The following information has been prepared in accordance with the Regulation (EU) 2019/2088 of 27 November on sustainability-related disclosures in the financial services sector (Sustainable Financial Disclosure Regulation, SFDR), as supplemented by the Delegated Regulation (EU) 2022/1288. It is important to note that this disclosure requirement applies specifically to Asterion Industrial Infra Fund II FCR, which is classified as an Article 8 fund under the SFDR. Please be aware that Asterion Industrial Infra Fund I FCR, despite sharing the same investment strategy and following the same ESG processes as Fund II, does not have a formal SFDR classification.
A. Summary
Asterion’s Funds promote environmental and/or social characteristics but do not have sustainable investments as their objective. Asterion’s investment strategy is based on infrastructure investments in the European mid-market, mainly focused on the telecom, energy & utilities and mobility sectors, across Iberia, Italy, France, and the UK (opportunistically rest of Europe).
Infrastructure assets, businesses and projects provide a public good as well as having an important and direct impact on economic growth, society, suppliers, customers, employees, and environment in the communities in which they operate. Through our investment themes and the management of our portfolio companies, we aim to contribute to the energy transition and the development of energy efficient solutions, as well as developing new and cleaner mobility trends and providing digital access and connectivity to all, including rural and remote areas that had no previous connection.
Asterion’s responsible investment management is based on the firm’s Responsible Investment Policy (RI Policy) which describes Asterion’s commitment to integrate a responsible approach to the investment process, as well as the management of its own operations through the consideration of environmental, social and governance (ESG) factors. As included in the RI Policy, Asterion does not invest in companies that are involved in controversial behaviour and/or products, including guidelines by internationally recognized human rights principles. Furthermore, it does not invest in companies directly associated with tobacco, alcohol, adult entertainment, weapons, and gambling. To ensure a comprehensive analysis, the investment team, with the support of the ESG Team, engages external experts who specialize in ESG assessments to perform due diligence before every acquisition. This due diligence allows to identify any red flags that may hinder our investment and to identify the most relevant aspects that should form the basis of our post-acquisition plan to enhance the target company's ESG management.
Asterion, by means of its active asset management strategy is well positioned to significantly increase ESG awareness and to implement best-in-class corporate governance practices and structures which lead to improve ESG related matters in its portfolio companies. As part of the investment process, all portfolio companies are required to actively manage ESG to meet Asterion’s standard requirements and are encouraged to prioritize key ESG aspects as part of the core strategy of their business. Asterion’s standard requirements include:
In addition to the above indicated, Asterion considers the principal adverse impact indicators on sustainability factors when making investment decisions. To this end, it monitors environmental and social indicators, including those outlined in table one, as well as two optional indicators listed in tables 2 and 3 of Annex I of the RTS. These indicators, derived from the disclosed information of the companies within the Fund's portfolio, facilitate an assessment of the potential negative consequences that the Fund's investments may have on external parties.
Information on the principal adverse impact indicators considered is reported in the ESG Annual Report, and we are dedicated to upholding this annual reporting commitment to maintain full transparency. For further detail, please refer to the last section of the report. Note that principal adverse impact indicators have also been published for Asterion’s Fund I despite not having a formal SFDR classification.
Infrastructure assets, businesses and projects provide a public good as well as having an important and direct impact on economic growth, society, suppliers, customers, employees, and environment in the communities in which they operate. Through our investment themes and the management of our portfolio companies, we aim to contribute to the energy transition and the development of energy efficient solutions, as well as developing new and cleaner mobility trends and providing digital access and connectivity to all, including rural and remote areas that had no previous connection.
Asterion’s responsible investment management is based on the firm’s Responsible Investment Policy (RI Policy) which describes Asterion’s commitment to integrate a responsible approach to the investment process, as well as the management of its own operations through the consideration of environmental, social and governance (ESG) factors. As included in the RI Policy, Asterion does not invest in companies that are involved in controversial behaviour and/or products, including guidelines by internationally recognized human rights principles. Furthermore, it does not invest in companies directly associated with tobacco, alcohol, adult entertainment, weapons, and gambling. To ensure a comprehensive analysis, the investment team, with the support of the ESG Team, engages external experts who specialize in ESG assessments to perform due diligence before every acquisition. This due diligence allows to identify any red flags that may hinder our investment and to identify the most relevant aspects that should form the basis of our post-acquisition plan to enhance the target company's ESG management.
