What are sustainability risks?

Sustainability risk is the risk arising from any environmental, social or governance events or conditions that, if they occur, could cause a material negative impact on the value of the investment. Specific sustainability risks will vary for each investment, and include but are not limited to the following:

Environmental risk: The risk posed by the exposure to issuers that may potentially be negatively affected by environmental degradation and/or the depletion of natural resources. Environmental risk may result from air pollution, water pollution, waste generation, depletion of freshwater and marine resources, loss of biodiversity or damages to ecosystems. Environmental risks may negatively affect the value of investments by impairing assets, productivity, or revenues, or by increasing liabilities, capital expenditures or operating and financing costs.

Transition risk: The risk posed by the exposure to issuers that may potentially be negatively affected by the transition to a low carbon economy due to their involvement in exploration, production, processing, trading and sale of fossil fuels, or their dependency upon carbon intensive materials, processes, products and services. Transition risk may result from several factors, including rising costs and/or limitations of greenhouse gas emissions, energy-efficiency requirements, reduction in fossil fuel demand or shift to alternative energy sources, due to policy, regulatory, technological and market demand changes. Transition risks may negatively affect the value of investments by impairing assets or revenues, or by increasing liabilities, capital expenditures or operating and financing costs.

Physical risk: The risk posed by the exposure to issuers that may potentially be negatively affected by the physical impacts of climate change. Physical risk includes acute risks arising from extreme weather events such as storms, floods, droughts, fires or heatwaves, and chronic risks arising from gradual changes in the climate, such as changing rainfall patterns, rising sea levels, ocean acidification, and biodiversity loss. Physical risks may negatively affect the value of investments by impairing assets, productivity, or revenues, or by increasing liabilities, capital expenditures or operating and financing costs.

Social risk: The risk posed by the exposure to issuers that may potentially be negatively affected by social factors such as poor labour standards, human rights violations, damages to public health, data privacy breaches, or increased inequalities. Social risks may negatively affect the value of investments by impairing assets, productivity, or revenues, or by increasing liabilities, capital expenditures or operating and financing costs.

Governance risk: The risk posed by the exposure to issuers that may potentially be negatively affected by weak governance structures. For companies, governance risk may result from malfunctioning boards, inadequate remuneration structures, abuses of minority shareholders or bondholders’ rights, deficient controls, aggressive tax planning and accounting practices, or lack of business ethics. For countries, governance risk may include governmental instability, bribery and corruption, privacy breaches and lack of judicial independence. Governance risk may negatively affect the value of investments due to poor strategic decisions, conflicts of interest, reputational damages, increased liabilities, or loss of investor confidence. The impacts of sustainability risks may vary depending on the nature of the risk, geographic region, or asset class. Generally, when a sustainability risk occurs for an asset, there will be a negative impact and potentially a partial or total loss of its value. However, the integration of sustainability risk analysis should mitigate the impact of such risks on the value of the investments and could help enhance long-term risk adjusted returns for investors.

Integration of Sustainability Risks at WRM Group

WRM Group recognises that environmental, social, and governance (“ESG”) factors can create sustainability risks which may materially affect the value of investments. In line with the requirements of the Sustainable Finance Disclosure Regulation (SFDR), the Group integrates the assessment and management of such risks into its investment decision-making processes and its governance framework.

Investment Decision-Making Process (Art. 3 SFDR)

Sustainability risks are defined under SFDR as environmental, social, or governance events or conditions which, if they occur, could have an actual or potential material negative impact on the value of an investment (Art. 2, para. 22).

In the context of WRM Group’s real estate investments, such risks may include:

  • Climate-related risks, such as sea level rise, flooding, landslides, or wildfires.
  • Regulatory and market risks, including new energy efficiency requirements for buildings, tenant well-being regulations, or shifts in customer preferences and behaviours.

If these risks materialise, they may reduce investment value through physical damage, increased renovation or operational costs, reduced attractiveness, or lower revenues.

