1. INTRODUCTION

As a real estate investment manager, Wanaka Fund Management acknowledges the importance of environmental, social and governance (“ESG”) matters as guiding principles for responsible investing. Wanaka Fund Management exclusively manages alternative investment funds (“AIF”) that invest in real estate assets (directly or indirectly), which has been taken into account in defining Wanaka Fund Management’s approach to integration of sustainability factors and risks in its investment decisions.

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 (the “SFDR”), aims at providing more transparency to investors on sustainability risk integration, on the consideration of adverse sustainability impacts in the investment processes and on the promotion of ESG factors in general. In particular, it requires financial market participants (which includes Wanaka Fund Management) to publish, on their websites, information concerning their policies on the integration of sustainability risks in their investment decision‐making process, how they consider principal adverse impacts of investment decisions on sustainability factors and how its remuneration policy is consistent with the integration of sustainability risks. Through this disclosure (the “Disclosure”), Wanaka Fund Management adheres to these SFDR requirements.

This Disclosure applies to Wanaka Fund Management and to any financial products in scope of the SFDR where Wanaka Fund Management acts as the AIF manager and undertakes the function of portfolio management.

In this section, the following terms shall be understood in accordance with the SFDR, namely:

"Sustainability risk" means an environmental, social or management situation or condition which, if it occurs, could cause an actual or potential material negative effect on the value of the investment. Sustainability risks can either represent a risk on its own or have an impact on and contribute significantly to other risks, such as market risks, operational risks, liquidity risks or counterparty risks.

"Sustainability factors" mean environmental, social and employee matters, respect for human rights, anti‐corruption and anti‐bribery matters.

2. SUSTAINABILITY RISK INTEGRATION (ART. 3 SFDR)

Wanaka Fund Management takes into consideration, on an ongoing basis, the sustainability risks that could directly or indirectly affect the value of the AIF’s it manages and the real estate assets held by such AIF’s. How sustainability risk is integrated in the investment decisions of Wanaka Fund Management are further described below.

Sustainability risks

Wanaka Fund Management has sought to identify sustainability risks which it assesses as relevant for its AIFs, split over “environmental risks”, “social impact risks” and “governance risks”. These sustainability risks may apply on manager, fund and/or asset level. When identifying the relevant sustainability risks, Wanaka Fund Management has taken into account that the AIFs under its management only invests in real estate assets (directly or indirectly).

The following types of sustainability risks have been assessed as likely to impact the return of the AIFs under Wanaka Fund Management’s management:

• Environmental risks include, but are not limited to, climate change risk (physical and transition), building energy-efficiency risk, waste & water management risk, carbon footprint risk and use of materials risk.
• Social risks include, but are not limited to, urban impact risk, user health & wellbeing risk, proximity of services & greenery risk and building connectivity risk.
• Governance risks include, but are not limited to, risks related to the selection of tenants and contractors, and the monitoring of ESG data as well as sustainability due diligence risk.

Wanaka Fund Management reassesses these main sustainability risks which it has identified on a continuous basis and may consider other sustainability risks in its investment decision-making process in the future. It shall further be noted that the degree to which sustainability factors are integrated into the investment decisions may vary according to the product's ESG targets as described in the relevant AIF’s investment strategy. As at the date of this Disclosure, none of the AIFs managed by Wanaka Fund Management have a specified sustainability objective as part of its investment strategy or otherwise.

Sustainability risk integration in investment decision-making process

Wanaka Fund Management exclusively manages AIF’s with strategies to invest (directly or indirectly) in different typologies of real estate assets. This has been taken into account when defining Wanaka Fund Management’s approach to integration of sustainability factors and risks in its investment decisions.

Wanaka Fund Management adopts an integrated ‘sustainable approach’ where ESG topics are considered at each step of the investment life cycle, from sourcing and acquisition to holding. It shall nevertheless be noted that the degree to which ESG aspects are integrated into the investment decisions may vary according to the AIF’s sustainability targets as described in its investment strategy (as relevant).

