EU Sustainable Finance Disclosure Regulation

This page contains certain disclosures required to be made pursuant to Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability‐related disclosures in the financial services sector (“SFDR“).

SFDR Entity-level Disclosures

Sustainability Risk Policies – Article 3 Disclosure

This disclosure applies to the following entities:

  • CBRE Investment Management EMEA AIFM B.V.
  • CBRE Investment Management Luxembourg AIFM S.à r.l.
  • CBRE Investment Management SGR p.A
  • CBRE Investment Management (UK Funds) Limited
  • CBRE Investment Management Indirect Limited


Together the “CBREIM Entities.

The CBREIM Entities are making the following disclosure pursuant to Article 3 of SFDR.

The CBREIM Entities consider that sustainability risks can have a material impact on investment performance and therefore consideration of sustainability risk is integral to the CBREIM Entities’ investment decision-making and investment management process.

The aforementioned considerations include the following key areas:

Strategic Risk Framework: the process through which risks surrounding an investment strategy can be assessed, monitored, reported and mitigated in a consistent manner;

House Views and Recommended Strategies: top-down house views and preferred strategies in light of current cycle positioning;

Investment Plan: plans prepared, adopted and updated as applicable for each mandate which set out the key objectives for a portfolio based on the current portfolio composition and past performance taking into account market forecasts and in-house tactical recommendations;

Investment Evaluation: the CBREIM Entities seek to apply an asset-class-specific set of criteria when evaluating assets and key counterparties. During the investment selection process, the relevant investment committee will assess the investment proposal and consider the findings of the due diligence screening and analysis. The materiality and relevance of a sustainability risk will vary depending on the specific asset class in question. Where applicable, the membership of each investment committee may include an ESG Team representative to support the investment committees and provide insight and oversight as required;

Asset Management: while an asset is held, ESG data is collected, monitored and assessed, and ESG action plans are developed as necessary; and

Reporting: as appropriate, ESG performance measurement and reporting is provided for each mandate and investment strategy.

Principal Adverse Impact Statements – Article 4 Disclosures

Remuneration Statement – Article 5 Disclosure

Disclosure pursuant to Article 5 of SFDR.

CBRE Investment Management has established remuneration policies (collectively, the “Policy") applicable to all group entities (together, “CBRE Investment Management EMEA” or the “Company") established in Europe, the Middle East and Africa (“EMEA"). The Policy is developed, approved, implemented and monitored by a series of bodies within the group structure, including in particular the boards of the entities in scope and relevant human resources and risk management departments. The Policy applies to all employees of CBRE Investment Management EMEA, save for limited exceptions.

The Policy has been developed with the aim of supporting the Company’s business strategy, corporate values and long-term interests, including by facilitating the identification, assessment and management of sustainability risks when determining individual remuneration packages. The key principles of the Policy include fostering an appropriate risk culture (including with respect to the management of actual and potential conflicts of interest) and compliance with applicable law and regulation.

The performance management and rewards framework envisioned by the Policy has been designed to promote effective risk management.

SFDR Product-level Disclosures

This disclosure applies to the following entities:

CBRE Investment Management EMEA AIFM B.V.
CBRE Investment Management Luxembourg AIFM S.à r.l.
CBRE Investment Management (UK Funds) Limited
(each such entity being a “Manager”)

The Manager manages (i) certain products which promote environmental and/or social characteristics and fall under Article 8(1) of SFDR; and (ii) certain products which have sustainable investment as their objective and fall under Article 9(1) of SFDR.  The disclosures required under Article 10(1) of SFDR and other information on sustainability-related matters in respect of such products can be found at the link immediately below. The Manager has taken measures to protect the confidentiality of the information contained in such disclosures.

SFDR Article 10 Disclosures