Regulatory
Informations

In accordance with applicable regulations, SCAPRIM REIM has established and maintains an operational procedure aimed at handling complaints from its clients in an efficient, rapid and transparent manner.

Any client or shareholder wishing to address a complaint to SCAPRIM REIM is invited to send a letter to the following address

SCAPRIM REIM
52 B rue de la Bienfaisance
75008 Paris

A complaint may also be sent to SCAPRIM REIM by e-mail to the following address: contact@scaprimreim.com. The client or shareholder is then invited to provide his contact details (postal address, email address, telephone).

SCAPRIM REIM undertakes to acknowledge receipt of the complaint within ten working days of receipt of the complaint, unless the reply itself is provided to the client within this period, and to reply to the client within two months of receipt of the complaint, except in the event of duly justified special circumstances.

In the event of dissatisfaction with the response to the complaint, the client or shareholder is invited to refer the matter to the mediator of the Autorité des Marchés Financiers at the following address

Autorité des marchés financiers
Mediator of the AMF
17 place de la Bourse
75082 Paris Cedex 02

The AMF mediation request form and the mediation charter are available on the website: www.amf-france.orgunder the heading “mediation”. It is also possible to submit a request via an electronic form on the same AMF website.

SCAPRIM REIM has implemented a system for managing conflicts of interest in accordance with AMF regulations. Within this framework, SCAPRIM REIM establishes and maintains an effective conflict of interest management policy which is set out in writing and is suited to its size, organization, nature, importance and the complexity of its activity.

This policy ensures that conflicts of interest are prevented, identified and dealt with so that they do not adversely affect the interests of clients and shareholders, thereby avoiding any reputational risk for the company.

In order to ensure the effective and rapid detection of any proven cases of conflicts of interest, SCAPRIM REIM’s employees are informed of the preventive measures put in place, the internal rules to be respected and the tools and support available to them to assist them in their vigilance mission.

The procedure for identifying and managing conflicts of interest aims to identify situations that lead, or are likely to lead, to a conflict of interest, in order to find a solution that guarantees the primacy and preservation of the interests of clients and investors.

SCAPRIM REIM has identified potential conflicts of interest of a general nature and those specific to the organization in place and the activities carried out.

When the measures adopted are not sufficient to guarantee with reasonable certainty that the risk of harming the interests of clients will be avoided, SCAPRIM REIM clearly informs them, before acting on their behalf, of the general nature or source of these conflicts of interest.

Finally, SCAPRIM REIM keeps and regularly updates a register recording the types of investment or related services or other activities carried out by it or on its behalf for which a conflict of interest involving a significant risk of prejudice to the interests of one or more of its clients has arisen or, in the case of an ongoing service or activity, is likely to arise.

Information as of 03/10/2021 on the Disclosure Regulation

In order to commit European finance to sustainable development and so as to define its practices, the European Commission has developed a specific regulatory framework for financial products, consisting of several components. The Disclosure Regulation (or SFDR) No. 2019/2088 of November 27, 2019 is one of these components. It creates new transparency obligations in terms of non-financial communication, for fund management companies and for the products they manage.

It is applicable for the most part since March 10, 2021.

Below you will find information on the sustainability risks taken into account in investment decisions, on how SCAPRIM REIM takes into account the main negative impacts, and on the integration of sustainability risks in its remuneration policy.

A. Sustainability risks factored into investment decisions

Declination Application by SCAPRIM REIM
I – Physical risks
Climate change
For real estate investment funds committed to an ESG approach, SCAPRIM REIM will conduct a risk exposure analysis for each asset likely to be acquired, prior to the investment decision. The purpose of this analysis will be to measure the building’s capacity to ensure continuity of service with or without additional investment.

SCAPRIM REIM, for its funds committed to an ESG approach, will measure the exposure of the assets to the various physical risks according to a regularly updated methodology.

