measures

Confidence building measures [CM1 01 - 07]

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You are in Strategy and Governance » Investment policy

Investment policy

SG 01. RI policy and coverage

New selection options have been added to this indicator. Please review your prefilled responses carefully.

01.1. Indicate if you have an investment policy that covers your responsible investment approach.

Yes

01.2. Indicate the components/types and coverage of your policy.

Select all that apply

Policy components/types	Coverage by AUM
Policy setting out your overall approach Formalised guidelines on environmental factors Formalised guidelines on social factors Formalised guidelines on corporate governance factors Fiduciary (or equivalent) duties Asset class-specific RI guidelines Sector specific RI guidelines Screening / exclusions policy Other, specify (1) Other, specify(2)	Applicable policies cover all AUM Applicable policies cover a majority of AUM Applicable policies cover a minority of AUM

01.3. Indicate if the investment policy covers any of the following

Your organisation’s definition of ESG and/or responsible investment and it’s relation to investments

Your investment objectives that take ESG factors/real economy influence into account

Time horizon of your investment

Governance structure of organisational ESG responsibilities

ESG incorporation approaches

Active ownership approaches

Reporting

Climate change

Understanding and incorporating client / beneficiary sustainability preferences

Other RI considerations, specify (1)

Other RI considerations, specify (2)

01.4. Describe your organisation’s investment principles and overall investment strategy, interpretation of fiduciary (or equivalent) duties,and how they consider ESG factors and real economy impact.

Objectives of EMPIRA - Implementation of ESG criteria:

- Creating a responsible and sustainable corporate culture
- Responsible interaction with society, environment and investors
- Increase in performance through sustainable investment
- Taking on a pioneering role in the real estate industry with regard to ESG standards

EMPIRA has drawn up an implementation plan to achieve these objectives. For the implementation of ESG criteria, EMPIRA uses a top-down approach. EMPIRA sees ESG as a development process that is subject to continuous adaptation. The concept focuses on the implementation of ESG criteria in the primary business processes (e.g. investment process) and the integration of ESG into the group-wide understanding of the company. EMPIRA follows the step-by-step implementation approach proposed by PRI and focuses in a first phase on mainly negative and positive criteria. It is important to consolidate the defined criteria in a first step and implement them in the sub-processes. EMPIRA initially uses a qualitative approach to measure the defined criteria. This involves actively checking, assessing and, if necessary, escalating the criteria in ongoing processes.

01.5. Provide a brief description of the key elements, any variations or exceptions to your investment policy that covers your responsible investment approach. [Optional]

01.6. Additional information [Optional].

SG 01 CC. Climate risk (Private)

SG 02. Publicly available RI policy or guidance documents

02.1. Indicate which of your investment policy documents (if any) are publicly available. Provide a URL and an attachment of the document.

Policy setting out your overall approach

URL/Attachment

URL

URL https://www.empira.ch/de/esg-nachhaltigkeit

Attachment (will be made public)

Formalised guidelines on environmental factors

Formalised guidelines on social factors

Formalised guidelines on corporate governance factors

Sector specific RI guidelines

Screening / exclusions policy

We do not publicly disclose our investment policy documents

02.2. Indicate if any of your investment policy components are publicly available. Provide URL and an attachment of the document.

Your organisation’s definition of ESG and/or responsible investment and it’s relation to investments

URL/Attachment

URL

URL https://www.empira.ch/de/esg-nachhaltigkeit

Attachment

Your investment objectives that take ESG factors/real economy influence into account

URL/Attachment

URL

URL https://www.empira.ch/de/esg-nachhaltigkeit

Attachment

ESG incorporation approaches

URL/Attachment

URL

URL https://www.empira.ch/de/esg-nachhaltigkeit

Attachment

Active ownership approaches

We do not publicly disclose any investment policy components

02.3. Additional information [Optional].

SG 03. Conflicts of interest

03.1. Indicate if your organisation has a policy on managing potential conflicts of interest in the investment process.

Yes

03.2. Describe your policy on managing potential conflicts of interest in the investment process.

The Empira Investment Solutions SA. (EIS / Empira subsidiary), as fund manager and licensed Luxembourg fund platform (AIFM) of the Empira Funds, has disclosed its conflict of interest policy under the following URL:

https://empira-invest.lu/de/corporate-governance

As Luxembourg Management Company and Manager of Alternative Investment Funds, EIS is obliged to perform its duties and activities honestly, fairly and professionally in the interest of the investors and to avoid conflicts of interest as far as possible or, if this is not possible, to keep them to a minimum.

The conflict of interest policy sets out the following points in more detail:

- INDEPENDENCE IN CONFLICT OF INTEREST MANAGEMENT
- IDENTIFICATION OF CONFLICTS OF INTEREST
- ACTIVE CONFLICT OF INTEREST MANAGEMENT
- DISCLOSURE OF CONFLICTS OF INTEREST
- CONFLICTS OF INTEREST IN OUTSOURCED ACTIVITIES
- MANAGEMENT REPORT

03.3. Additional information. [Optional]

SG 04. Identifying incidents occurring within portfolios (Private)

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