Sustainability Disclosures
TOPSMART INVESTMENTS AIFLNP V.C.I.C. LIMITED / GREEN LAND DEVELOPMENT
SFDR Pre-Contractual and Periodic Disclosure – Article 8 Fund and Remuneration Policy
License Number: LPAIF 138/2018
SFDR Classification: Article 8 Fund
ESG Naming Compliance: Compliant with ESMA Guidelines 34-1592494965-657
1. Pre-Contractual Disclosure
• Fund promotes environmental and social (E/S) characteristics but does not have sustainable investment as its objective.
• No minimum commitment to sustainable investments.
• Fund integrates ESG factors in investment decisions and monitors E/S KPIs.
- The Fund’s remuneration policy is consistent with the integration of sustainability risks and the promotion of environmental and social characteristics. Variable remuneration is partly linked to the achievement of ESG performance indicators, including energy efficiency, carbon reduction, and social impact metrics. Deferred compensation mechanisms ensure long-term alignment between the remuneration of key staff and the Fund’s sustainable investment strategy.
Environmental Characteristics: – Investment in green real estate developments (residential/commercial). Focus on energy efficiency, Energy Class A/B, emissions reduction, climate resilience.
Social Characteristics: – Max 50 investors for informed decision-making. – Promote healthier and smart-living spaces enhancing tenant wellbeing.
Exclusions: Fossil fuel production, coal mining, tobacco, weapons manufacturing, gambling, or other controversial industries.
- Direct/indirect investments in green projects via partnerships/co-investment.
- ESG screening during due diligence and ongoing
- Active engagement with developers, property managers,
- Investments aligned with E/S characteristics: 100%
- Other investments: 0%
- EU Taxonomy Alignment: Not
| Enviromental Key Category | KPI (Indicator) |
| Energy Efficiency | – % of buildings with EPC rating A
– Average energy consumption per m² – % of buildings using smart energy systems |
| Emissions | – GHG emissions per m² (Scope 1 C 2)
– Portfolio carbon intensity |
| Certifications | – % of assets with green building certifications |
| Climate Risk | – % of assets exposed to climate-related physical risk such as Flood, Heat C Water Stress
– Assets with resilience measures in place |
| Social Indicators | KPI (Indicator) |
| Tenant well-being | – Indoor air quality / ventilation (air flow) standards met |
| Accessibility | – % of assets meeting universal design standards |
| Safety | – # incidents per year |
| Tenant engagement | – % of tenants receiving ESG communication / training |
The fund monitors environmental performance via:
- Yearly energy and emissions
- Use of smart meters and building management
- Annual external audits and third-party EPC
- Internal ESG scorecards per
- Platform: Synesgy ESG global
- Sources: ESG self-assessment questionnaires, utility bills, certifications, developer/supplier
- Quality Control: mandatory evidence uploads, automated validation, audit trail, internal QA and
- ESG screening is integrated into investment
- Multidisciplinary committee
- ESG risk scoring; underperforming assets
- Site visits, four-eyes principle, continuous
- Reference benchmark has not been designated for the purpose of attaining the environmental or social characteristics promoted by the
2. Principle Adverse Impacts (PAIs)
- As of the date of this publication, TopSmart Investments AIFLNP V.C.I.C. Limited (Green Land Development) does not yet consider the principal adverse impacts (PAIs) of its investment decisions on sustainability factors in the sense of Article 4(1)(a) of the SFDR.
- Data limitations: The Fund invests in Direct/indirect investments in green projects via partnerships/co-investment where consistent, reliable and comparable ESG data aligned is not yet fully available.
- Ongoing regulatory alignment: The Fund is currently in the process of enhancing its ESG data collection and reporting systems through third-party platforms (including Synesgy) and independent ESG verification frameworks.
Resource prioritization: The Fund is in its early operational phase and is prioritizing the implementation of core ESG integration, monitoring, and impact measurement processes before expanding to full quantitative PAI reporting
3. Periodic Reporting / Annual Review Template
Content:
- Environmental Social Performance: KPI results and progress in attaining promoted E/S characteristics.
- Asset Allocation Update: Proportion of investments aligned with E/S
- Monitoring Activities: Engagement activities, site visits, and ESG data
- Sustainability Risks (Article 6): Material impacts of sustainability risks on returns and mitigation measures.
- Methodology Updates: Any changes to data collection, validation, or
- PAIs Update: Review of consideration of principal adverse sustainability
- Remuneration Policy Update: ESG-related adjustments in remuneration, alignment with sustainability
- External Verification: Third-party audits or ESG data validation