IT

POLICY

CODE OF ETHICS AND COMMITMENT

Our Code of Ethics captures the values that inspire us and to which we are committed. It stems from the goals we have set for ourselves and outlines a system of rules to which all those who work in the interests of the Company must adhere to. Redo is constantly seeking ways and solutions to have a positive impact on the lives of people and cities, on social and labor dynamics, on democratic institutions, and ultimately on the planet.

These principles form the basis of Redo's statute, values, and development strategy, both as a company and as managers of social impact real estate investments.

Ethical principles:
Legality, transparency, integrity, fairness, dignity and equality,
professionalism and cooperation

Common Benefit Purposes:

1. Pursue a positive impact for people who cannot afford residential market rents for adequate housing and/or student accommodation;


2. Pursue a positive impact in communities and neighbourhoods through urban regeneration, creation and recovery of relationships between people, enhancement of third sector entities and services offered to the community and the neighborhood;

3. Minimise the negative impact on natural resources by implementing a progressive transition to a climate neutral economy, both in its internal management activity and in the supply chain and consequent realization of real estate projects, in line with European, national and regional objectives of climate neutrality and ecological transition;

4. Promote solutions that generate a positive impact in the area of real estate development and regeneration;

5. Promote the involvement of its employees in the pursuit of corporate targets, as well as the pursuit of their working, personal and family welfare.

These principles form the basis of Redo's statute, values, and development strategy, both as a company and as managers of social impact real estate investments.
SUSTAINABLE INVESTMENTS
WHAT IS A SUSTAINABLE INVESTMENT?
An investment is sustainable if it significantly contributes to the achievement of environmental and/or social goals (for example the use of renewable energy or the promotion of social integration), as outlined in Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 (“SFDR”)

IL NOSTRO IMPEGNO

Redo ricerca costantemente modalità e soluzioni che consentano di avere
un impatto positivo sulla vita delle persone e delle città, sulle dinamiche
sociali e del lavoro, sulle istituzioni democratiche e, in ultima istanza, sul
pianeta.
Tali princìpi sono alla base dello Statuto, dei valori di Redo e della strategia
di sviluppo della Sgr
, sia come società che come gestori di investimenti
immobiliari a impatto sociale.

THE ANNUAL IMPACT REPORT

Through the Annual Impact Report, we are able to show how our actions towards people isresponsible and transparent, as it is towards communities, territories, environments, entities, associations, workers, suppliers, final clients and civil society. The Report illustrates how, in the financial analysis and in the investment decisions, Redo takes into consideration Environmental, Social and Governance factors (namely the ESG criteria that guide sustainable investments).

SUSTAINABLE FINANCE DISCLOSURE REGULATION (SFDR) - REDO'S ACTIVITY

As explicitely required by the EU Regulation 2019/2088 on on sustainability‐related disclosures in the financial services sector (SFDR), in relation to:
  • the adoption of sustainability risk policies at Entity level (art. 3);
  • whether the Sgr considers principal adverse impacts of investment decisions on sustainability factors (art. 4);
  • the integration of sustainability risks and opportunities in the remuneration policy (art. 5);

the following should be noted.

Art. 3 SFDR

The Company has adopted the Policy for the integration of sustainability risks and opportunities into investment decisions, conscious that environmental, social and governance (ESG) factors represent not only risks but real opportunities to achieve those impacts that are essential to the attainment of the common-benefit goals that Redo, as a Benefit Company, natively pursues.

Art. 4 SFDR

Redo, also as a member company of the United Nations Global Compact, observes the codes of conduct for responsible business and internationally recognised standards of due diligence and reporting and, as indicated in the fourth Common Benefit objective in its Articles of Association, pursues the goal of climate neutrality in accordance with the objectives set by the European Union in line with the Paris agreements. To this end, the Company considers the principal adverse impacts on sustainability factors arising directly or indirectly from real estate investment choices, adopting appropriate due diligence policies.

In the Policy for the integration of sustainability risks and opportunities into investment decisions, Redo applies, among other measures, negative screening on the selection of counterparties and real estate investment activities based on specific binding and non-binding exclusion criteria, including activities involving the extraction, storage, transport or production of fossil fuels.