Asterion, by means of its active asset management strategy is well positioned to significantly increase ESG awareness and to implement best-in-class corporate governance practices and structures which lead to improve ESG related matters in its portfolio companies. As part of the investment process, all portfolio companies are required to actively manage ESG to meet Asterion’s standard requirements and are encouraged to prioritize key ESG aspects as part of the core strategy of their business. Asterion’s standard requirements include:
- The definition of an internal ESG governance structure (ESG team or ESG responsible, ESG Committee or forums where ESG decisions are made, involvement of the Board of Directors).
- Development of a minimum set of internal policies (including anti-corruption & bribery, health & safety, internal code of conduct, risk management, business continuity, AML, ESG, supply chain, diversity and inclusion, among others).
- Definition and implementation of an ESG Action plan (including at least aspects such as emissions reduction, diversity & inclusion and shared success).
- Reporting requirements including a “contribution KPI” related to the business activity as well as a set of additional KPIs including PAIs as per SFDR regulation.
In addition to the above indicated, Asterion considers the principal adverse impact indicators on sustainability factors when making investment decisions. To this end, it monitors environmental and social indicators, including those outlined in table one, as well as two optional indicators listed in tables 2 and 3 of Annex I of the RTS. These indicators, derived from the disclosed information of the companies within the Fund's portfolio, facilitate an assessment of the potential negative consequences that the Fund's investments may have on external parties.
Information on the principal adverse impact indicators considered is reported in the ESG Annual Report, and we are dedicated to upholding this annual reporting commitment to maintain full transparency. For further detail, please refer to the last section of the report. Note that principal adverse impact indicators have also been published for Asterion’s Fund I despite not having a formal SFDR classification.
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B. No sustainable investment objective
Asterion’s financial products promote environmental or social characteristics but do not have as its objective a sustainable investment.
C. Environmental or social characteristics of the financial product
Asterion promotes environmental and social characteristics within its investment strategy, leveraging infrastructure investments to provide critical public services for societal development and well-being. Asterion’s investment strategy places a strong emphasis on supporting the energy transition, enhancing energy efficiency, bridging the digital divide between rural and urban areas and fostering sustainable and efficient mobility and transportation solutions.
Additionally, given Asterion’s active management approach, it also promotes the improvement of environmental, social, and governance (ESG) performance within its portfolio companies, ensuring responsible and sustainable practices.
As included in the legal documentation of the funds, Asterion prioritises investments in companies with an economic activity that actively promotes social and/ or environmental characteristics, that are aligned with key societal trends as described above, as well as with the United Nations Sustainable Development Goals for 2030 (SDGs), while satisfying the return objectives of the funds.
Regarding its contribution to the SDGs, and in addition to other SDG goals, Asterion’s investment strategy primarily aligns with SDG 9 which focuses on “building resilient infrastructure, promoting inclusive and sustainable industrialization and fostering innovation”. In addition, Asterion also places special attention to other SDGs as key components of its asset selection and portfolio management approach, as detailed in the funds’ legal documentation.
Additionally, given Asterion’s active management approach, it also promotes the improvement of environmental, social, and governance (ESG) performance within its portfolio companies, ensuring responsible and sustainable practices.
As included in the legal documentation of the funds, Asterion prioritises investments in companies with an economic activity that actively promotes social and/ or environmental characteristics, that are aligned with key societal trends as described above, as well as with the United Nations Sustainable Development Goals for 2030 (SDGs), while satisfying the return objectives of the funds.
Regarding its contribution to the SDGs, and in addition to other SDG goals, Asterion’s investment strategy primarily aligns with SDG 9 which focuses on “building resilient infrastructure, promoting inclusive and sustainable industrialization and fostering innovation”. In addition, Asterion also places special attention to other SDGs as key components of its asset selection and portfolio management approach, as detailed in the funds’ legal documentation.
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D. Investment strategy
Asterion seeks to invest in the European infrastructure mid-market, especially focusing on the telecoms, energy & utilities and mobility sectors. We see these as very attractive segments where Asterion’s partners have decades of investing experience and can differentiate our offer and add value through our partnership and industrial model. We focus on markets and sectors overlapping with our experience and origination networks in Western Europe.
ESG considerations are fully integrated into all Asterion's activities, as opposed to being treated as a separate vertical. To ensure a responsible approach throughout the investment and asset management process, Asterion has established a Responsible Investment Policy (RI Policy), outlining the guidelines for Asterion’s commitment to integrating responsible practices.