Wanaka Fund Management implements the following steps in the investment analysis and decision-making processes:

• Screening phase: The investment team of Wanaka Fund Management takes into account several factors when analysing potential investment opportunities, including sustainability factors. During this phase, the investment team makes an initial assessment of presence of sustainability exclusion factors which include indications of material land contamination, exposure to fossil fuel production and tenants active in certain undesired industries. If the presence of exclusion factors are identified, a potential investment shall not be pursued further.
• Acquisition phase: This phase consists of two phases; the pre-due diligence and the due diligence phase. During the pre-due diligence phase, an initial light ESG assessment is made by the investment team based on the investment and sustainability strategy of the AIF as well as the main sustainability risks (as outlined above). This initial ESG assessment is further completed during the due diligence phase. During the due diligence phase, a further deep dive is done into the initial ESG assessment as part of the technical due diligence exercise as well as through further investigation by the investment team. If an AIF has a specific ESG objective, additional due diligence may be done on certain ESG factors in order to assess such specific objectives (Wanaka Fund Management does not currently manage any AIFs with such specific ESG objectives). Based on the results from the final ESG assessment, recommendations are formulated as to how to improve the sustainability performance of the real estate asset (where deemed necessary). These recommendations are integrated into a sustainability plan for the asset as well as to the business plan. The results shall be presented to the investment committee of Wanaka Fund Management as part of the final investment proposal when the contemplated investment is presented for consideration.
• Holding and monitoring phase: At the start of the holding and monitoring phase, a final sustainability plan (where relevant, based on the sustainability plan created during the acquisition phase as mentioned above) is created, which sets out the main sustainability ambitions during the holding period. The sustainability plan(s) of each AIF is then implemented and continuously monitored by internal and/or external management teams, including asset and property managers (as relevant), under the overall responsibility of the fund management team of Wanaka Fund Management. On an annual basis the sustainability plan(s) of each AIF is reviewed and revised where necessary due to for example identification of new sustainability risks. It shall be noted that the sustainability plans are only setting out the ambitions of each AIF while actual results may deviate from the ambitions.

3. PRINCIPAL ADVERSE SUSTAINABILITY IMPACTS STATEMENT (ART. 4 SFDR)

In accordance with the SFDR, financial market participants are required to disclose whether they consider principal adverse impacts of their investment decisions on sustainability factors and, if so, include a statement on their due diligence policies regarding such impacts.

3.1 Principal adverse sustainability impacts indicators

Pursuant to article 4(1) (a) of the SFDR, Wanaka Fund Management states that it considers principal adverse impacts of investment decisions on sustainability factors. Principal adverse sustainability impacts should be understood as impacts of investment decisions that result in negative effects on sustainability factors relating to environmental, social and employee matters, respect for human rights, anti-corruption and anti-bribery matters.

As previously mentioned in this Disclosure, Wanaka Fund Management and the AIFs that it manages specializes in real estate investments. The specific characteristics of real estate assets have been recognized in the regulatory technical standards established in the Commission Delegated Regulation (EU) 2022/1288 of 6 April 2022 (the “RTS”).

Adhering to the RTS, Wanaka Fund Management will in particular review the principal adverse sustainability impact of its investments decisions on, without limitation, the following indicators, at the screening/acquisition phase as well during the holding and monitoring phase:

• Exposure to fossil fuels through real estate assets, share of investments in real estate assets involved in the extraction, storage, transport or manufacture of fossil fuels.
• Exposure to energy-inefficient real estate assets, share of investments in energy inefficient real estate assets, based on the EPC or NZEB score of a building.
• Energy consumption intensity, sum of gas and power consumptions in GWh per m².

The impacts above are considered as part of Wanaka Fund Management’s due diligence process (as described in section 2 of this Disclosure), and where such principal adverse sustainability impacts have been identified, they can either function as an exclusion factor (as in the case concerning real estate assets involved in the extraction, storage, transport or manufacture of fossil fuels) or will be analysed for potential mitigative actions which could be considered in the relevant sustainability plan and business plan for such investment where appropriate.