To mitigate these risks, WRM Group integrates ESG considerations into all phases of the investment lifecycle:

  • Pre-acquisition: The Group conducts ESG screenings of potential assets to identify material sustainability risks before deciding whether to proceed with the investment.
  • Post-acquisition: The Group monitors exposure to sustainability risks on an annual basis at both the asset and fund level, using a series of Key Risk Indicators (KRIs).
  • Ongoing monitoring: The Group has initiated a digitalisation programme of its real estate portfolio, enabling the tracking of ESG performance metrics, including energy use, greenhouse gas emissions intensity, and vulnerability to physical climate-related risks.

Remuneration Policies (Art. 5 SFDR)

In accordance with Article 5 of the SFDR and Regulation (EU) 2021/1255, WRM Group is reviewing its remuneration policies to ensure consistency with the integration of sustainability risks.

The revised policies aim to align the interests of management and staff with sound and effective risk management practices, explicitly covering ESG-related risks. They apply to:

  • Top Management
  • Control Functions
  • Employees whose professional activities have a material impact on the AIFM’s risk profile

By embedding sustainability considerations into investment processes and remuneration structures, WRM Group reinforces its commitment to responsible investment practices and long-term value creation.

Remuneration Policy

Integration of Principal Adverse Impacts (PAIs)

At WRM Group, we recognise that investment activity can influence not only financial performance but also broader environmental, social, and governance (“ESG”) outcomes. The Sustainable Finance Disclosure Regulation (SFDR) requires financial market participants to assess and, where possible, disclose the principal adverse impacts (“PAIs”) of investment decisions on sustainability factors.

Our Current Position

In line with Article 4 SFDR, WRM Group has carefully evaluated its capacity to consider PAIs at the entity level. At this stage, WRM Group has opted for the “explain” approach, meaning that PAIs are not yet systematically considered. This decision is the result of two main challenges:

  • Access to reliable ESG data: Effective PAI reporting depends on high-quality and consistent information from multiple stakeholders. For example, in the real estate sector, accurate measurement of energy consumption requires the active cooperation of tenants, which is not always feasible today.
  • Internal resources and processes: Establishing a structured framework for collecting, processing, and reporting PAI indicators demands significant organisational capacity. WRM Group’s current structure is not yet fully equipped to support this on a systematic basis.

Building Towards Future Integration

Although PAIs are not formally integrated today, WRM Group has taken significant steps towards future integration. A key initiative has been the digitalisation of our real estate portfolio, which enables us to collect, process, and monitor ESG performance data more effectively across assets and funds. This platform will allow us to track metrics such as energy use, greenhouse gas (GHG) emissions, and exposure to physical climate risks.

Looking ahead, WRM Group expects to consider and report on PAIs from January 2027, initially focusing on its core business of real estate funds. The indicators that will be prioritised include:

  • Exposure to fossil fuel-related activities
  • Exposure to energy-inefficient real estate assets (Table 1, Annex I of the RTS)
  • GHG emissions and energy efficiency of portfolio assets (Table 2, Annex I of the RTS)

Over time, and depending on data availability and relevance, additional indicators may also be integrated to broaden the scope of PAI monitoring.

How This Fits into Our Broader ESG Framework

Our approach to PAIs complements the wider integration of ESG considerations across our investment and governance processes:

  • Investment process (Art. 3 SFDR): ESG factors are assessed from the pre-acquisition phase through to annual post-investment monitoring, using Key Risk Indicators (KRIs) to track potential sustainability risks.
  • Remuneration policies (Art. 5 SFDR): WRM Group is reviewing remuneration structures to ensure they align with the sound management of sustainability risks, encouraging responsible behaviours across management, control functions, and staff.
  • Portfolio management: The ongoing digitalisation of our real estate portfolio enhances transparency and provides the foundation for more robust ESG and PAI reporting in the future.

Commitment to Responsible Investment

While WRM Group does not currently consider PAIs in its investment decision-making processes, we are actively laying the groundwork to do so. The planned integration of PAI reporting from 2027 reflects our commitment to aligning with regulatory standards and to advancing a responsible investment strategy that balances financial objectives with sustainability outcomes.