CBRE Global Investors Luxembourg AIFM S.à r.l. (“CBRE GI Luxembourg AIFM”), is making the following disclosure pursuant to Article 4 of SFDR.
CBRE GI Luxembourg AIFM, as part of CBRE Global Investors (the “Firm”), does consider, evaluate and monitor the adverse impacts of its investments on a range of sustainability factors that it determines to be relevant. However, it continues to monitor the requirements of compliance with Article 4 of SFDR.
Article 4 of SFDR will be complemented by regulatory technical standards contained in a Commission Delegated Regulation supplementing SFDR (the “RTS“). The European Supervisory Agencies have issued their final report on the proposed RTS but the text of the RTS has not been finalised and is subject to change. The RTS is expected to apply from 1 January 2022.
It is currently unclear how mandatory principal adverse impact indicators with respect to real estate assets should be assessed with regard to investments outside of the EU and the UK, given that the methodology to calculate inefficient real estate assets relies on EU-specific regulation1 and associated ratings (energy performance certificate, primary energy demand, nearly zero energy building), none of which are available in countries where assets under management are located outside of EU and the UK.
Based on the current draft of the RTS, CBRE GI Luxembourg AIFM expects to be able to comply with the RTS once they start to apply and to collate data for EU and UK real estate assets in respect of the first reference period (1 January 2022 to 31 December 2022). CBRE GI Luxembourg AIFM will continue to monitor the legislative progress of the RTS and, in particular, whether any clarity is achieved in relation to inefficient real estate assets for buildings outside of EU and the UK.
In the meantime, CBRE GI Luxembourg AIFM confirms that as a more general matter ESG considerations remain of great importance, including in the context of its investment decisions. Please see our Firm-wide ESG vision on CBRE Global Investors website for more detail.
 Directive 2010/31/EU of the European Parliament and of the Council of 19 May 2010 on the energy performance of buildings (recast)