Our commitment to promoting environmental and social characteristics through our investments stems from two key factors: Firstly, we select businesses that have an intrinsic contribution to society or the environment, by investing behind trends that are key in today’s world, such as different stages of the energy transition, digitalization with focus on rural areas that are difficult and expensive to connect and new mobility, as well as linked to selected SDGs as explained in section C. With our investment, we enhance or enable this contribution. To measure and report this contribution, we track and report several KPIs that are established by the Management Company at the beginning of the investment’s life. In each case, targets and indicators relevant to each particular sector, country and business shall be established. These objectives will be integrated into the company’s asset management plan and will also be measured at the time of the sale. Throughout this process, the Management Company provides support to the portfolio company in achieving and measuring these objectives, leveraging external resources when necessary.
Secondly, we consider the contribution a company has on its stakeholders as a direct result of the way in which it is managed, including its governance structure, internal policies and procedures, priorities, and actions. This is assessed, first, during the pre-acquisition phase, through the performance of an ESG Due Diligence (done by an external expert where needed), and second, in the post-acquisition phase. During the post-acquisition phase, we put in place the necessary tools and processes to ensure good governance and management of key ESG topics.
Additionally, we measure, and report Principal Adverse Impact indicators (PAIs) as mandated by the Regulatory Technical Standards of the Regulation (EU) 2019/2088. Additional KPIs that Asterion considers relevant might also be monitored and priorities and action plans will be established for the companies regarding key ESG aspects.
Additionally, a governance structure has been defined assigning ESG-linked responsibilities across the wider Asterion team. The Investment Committee and Portfolio Management Committee, together with the ESG team, supervise the implementation of Asterion’s ESG strategy, leveraging the expertise of external advisors where necessary.
Our commitment to promoting environmental and social characteristics through our investments stems from two key factors: Firstly, we select businesses that have an intrinsic contribution to society or the environment, by investing behind trends that are key in today’s world, such as different stages of the energy transition, digitalization with focus on rural areas that are difficult and expensive to connect and new mobility, as well as linked to selected SDGs as explained in section C. With our investment, we enhance or enable this contribution. To measure and report this contribution, we track and report several KPIs that are established by the Management Company at the beginning of the investment’s life. In each case, targets and indicators relevant to each particular sector, country and business shall be established. These objectives will be integrated into the company’s asset management plan and will also be measured at the time of the sale. Throughout this process, the Management Company provides support to the portfolio company in achieving and measuring these objectives, leveraging external resources when necessary.
Secondly, we consider the contribution a company has on its stakeholders as a direct result of the way in which it is managed, including its governance structure, internal policies and procedures, priorities, and actions. This is assessed, first, during the pre-acquisition phase, through the performance of an ESG Due Diligence (done by an external expert where needed), and second, in the post-acquisition phase. During the post-acquisition phase, we put in place the necessary tools and processes to ensure good governance and management of key ESG topics.
Additionally, we measure, and report Principal Adverse Impact indicators (PAIs) as mandated by the Regulatory Technical Standards of the Regulation (EU) 2019/2088. Additional KPIs that Asterion considers relevant might also be monitored and priorities and action plans will be established for the companies regarding key ESG aspects.
Additionally, a governance structure has been defined assigning ESG-linked responsibilities across the wider Asterion team. The Investment Committee and Portfolio Management Committee, together with the ESG team, supervise the implementation of Asterion’s ESG strategy, leveraging the expertise of external advisors where necessary.
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E. Proportion of investments
Asterion Industrial Partners SGEIC, SA shall seek to ensure that at least 51% of the Fund’s investments are targeted towards companies with an economic activity that actively promotes social and/ or environmental characteristics previously described, and satisfy the return objectives described in the Fund’s Prospectus.
For the remaining 49% of the investments that may not necessarily be made in portfolio companies or assets with an economic activity that actively contributes to the promotion of social and/or environmental characteristics, Asterion reserves the right to decide on a case by case basis if they will or will not be aligned with environmental and/or social characteristics. In any case, these investments will be in alignment with the strategy of the Fund which consists on infrastructure investments in the European mid-market with a focus on the telecom, energy & utilities and mobility sectors, where the industrial approach of the team and value creation skills can be applied. Additionally, all investments will follow the guidelines described by the RI Policy ensuring a set of minimum environemental, social and governance safeguards.
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F. Monitoring of environmental or social characteristics
At Asterion, the promotion of environmental or social characteristics through our investments is carefully monitored throughout the lifecycle of the financial product, supported by robust internal control mechanisms. We employ various sustainability indicators to measure the progress of each environmental or social characteristic promoted by the financial product.