SCAPRIM REIM will adopt a diagnostic approach for all real estate assets held directly or indirectly by the funds it manages, in order to be able to take the necessary measures to ensure their sustainability. This approach is in its infancy in the sector as a whole, and SCAPRIM REIM is committed to a long-term vision of the sustainability of investments under management. Thus, the objective set by SCAPRIM REIM is to have a mapping of the exposure to physical risks on more than 90% of its assets by the end of 2024, and to have identified action plans to reduce this risk by the end of 2028.

Loss of biodiversity As regards real estate investment funds committed to an ESG approach, SCAPRIM REIM will take into account the negative impact of its activities on the loss of biodiversity.
II – Transition risks
Climate change mitigation
As regards real estate investment funds committed to an ESG approach, SCAPRIM REIM will set up a monitoring of the energy performance of its assets.

In addition, SCAPRIM REIM already complies with the provisions of the “tertiary decree” for each asset concerned held directly or indirectly by a fund it manages.

SCAPRIM REIM has launched an initiative to measure the energy consumption of all the assets held directly or indirectly by the funds it manages. In addition to meeting regulatory requirements, the objective is to identify real estate assets that could be exposed to this risk and to define the appropriate actions to be taken.

Adaptation to climate change Cf. Physical risks: climate change
Transition to a circular economy
The main activity of the funds managed by SCAPRIM REIM concerns the management of real estate assets already built at the date of their acquisition. SCAPRIM REIM therefore does not currently consider this risk to be significant for the valuation of its assets.

SCAPRIM REIM is initially committed to respecting French regulations, which are already demanding on this point, and is studying the possibility of making extra-regulatory commitments of its own.

SCAPRIM REIM will require its service providers, in particular developers, construction companies and technical service providers, to study the reuse and recovery of waste for any development project involving real estate assets managed directly or indirectly by the funds it manages.

Pollution prevention and control During the process of acquiring a real estate asset, SCAPRIM REIM will analyze the history of soil pollution and take into account the risk of additional pollution in its investment analysis.
Protection and restoration of biodiversity and ecosystems. The main activity of the funds managed by SCAPRIM REIM concerns the management of real estate assets already built at the date of their acquisition. By 2024, SCAPRIM REIM will implement an ecological study procedure on the preservation of biodiversity for all acquisitions of building development projects, or land to be built.
III – Litigation and liability risks
– As regards real estate investment funds committed to an ESG approach, SCAPRIM REIM will integrate the consideration of the main negative impacts on the environment and/or society, and will commit to a continuous improvement approach beyond the regulations.

B. Consideration of key negative sustainability impacts

Negative sustainability impacts represent the potential impacts of investments on external sustainability factors. Thus, it is a matter of identifying and controlling the possible prejudices that could be generated by the real estate investments made by SCAPRIM REIM, on environmental and social factors.

With regard to real estate investment funds committed to an ESG approach, SCAPRIM REIM wishes to take into account the negative impact on the sustainability of the assets it manages. To this end, it intends to take an active approach to reducing the environmental impact and improving the societal impact of these funds’ assets.

This will aim to limit the potential negative impact of sustainability risks on the performance of the real estate product. Thus, for these funds, during the acquisition and management phases of a building, SCAPRIM REIM will take into account and monitor the following impact indicators:

Energy performance
Greenhouse gas emissions
Actions in favor of biodiversity
Controlling water consumption
The proximity of alternative modes of transportation to the private car
Thermal comfort and quality of life for the occupants
The use of local service providers
Tenant satisfaction
The contribution to the supply of housing in dense areas
The commitment of the service providers
Raising occupants’ awareness of good environmental and social practices
Asset resilience to climate risks
C. Integrating sustainability risks into compensation policy

Within the framework of individual and collective objectives, SCAPRIM REIM is committed to setting up, by the end of 2022, quantitative and/or qualitative objectives adapted to each position involved in investment and management decisions, so that each actor is aware of the notion of sustainability risk and can contribute to the long-term and very long-term performance of SCAPRIM REIM’s investments.

In accordance with the applicable regulations, information on SCAPRIM REIM’s remuneration policy is published each year in the AIF’s periodic reports.