Redo also collects and monitor energy consumption data in order to achieve optimal energy efficiency performance through a digital Environmental Management System that is aligned to the ISO 14001 framework standard, to reduce the greenhouse gas emissions of the assets in the portfolio, and to raise tenants’ awareness and responsibility regarding the environmental and economic footprint of their consumption.

With reference to the Principal Adverse Impact indicators foreseen in the European legislation currently adopted by the European Commission and in the stage of approval by the European Parliament and the Council (Delegated Regulation 2022/1931 of 6 April 2022, not yet published in the Official Journal, will be in force as of 1 January 2023. Available at: https://ec.europa.eu/info/business-economy-euro/banking-and-finance/sustainable-finance/sustainability-related-disclosure-financial-services-sector_en), Redo has started monitoring the PAI applicable to the sector. Starting 1 January 2023, disclosure will be duly provided and regular updates will be posted on the website, in line with the applicable regulatory requirements.

Art. 5 SFDR

Shareholders’ Assembly approved the Sgr Remuneration and Incentive Policy, which, also through the incentive plan, integrates sustainability risks for the achievement of social and environmental performance.

The Policy aims to encourage the pursuit of annual and multi-year objectives as outlined in the medium to long-term strategy and to contribute to the creation of shared value for the Company and its shareholders, as well as for all stakeholders. In particular, Redo’s sustainable strategy aims to create value through, among others, the integration of the SDGs and relevant ESG factors in the scope of activities of the SGR and the managed AIFs.

More specifically, Redo has based its business strategy on consistency with its social impact vocation, pursuing the promotion of real estate initiatives that contribute to increasing the supply of social housing (“Affordable housing”), in the urban regeneration field with a social impact and/or content, while respecting environmental sustainability to create value for the diverse stakeholders, and, in particular:
  • social, by promoting inclusion based on social cohesion and social integration and investment in human capital or economically or socially disadvantaged communities;
  • environmental, by promoting decarbonisation, the use of renewable energies and pursuing a positive impact on biodiversity and the circular economy, including the responsible use of raw materials, water resources, soil, in addition to the reduction of waste production and greenhouse gas emissions.
In this context, both short- and medium- to long-term strategic objectives underlying the incentive systems are directly related to the goals described.

SHOW MORE

MODELLO ORGANIZZATIVO 231

Redo has adopted its own Organisational Model, with the aim of building a structured and organic system of guiding principles, operating procedures and other specific safeguards.

Legislative Decree No. 231 of 8 June 2001 introduced into the Italian legal framework a system of administrative liability of entities – including corporations – for certain violations committed by directors, managers or employees in the interest or to the advantage of the entity itself. Redo has adopted its own Organisational Model, with the aim of constructing a structured and organic system of guiding principles, operating procedures and other specific safeguards, inspired by criteria of sound business management and aimed, inter alia, at preventing the commission of the offences provided for in the Decree. Redo has entrusted a Supervisory Board with the task of monitoring compliance with the provisions of the Organisational Model, verifying their actual effectiveness and assessing the need for any updates. The term of office of the Supervisory Board is three years.

SHOW MORE

PRIVACY E DATA PROTECTION

Redo has decided to adopt the "Policy on the Processing of Personal Data" in order to ensure its own compliance and that of its employees and contractors in any capacity, with the applicable legislation on the protection of personal data.
In light of the importance of the changes brought about by the General Data Protection Regulation or GDPR (EU) no. 2016/679 and the subsequent Legislative Decree 101/2018 issued by the Italian legislator to implement the amendments necessary to adapt the national legislation on personal data, Redo has decided to adopt the “Policy On The Processing Of Personal Data” in order to ensure its own compliance and that of its employees and collaborators in any capacity, with the applicable legislation on the protection of personal data.


To this end, Redo ensures that it always makes available to its employees and collaborators the most up-to-date version of this Policy and organises training courses on the principles of the GDPR and the content of the Policy itself.


To exercise their rights and for any questions or clarifications on how their personal data are processed and used by Redo, data subjects may contact the e-mail address privacy@redosgr.it.


All data provided will be processed exclusively for the purpose of providing prompt feedback and to ensure the proper handling of requests from data subjects.
SHOW MORE