To begin with, we assess the intrinsic contribution of the business activity on the environment and/or society. Asterion aims to align its investments with key societal trends and SDGs as decribed in previous sections. Our goal is to enhance or enable this contribution through Asterion's investment and asset management. A set of KPIs, tailored to the specific sector and business in question, are established by the Management Company at the onset of the investment and are periodically measured. The investment teams are reponsible for internally reporting the evolution of these KPIs. Additionally, the achievement and measurement of these objectives are also considered during the sale of the portfolio company.
Furthermore, we consider the contribution a company has on its stakeholders as a direct result of the way in which it is managed, including its governance structure, internal policies and procedures, priorities, and actions. This is assessed, first, during the pre-acquisition phase, through the performance of an ESG Due Diligence (done by an external expert where needed), and second, in the post-acquisition phase. During the post-acquisition phase, we put in place the necessary tools and processes to ensure good governance and management of key ESG topics. Additionally, we measure, and report Principal Adverse Impact indicators (PAIs) as mandated by the Regulatory Technical Standards of the Regulation (EU) 2019/2088. Additional KPIs that Asterion considers relevant might also be monitored and priorities and action plans will be established for the companies regarding key ESG aspects. Through this comprehensive approach, Asterion ensures that the environmental or social characteristics promoted by the financial product are diligently monitored and evaluated, with clear indicators and control mechanisms in place throughout the lifecycle of the financial product.
To begin with, we assess the intrinsic contribution of the business activity on the environment and/or society. Asterion aims to align its investments with key societal trends and SDGs as decribed in previous sections. Our goal is to enhance or enable this contribution through Asterion's investment and asset management. A set of KPIs, tailored to the specific sector and business in question, are established by the Management Company at the onset of the investment and are periodically measured. The investment teams are reponsible for internally reporting the evolution of these KPIs. Additionally, the achievement and measurement of these objectives are also considered during the sale of the portfolio company.
Furthermore, we consider the contribution a company has on its stakeholders as a direct result of the way in which it is managed, including its governance structure, internal policies and procedures, priorities, and actions. This is assessed, first, during the pre-acquisition phase, through the performance of an ESG Due Diligence (done by an external expert where needed), and second, in the post-acquisition phase. During the post-acquisition phase, we put in place the necessary tools and processes to ensure good governance and management of key ESG topics. Additionally, we measure, and report Principal Adverse Impact indicators (PAIs) as mandated by the Regulatory Technical Standards of the Regulation (EU) 2019/2088. Additional KPIs that Asterion considers relevant might also be monitored and priorities and action plans will be established for the companies regarding key ESG aspects. Through this comprehensive approach, Asterion ensures that the environmental or social characteristics promoted by the financial product are diligently monitored and evaluated, with clear indicators and control mechanisms in place throughout the lifecycle of the financial product.
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G. Methodologies
Asterion uses a robust methodology to measure the attainment of social and environmental characteristics within the Funds. The process involves the collection of both qualitative and quantitative sustainability information and data from portfolio companies, in collaboration with the investment teams. This data is then internally processed by Asterion's ESG team, with support from an external advisor to ensure compliance with relevant regulations for accurate reporting.
The ESG team, in collaboration with the investment teams, carefully reviews the processed data and actively engages with portfolio companies to ensure progress is made on the different fronts. Through these engagements, improvement measures are identified and implemented to enhance the ESG performance of the portfolio companies. On this basis, ESG annual targets are set for each portfolio company at the beginning of the year by Asterion.
With this comprehensive approach, Asterion ensures that social and environmental characteristics are effectively measured, monitored, and improved throughout the lifecycle of the Funds, with the aim of promoting sustainable practices and aligning with regulatory requirements.
The ESG team, in collaboration with the investment teams, carefully reviews the processed data and actively engages with portfolio companies to ensure progress is made on the different fronts. Through these engagements, improvement measures are identified and implemented to enhance the ESG performance of the portfolio companies. On this basis, ESG annual targets are set for each portfolio company at the beginning of the year by Asterion.
With this comprehensive approach, Asterion ensures that social and environmental characteristics are effectively measured, monitored, and improved throughout the lifecycle of the Funds, with the aim of promoting sustainable practices and aligning with regulatory requirements.
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H. Data sources and processing
Data sources used to measure the social and environmental characteristics promoted by the Funds are mainly direct information collected from portfolio companies through Asterion’s monitoring system. By gathering data directly from the portfolio companies, Asterion obtains accurate and reliable insights into their social and environmental performance. Some of the data, such as carbon emissions, is often calculated by external advisors hired by each portfolio company.
