The fund promotes environmental and social characteristics but does not pursue a sustainable investment objective within the meaning of Article 9. We name this classification openly, because it makes the difference.
The fund promotes environmental and social characteristics within the meaning of Article 8 of Regulation (EU) 2019/2088.
For the principal adverse impacts on sustainability factors there is an opt-out. The fund does not consider them systematically under Article 4(1)(b).
The reason is the data situation: in insolvency purchases and NPL acquisitions neither energy-consumption data nor verified tenant compositions are available, so the fourteen standardised indicators cannot be reliably captured at asset level. Instead, a qualitative assessment is carried out project by project as part of the ESG due diligence. The AIFM reviews annually whether systematic capture becomes possible.
Four characteristics, each backed by an indicator. Source: prospectus Annex A.2.
Target standard KfW 40 QNG for German, and klimaaktiv or ÖGNI Gold for Austrian new builds and comprehensive refurbishments. For existing properties, the improved energy balance relative to the acquisition condition counts.
Priority for the repositioning of existing fabric over greenfield new build. Demolition and new-build volumes are avoided where the fabric can carry.
Promotion of socially acceptable forms of housing — affordable multi-family housing, assisted living and care facilities.
Neighbourhood reactivation, cooperation with local stakeholders and transparent governance through the Operandis group.
Source: prospectus v1.4, Annex A.2, as at 2 September 2026. Refurbishments of existing stock in the distressed segment do not reach the target standard in every case; the target figure applies at portfolio level, not per asset.
Four building blocks across the entire investment cycle. Source: prospectus Annex A.3.
The minimum share of sustainable investments of 20 % is aligned with the climate change mitigation objective of the EU Taxonomy, specifically the economic activity “construction and operation of energy-efficient buildings” under Annex I point 7.7 of Delegated Regulation (EU) 2021/2139.
Every investment declared sustainable undergoes a DNSH assessment against the other five EU environmental objectives: climate change adaptation, water, circular economy, pollution prevention and biodiversity. The minimum social safeguards under the UN Guiding Principles and the ILO core labour standards are verified in the KYC review.
Four indicators, four data sources. Source: prospectus Annex A.8 and A.9.
In distressed assets the ESG legacy documentation is frequently incomplete or outdated. Data is supplemented through the due diligence and the capex phase. This delays the final ESG classification, particularly for existing properties of acquisition profile C and for insolvency acquisitions. An asset qualifies as a sustainable investment only after a completed DNSH assessment and submission of the certificates.
The ESG due diligence is a mandatory component of every acquisition review and is documented through the AIFM's ESG scorecard tool.
Engagement with tenants, operators and general contractors takes place project by project, in particular on construction and operating standards and in the selection of whitelist partners. There is no formal stewardship policy — the fund holds no listed equity interests.
Delegated Regulation (EU) 2022/1288 prescribes twelve sections on the website for an Article 8 product. We disclose openly which are substantively in place and which is still missing.
| Mandatory section | Evidenced by | Status |
|---|---|---|
| Summary | — | open |
| No sustainable investment objective | Annex A.1 | in place |
| Environmental and social characteristics | Annex A.2 | in place |
| Investment strategy | Annex A.3 | in place |
| Allocation of investments | Annex A.4 | in place |
| Monitoring of the characteristics | Annex A.8 | in place |
| Methodologies | Annex A.8 | in place |
| Data sources and processing | Annex A.9 | in place |
| Limitations to methodologies and data | Annex A.10 | in place |
| Due diligence | Annex A.11 | in place |
| Engagement policy | Annex A.11 | in place |
| Reference benchmark | Annex A.12 | in place |
Article 8 means: the fund promotes environmental and social characteristics. It does not mean that every investment is sustainable, and it is not a seal of quality. Up to 30 % of the portfolio is not subject to the promoted characteristics.
Distressed assets naturally enter the portfolio in poor energy condition. The sustainability contribution arises only through refurbishment — and thus only after acquisition, construction time and capital deployment. That is a risk, not an argument.
