About

Libertas – SGOIC, S.A. recognizes that the activity of managing real estate and venture capital investment organizations entails sustainability risks.
Under Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 (SFDR), a sustainability risk means an environmental, social, and governance (ESG) event or condition that, if it occurs, could cause an actual or a potential material negative impact on the value of the investment. It is relevant to Libertas – SGOIC, S.A.’s activity, in particular, without prejudice to others, the ecological impact, the exposure to fossil fuels, or the energy efficiency of real estate developments.
Libertas – SGOIC, S.A., as a diligent and careful management entity, in performing the mandates attributed to it under the management regulations, must consider the various risks that may be relevant for the investments made by collective investment undertakings managed by it, including sustainability risks that may exist.
Our investment decision-making process is based on the following general principles:
- Commitment: It is our responsibility to identify and monitor not only the more traditional risks (such as market, credit, liquidity, and operational risks, among others) that may impact the value of investments but also the above-mentioned sustainability risks that may also impact them.
- Adaptability: Libertas – SGOIC, S.A. accepts the requirements arising from the sustainability regime in adapted terms to the real estate and venture capital investment organizations under its management, in accordance with the characteristics described in their respective constituent documents.
- Proportionality: As with the remaining risks, sustainability risks are weighted according to the nature and complexity of Libertas – SGOIC, S.A.’s activities.
These principles are applied throughout the various stages of the decision-making process:
- Screening: In the process of detecting possible investment opportunities, based on publicly available information and/or from third parties, including specialized service providers, exposure to sustainability risks will also be considered. As an ancillary element, lists of activity sectors more and less exposed to this type of risk could be elaborated and updated from time to time.
- Investment analysis: The information gathered in the previous stage will be complemented, whenever appropriate, with additional elements of information, namely from the target company itself, which will allow a more detailed assessment of the existence of such risks.
- Due Diligence: Whenever appropriate and when conducted in collaboration with external consultants, due diligence processes must take into account such risks in the analysis undertaken and suggest mitigation measures.
- Investment decision: The information collected and analyzed in the previous stages, in relation to sustainability risks, must be considered in the decisions to be adopted, including the implementation of appropriate mitigation measures if these risks are detected, such as through shareholder engagement with the target company.
- Portfolio monitoring: Among the matters subject to regular monitoring throughout the duration of the investments, sustainability risks will be considered, whenever relevant, and the respective mitigation measures will also be reviewed, when convenient.
Accordingly, the impact of such risks on the value and return of the investments shall be assessed case-by-case, being to such extent integrated into the investment decision process of Libertas – SGOIC, S.A. as a management entity.

Libertas – SGOIC, S.A. recognizes that the remuneration policy plays a central and important role in aligning the relevant interests, namely those of investors and other stakeholders, and should also be able of ensuring appropriate conditions for the implementation of fair remuneration, capable of attracting, retaining and motivating our managers and employees. In turn, Libertas – SGOIC, S.A. analyses and determines the sustainability factors that are relevant to its activity and whether they are compatible with its long-term business interest and vision, as well as with sustainable investment.
Libertas – SGOIC, S.A. integrates in its Remuneration Policy:
- The sustainability risks, given the nature, scale, and complexity of its activities.
- Compensation structures that aim to optimize results in generating or exacerbating risks that may harm their and their participants’ long-term interests.
By applying mechanisms that allow for changes in the remuneration structure, Libertas – SGOIC, S.A. seeks to ensure the implementation of appropriate incentives to take precautions and mitigate risks, including those related to sustainability.

Libertas – SGOIC, S.A. does not consider the adverse impacts of investment decisions on sustainability factors and it does not meet the requirements for large financial market participants set out in Article 4(3) and (4) of the SFDR.
Without prejudice to its diligent and careful action under the mandates assigned to it under the management regulations, Libertas – SGOIC, S.A. does not take into account the adverse impacts of investment decisions on sustainability factors for the following reasons:
- We do not manage collective investment undertakings that fall within the scope of Article 8 or Article 9 of the SFDR.
- The investments underlying the collective investment undertakings under our management do not take into account the European Union criteria for environmentally sustainable economic activities.
- Considering the type of investments made by our collective investment undertakings, the level of public information available on ESG, in particular in regard to the indicators listed in Annex I of the Commission Delegated Regulation (EU) 2022/1288 of 6 April 2022, is not sufficient, which prevents a reasonable and adequate consideration of the adverse impacts of investment decisions on sustainability factors based on that information.
- As there are no sufficient public sources of information on this matter, the consideration of the adverse impacts of investment decisions on sustainability factors would imply obtaining this information externally, either through service providers or by the invested companies, but even in this way, it is anticipated that in many cases the available information would be insufficient, considering the companies where the investments are typically made. Thus, not only would this process entail excessive and disproportionate costs for Libertas – SGOIC, S.A. and its collective investment undertakings, but also the necessary result for the effective consideration of these adverse impacts would not be assured.
If in the future the circumstances listed above change, Libertas – SGOIC, S.A. may reconsider this matter and, in such case, will inform, in a timely and appropriate manner, its investors and other stakeholders of any such change, but it is not possible, at this time, to anticipate a specific date for this purpose.