To ensure data quality, Asterion will assess the data received through multiple levers of control, starting with investment teams, responsible for each investment, and later the ESG team with the help of an external expert. If any doubts or uncertainties arise regarding the accuracy of the data, Asterion engages with the portfolio companies to seek clarification. The data is processed internally by Asterion's ESG team, with support from an external expert to ensure compliance with relevant regulations for accurate reporting.
To ensure data quality, Asterion will assess the data received through multiple levers of control, starting with investment teams, responsible for each investment, and later the ESG team with the help of an external expert. If any doubts or uncertainties arise regarding the accuracy of the data, Asterion engages with the portfolio companies to seek clarification. The data is processed internally by Asterion's ESG team, with support from an external expert to ensure compliance with relevant regulations for accurate reporting.
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I. Limitations to methodologies and data
Asterion recognizes that limitations in methodologies and data sources may arise, mainly due to the lack of precise data from portfolio companies. However, Asterion does not expect these limitations to hinder the achievement of the social or environmental characteristics of the Funds. Asterion will actively collaborate with its portfolio companies to improve data sources and explore the feasibility of implementing automatic monitoring systems.
J. Due diligence
To ensure data quality, Asterion will assess the data received through multiple levers of control, starting with investment teams, responsible for each investment, and later the ESG team with the help of an external expert. If any doubts or uncertainties arise regarding the accuracy of the data, Asterion engages with the portfolio companies to seek clarification. The data is processed internally by Asterion's ESG team, with support from an external expert to ensure compliance with relevant regulations for accurate reporting.
Additionally, when evaluating potential investments, alongside legal, financial, technical and other considerations, Asterion conducts a thorough ESG due diligence with the assistance of an external advisor, to identify whether a potential investment is aligned with the social and environmental characteristics of the Funds. The ESG due diligence encompasses several aspects, such as identifying material topics for assessment, any red flags arising from those material topics, and assessing compliance with SFDR Article 8 criteria and Asterion's Responsible Investment Policy. A high-level climate risk assessment is also performed in most cases.
The results of ESG due diligence, including risks and opportunities, are presented to the Investment Committee (IC) for decision-making alongside other relevant factors. If concerning issues arise, the IC may request further diligence. In the case of acquiring a company, the selected topics are continuously monitored and reported to the Portfolio Management Committee (PMC).
Additionally, when evaluating potential investments, alongside legal, financial, technical and other considerations, Asterion conducts a thorough ESG due diligence with the assistance of an external advisor, to identify whether a potential investment is aligned with the social and environmental characteristics of the Funds. The ESG due diligence encompasses several aspects, such as identifying material topics for assessment, any red flags arising from those material topics, and assessing compliance with SFDR Article 8 criteria and Asterion's Responsible Investment Policy. A high-level climate risk assessment is also performed in most cases.
The results of ESG due diligence, including risks and opportunities, are presented to the Investment Committee (IC) for decision-making alongside other relevant factors. If concerning issues arise, the IC may request further diligence. In the case of acquiring a company, the selected topics are continuously monitored and reported to the Portfolio Management Committee (PMC).
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K. Engagement policies
As controlling owners of most of our portfolio companies, we are well positioned to foster and implement best practices on ESG management. In this context, we have developed a standard process to be applied during our ownership of all companies.
During the asset management phase, it is the responsibility of all deal teams, supported by the ESG team, to ensure that all companies meet the minimum standards defined by Asterion in relation to our ESG strategy and are encouraged to prioritize key ESG aspects as part of the core strategy of their business.
Asterion’s minimum requirements include:
Asterion’s minimum requirements include:
- The definition of an internal ESG governance structure (ESG team or ESG responsible, ESG Committee or forums where ESG decisions are made, involvement of the Board of Directors).
- Development of a minimum set of internal policies (including anti-corruption & bribery, health & safety, internal code of conduct, risk management, business continuity, AML, ESG, supply chain, diversity and inclusion, among others).
- Definition and implementation of an ESG Action plan (including at least aspects such as emissions reduction, diversity & inclusion and shared success).
- Reporting requirements including a “contribution KPI” related to the business activity as well as a set of additional KPIs including PAIs as per SFDR regulation. To ensure implementation, we maintain continuous communication with our portfolio companies, ensuring that board-level updates include the company's ESG progress.
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L. Designated reference benchmark
No specific index has been designated as a reference benchmark to determine whether this financial product is aligned with the environmental and/or social characteristics.
KEY TOPICS OF OUR ESG APPROACH
Please click here to download our Responsible Investment Policy
Please click here to download our ESG reports
Climate change and low-carbon economy
Efficient use of resources
Environmental impact on ecosystems
Social progress and human rights
Diversity and inclusion
Well-being in the workplace
