Siloé Infrastructure Fund

Sustainability-related disclosures

Summary

This information is provided in accordance with Article 10.1(1) of Regulation (EU) 2019/2088 SFDR in the format required by Delegated Regulation 2022/1288, Articles 24 to 36.

The Siloé Infrastructures Fund, classified as Article 8 under the SFDR, aims to support the development of territories in the context of the triple energy, digital, and demographic transition.

The investments made mainly promote environmental characteristics, and although there was no specific sustainable investment objective, the fund has a majority of sustainable investments.

In practice, and in line with the investment strategy of the fund, investments are primarily geared towards mitigating climate change.

The verification that investments contribute to the intended objective is conducted during the initial assessment and regularly updated through direct communication between the asset management company and the beneficiary counterpart. Information on eligibility and alignment with environmental objectives is collected through an internal ESG questionnaire (Environmental, Social and Governance) and reported by the beneficiary entities, which are not subject to the obligation of publishing a non-financial performance statement. The process is overseen by an internal control system.

Without a sustainable investment objective

This product promotes environmental or social characteristics but does not have a specific sustainable investment objective.

Environmental or social characteristics of the financial product

The investments made aim to mitigate climate change.

Investment strategy

To respect the environmental characteristics promoted, the SILOE infrastructure fund has invested in France in the field of renewable energies, electric mobility and thermal decarbonization of buildings.

The governance practices of the beneficiary companies are assessed at all stages of the investment cycle and regularly monitored, including through an internal questionnaire updated annually.

This questionnaire includes sections on internal organization, employee relations, staff remuneration, and tax obligations, and reviews compliance with Principal Adverse Impacts (PAI) to measure negative sustainability impacts, i.e., the most significant negative impacts of investment decisions on sustainability factors related to environmental, social, personnel, human rights, and anti-corruption issues.

When certain indicators are not available, the asset management company makes its best efforts to identify comparable qualitative criteria.

Proportion of investments

Although there was no specific sustainable investment objective or predefined allocation, the Siloé Infrastructures Fund had 90% direct sustainable investments as of December 31, 2023, with an environmental objective.

Control of environmental or social characteristics

The environmental characteristics promoted by the Siloé Infrastructures Fund are regularly reviewed through:

• Integration of environmental, social and governance issues at all stages of fund governance
• Verification of internal rules related to compliance, internal control, and risk control by the compliance and internal control officer, including adherence by operational teams to procedures linked to environmental, social and governance criteria at all stages of the investment process
• The questionnaire, which includes information collection regarding compliance with principal adverse indicators;
• Review of the management report of the Siloé Infrastructures Fund by the external auditor

Methods

The Siloé Infrastructures Fund primarily invests in the energy transition through:

• Wind or photovoltaic parks
• Renewable energy producers: existing or upcoming project portfolios
• Electric vehicle charging stations
• Developers industrializing energy solutions using hydrogen
• Regulation of the energy performance of buildings

The methods used to assess the extent to which the promoted environmental or social characteristics of the financial product have been achieved consist of an ongoing dialogue with the investment beneficiaries, aligning the financed activities with the sustainable development goals retained by the management company, particularly the climate change mitigation objective.

The required information to perform this verification is directly collected from funded companies and used to prepare periodic reports for funds promoting environmental or social characteristics.

Data sources and processing

The data used to assess the achievement of the environmental characteristics promoted by the Siloé Infrastructures Fund are:

• Verified by the management team regarding the correspondence of the investment beneficiary's activities with the climate change mitigation objective
• Collected by the asset management company and reported by the beneficiary through the internal ESG questionnaire

The asset management company does not rely on estimates (e.g., sector data) for the Siloé Infrastructures Fund.

Limitations of methods and data

The methods used to assess the extent to which the promoted environmental characteristics are achieved rely on evolving and continuously enriched regulations that are not yet finalized.

Additionally, the reported data used does not require publication by the investment beneficiaries, as they are non-listed entities that do not meet the minimum thresholds for publishing their non-financial performance statement.

However, these limitations do not impact the extent to which the environmental characteristics promoted by the Siloé Infrastructures Fund are respected.

Due diligence

The asset management company has established methods to ensure the respect of the environmental characteristics promoted by the Siloé Infrastructures Fund through procedural frameworks and a governance system that is monitored as indicated above.

Engagement policies

Crédit Mutuel Impact’s shareholder engagement policy is published on its website in the “Regulatory framework” section. The review of its application is set out in the same document.

The report prepared by the management company pursuant to section 29 of the Climate Energy Act also specifies the results of the implementation of this policy regarding environmental, social and governance issues. The same report presents the methods applicable to the monitoring of controversies and other sustainability risks in funded companies.

• Link to the Extra-financial report - Article 29 of the Climate Energy Act [PDF – 298 ko] ;
• Link to the Shareholder Engagement Policy and Year 2023 Report [PDF – 200 ko] ;

Benchmark

The asset management company has designated no index as a reference benchmark for achieving the environmental characteristics promoted by the Siloé Infrastructures Fund.