Sustainability-related disclosures

Interfundos integrates considerations related to sustainability risks into its analysis and investment decision-making processes, proportionally to the nature of its activity and the entities under management. Nevertheless, at this time, for the reasons stated below, it does not consider the principal adverse impacts of investment decisions on sustainability factors:

• The investment policy and strategy for 14 (fourteen) of the 15 (fifteen) closed-end and privately subscribed real estate investment undertakings under management are, to a large extent, defined by their respective Participants/Shareholders, limiting Interfundos' ability to autonomously introduce specific criteria related to the consideration of principal adverse impacts on sustainability factors;
• None of the 15 real estate investment undertakings under management promote environmental or social characteristics or pursue sustainable investment objectives as per Articles 8 or 9 of Regulation (EU) 2019/2088, with all of them falling under Article 6 of the said Regulation;
• The availability, quality, consistency, and comparability of the information required for the calculation of the indicators listed in Annex I of Delegated Regulation (EU) 2022/1288 continue to present significant limitations within the universe of real estate assets and entities in which the undertakings under management can invest, a circumstance that hinders the adequate consideration of the principal adverse impacts of investment decisions on sustainability factors;
• Obtaining and processing the necessary information through external specialized providers would currently entail a significant operational and financial effort and disproportionate costs relative to the size and nature of the activity developed by Interfundos, without guaranteeing in all cases the coverage, quality, and sufficiency of the information required for a consistent assessment of the principal adverse impacts;
• Interfundos does not currently meet the size criteria set out in paragraphs 3 and 4 of Article 4 of Regulation (EU) 2019/2088, and therefore is not subject to the obligation to consider principal adverse impacts at the entity level.

Notwithstanding the above, Interfundos monitors the evolution of the European regulatory framework for sustainable finance, as well as the availability, quality, and comparability of relevant ESG information for the assets under management. To this end, it will periodically re-evaluate its position regarding the consideration of the principal adverse impacts of investment decisions on sustainability factors, making any necessary adaptations. Should the circumstances listed above change, it will timely and appropriately inform its investors, other stakeholders, and the competent supervisory authorities in a transparent manner.