In general, Wanaka Fund Management takes the following actions to identify, assess, measure and monitor the relevant principal adverse sustainability impacts:

• Principal adverse sustainability impacts are analysed and identified as part of the due diligence process for potential investments as described above in section 2 of this Disclosure.
• If identified, the principal adverse sustainability impact will either (i) function as an exclusion factor which means that a potential investment cannot proceed (this is the case for real estate assets involved in the extraction, storage, transport or manufacture of fossil fuels), or (ii) be assessed and measured to further understand exact impact, and possible mitigative actions are explored. The conclusions of this step (including presence of exclusion factors as well as possible mitigative actions) shall be presented to the investment committee of Wanaka Fund Management when the contemplated investment is presented for consideration.
• Principal adverse sustainability impacts and the progress on mitigative actions (taken into account in the relevant sustainability plan and business plan), where relevant, are continuously monitored throughout the holding period. If further needs for mitigative actions or additional principal adverse sustainability impacts are identified during such monitoring, it shall be reflected and considered in the (annually) revised sustainability/business plan as relevant.

3.2 Responsible business conduct codes and internationally recognised standards for due diligence and reporting

At the date of this Disclosure, Wanaka Fund Management does not formally adhere to any of the responsible business conduct codes and internationally recognised standards for due diligence and reporting.

4. INTEGRATION OF SUSTAINABILITY RISKS IN THE REMUNERATION POLICY (ART. 5 SFDR)

Pursuant to the SFDR, Wanaka Fund Management is required to explain how its remuneration policy is consistent with the integration of sustainability risks. Wanaka Fund Management considers sustainability risks in its remuneration policy by ensuring that performance is evaluated on a number of key principles, such as, for example:

• Remuneration should be consistent with and promote sound and effective risk management; amongst other through encouraging risk-taking approaches which are consistent with the risk profile (which covers for example sustainability risks) or fund documentation of the AIFs managed by Wanaka Fund Management.
• Use of both quantitative (financial) as well as qualitative (non-financial) criteria for assessing individual performance, which will include ESG criteria (such as the integration of sustainability risks into the investment decisions; and adherence to Wanaka Fund Management’s sustainability policies and standards).

5. PRODUCT LEVEL DISCLOSURES

At the date of this Disclosure, none of the AIFs managed by Wanaka Fund Management have a specified sustainability objective as part of its investment strategy or otherwise. The current products neither promote environmental or social characteristics (article 8 SFDR), nor have an objective to invest in sustainable investments (article 9 SFDR). Thus, each of the current AIFs managed by Wanaka Fund Management shall disclose under article 6 of the SFDR. However, it is likely that Wanaka Fund Management will manage AIFs that will disclose under article 8 or 9 of the SFDR in the future and the Disclosure will be updated accordingly at such time.

Nevertheless, Wanaka Fund Management acknowledges that sustainability risks can represent a risk of their own with a potential material negative effect on the value of the assets held by the AIF under its management or have an impact on other risks and may contribute significantly to risks, such as market risks, operational risks, liquidity risks or counterparty risks. Wanaka Fund Management therefore believes that the integration of sustainability risks in the investment process and the regard of principal adverse sustainability impacts are crucial in order to generate sustainable long-term risk adjusted returns for investors in accordance with the respective AIFs strategies and business plans.

Wanaka Fund Management therefore integrates sustainability risks into its investment decisions of all AIFs for which it undertakes portfolio management, as described above in this Disclosure. The principles related to principal adverse sustainability impacts as described above in this Disclosure apply for these funds but no specific disclosure per fund will be made as all these funds currently disclose under article 6 of the SFDR.

This Disclosure is published on the website of Wanaka Fund Management on 18/06/25. The former versions of the Disclosure are available upon request.

Last updated on 18/06/2025.