Sustainability-related disclosures

SFDR

Sustainable Finance Disclosure Regulation

The Sustainable Finance Disclosure Regulation (SFDR) is part of the EU Sustainable Finance Action Plan to stimulate the flow of capital into sustainable financial products. The SFDR focuses on improving transparency on how financial market participants and financial advisors integrate sustainability into their investment choices and investment advice. It aims to strengthen the financial sector's response to environmental and social risks, in line with the UN 2030 Agenda for Sustainable Development and the Paris Agreement.

The SFDR consists of specific information requirements and a classification system that aims to increase the transparency and credibility of sustainability claims made by financial market participants and financial advisors. This framework also enables peers, regulators, governments, and consumers to assess and compare how financial market participants and financial advisors incorporate sustainability considerations into their decision-making, products and advice based on consistent disclosure criteria.

How does APG Asset Management implement the SFDR?

As a participant in financial markets and financial advisor, APG Asset Management is required by the SFDR to disclose information on how we integrate sustainability risk management and the consideration of adverse sustainability impacts into our processes, financial products and investment advice. Although the main provisions of the SFDR have been applicable since March 2021, the framework and other related sustainable finance rules are still being refined and expanded. This process is set to continue, which is why we continuously monitor the adoption of new regulations and guidelines and aim to implement these to the best of our ability.

This page provides information on APG Asset Management's implementation of the SFDR, including our Sustainability Risk Policy, Principal Adverse Impact Statement, Remuneration Policy, and product-specific information for 24 of our investment pools (See the "our investments" page). These documents also reference other APG Asset Management policies to give a clearer picture of how we incorporate sustainability considerations into our decision-making and advice.

Our sustainability risk policy demonstrates how sustainability risks are incorporated into investment policy and investment recommendation procedures. In the context of the SFDR, 'sustainability risk' refers to an environmental, social or governance (ESG) event or condition that, if it occurs, could have an actual or potential material adverse impact on the value of the investment. Article 3 of the SFDR requires APG Asset Management to describe how we integrate sustainability risks into our investment decision-making process and investment advice. Responsible investment is an integral part of the investment process at APG AM and one of our fundamental investment principles. As long-term investors, this means that we actively consider sustainability risks and evaluate ESG criteria for every single investment, irrespective of asset class, to ensure we make the best possible investment decisions and advice. Our responsible investment approach is documented more fully in our Responsible Investment Policies.

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Under Article 4 of the SFDR, financial market participants and financial advisor must disclose whether their investment decisions and advice negatively impact sustainability factors. APG Asset Management actively considers the principal adverse impact (PAI) of each investment on a range of sustainability factors, for example, environmental, social and employee matters, respect for human rights and anti‐bribery and corruption issues. As a financial market participant, this involves assessing PAI indicators for each investment we make and aggregating the results to report on the impact at the entity level; for APG Asset Management as a whole. Product-level PAI disclosures (required under Article 7) can also be found on the "our investments" page. We are also obliged to outline the due diligence policies we have in place regarding these impacts. In 2021, we drafted our first Principal Adverse Impacts Statement as part of the SFDR Level I disclosure requirements, and from now on, we will annually publish an updated PAI Statement on our website.

APG AM PAI Statement 2024

The SFDR (Article 5) requires financial market participants and financial advisors to demonstrate and disclose how their remuneration policy is consistent with integrating sustainability risks. APG Asset Management has adopted a remuneration policy that enables us to attract and retain qualified employees with integrity. The remuneration policy is set-up to prevent excessive sustainability risks. The possible risks associated with variable remuneration are mitigated by a policy that is based on objectives related to responsible investing. The SFDR Disclosure document can be found here.

Summary Remuneration Policy

Sustainability-related disclosures

Our policies

Our financial products

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Sustainable Finance Disclosure Regulation

How does APG Asset Management implement the SFDR?

Sustainability Risk Policy

Principal Adverse Impact Statement

Remuneration Policy

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Sustainability-related disclosures

Our policies

Our financial products

All Downloads

Sustainable Finance Disclosure Regulation

How does APG Asset Management implement the SFDR?

Sustainability Risk Policy

Principal Adverse Impact Statement

Remuneration Policy