E.S.G. POLICY

Environmental • Social • Governance

Our real estate business is subject to various sets of rules or regulations which minimise the environmental impact of buildings and their operation.

Our investment and management policy integrates criteria pertaining to the Environment, Social aspects and the quality of Governance.

Our aim is to optimise the financial performance of investments while integrating ESG criteria into investment decisions and the management of the real estate assets. This allows us to limit the risks of obsolescence or devaluation of the assets, failure to comply with regulations or poor positioning with respect to the demand by users and tenants.

From the time of its authorisation in April 2013, Atream has fixed its sustainable development objectives around the three E.S.G. pillars. To attain these objectives progressively, targets are set each year and are subject to an annual review.

ENVIRONMENTAL APPROACH

  • We systematically carry out technical audits and treat building-related pollution issues in order to control environmental risks:
    – technical and energy audits and pollution diagnostics to control environmental risks;
    – five-year works programmes integrating improvement plans for building energy efficiency;
    – energy performance audits during the acquisition due diligence phases for buildings which do not have specific certification (BBC, HQE) and which we intend to improve to obtain better energy performance.
  • Our team of asset managers keeps a regulatory watch in matters of the environment, thermal insulation, construction regulations etc.

SOCIAL APPROACH

  • Social criteria applied in managing the funds and the real estate assets:
    – we also assess the profile of incumbent tenants (corporate objects, activity) having regard to ESG criteria.
    – – we are attentive to the comfort and security of tenants (criteria included in our technical audits on acquisition) such as universal accessibility, availability of public transport and local services (shops, restaurants, whether there is a staff canteen, landscaped areas, etc.), and facilities for users (ventilation, heating etc.).
  • Criteria for the selection of service providers which may integrate their commitments concerning compliance with our sustainable development, good conduct and transparency policies.
  • In-house, Atream aims to maintain and develop the motivation of its employees, including by developing skills via training.

GOVERNANCE

Good conduct within Atream
Atream’s employees and directors have all read and accepted the terms the Code of Conduct for OPCIs (ASPIM/AFG) approved by the collegiate board of the AMF.

Atream has put internal procedures in place (management of conflicts of interest, customer relations, supplier relations etc.) in accordance with the main themes of the Code of Conduct for OPCIs.

Atream’s Governance
Atream is an independent company, owned by its founding members and managed by an Executive Committee.

As an AMF-authorised Management Company, our activity is subject to the AMF General Regulation and the French Financial Markets Code, and in particular the statutory requirements for communication to investors (transparency principle).

Anti-Money Laundering and Countering the Financing of Terrorism
Atream has provided itself with an organisation and internal procedures allowing it to ensure the identification and knowledge of its customers, the detection of atypical transactions and the declaring of suspicion for dubious transactions.

In accordance with regulations, all members of the personnel and every new arrival receive annual training on Anti-Money Laundering and Countering the Financing of Terrorism.

Internal control and compliance functions are outsourced to an external and independent firm of consultants, under the supervision of the Chairman of Atream who is also the Compliance Officer (Responsable de la Conformité et du Contrôle Internal – RCCI).