EOS Atlas Infrastructure and Green Transition SCA, SICAV-RAIF (EOS ATLAS)
Disclosures on the implementation of the Commission Delegated Regulation (EU) 2022/1288 of 6 April 2022 supplementing Regulation (EU) 2019/2088
Article 24 SFDR- Sections of website product disclosure for financial products that promote environmental or social characteristics
We aspire to have a positive impact and make a significant difference for our stakeholders and society. We bind our portfolio companies to:
For financial products that promote environmental or social characteristics, financial market participants shall publish the information referred to in Article 10(1) of Regulation (EU) 2019/2088 and Articles 25 to 36 of this Regulation in the following order and made up of all of the following sections titled:
a) Summary
b) No sustainable investment objective
c) Environmental or social characteristics of the financial product
d) Investment strategy
e) Proportion of investments
f) Monitoring of environmental or social characteristics
g) Methodologies
h) Data sources and processing
i) Limitations to methodologies and data
j) Due diligence
k) Engagement policies
l) where an index is designated as a reference benchmark to attain the environmental social characteristics promoted by the financial product, ‘Designated reference benchmark’
Article 25 SFDR – Summary
EOS ATLAS promotes environmental and social characteristics by investing indirectly in infrastructure and green transition projects and in small and medium-sized enterprises (SMEs) with measurable environmental impact, primarily located in Greece. Investments are made through equity and debt instruments, including project finance structures and special purpose vehicles (SPVs).
The Fund promotes environmental characteristics such as the reduction of air pollution, improved water usage, efficient energy consumption, and compliance with environmental legislation. It also promotes social characteristics such as respect for human rights, employee training and development, diversity and equal opportunity, occupational health and safety, and compliance with national labour legislation.
In addition, the Fund promotes environmental and social characteristics by:
– fully respecting the climatic and environmental standards and priorities of the European Union and the principle of “do no significant harm” in accordance with the provisions of the Commission Communication (2021/C 58/01) “Technical guidance on the application of the principle of “do no significant harm” in the framework of the Regulation establishing the Recovery and Resilience Facility; and
Article 26 SFDR – No sustainable investment objective
EOS ATLAS promotes environmental or social characteristics but does not have as its objective sustainable investment.
Article 27 SFDR – Environmental or social characteristics of the financial product
EOS ATLAS aims to promote the improvement of ESG practices of investees within their sector of activity. The ESG performance of an entity is evaluated against a combination of environmental, social and governance characteristics including the ones below:
ENVIRONMENTAL
- Reduction of air pollution and greenhouse gas emissions.
- Efficient use of water resources.
- Reduction of energy consumption and promotion of renewable energy use.
- Compliance with applicable environmental legislation.
- Support for SMEs contributing to environmental improvement through green technologies, circular economy solutions, or sustainable infrastructure services.
SOCIAL
- Human Rights
- Employee Training
- Diversity & Equal opportunity
- Occupational Health & Safety
- Compliance with labor legislation
- Support for social infrastructure projects such as residences and dormitories for aged people, contributing to social inclusion, improved living conditions, and access to essential care services.
Article 28 SFDR – Investment strategy
EOS ATLAS will primarily focus on fully licensed ready-to-build or brownfield projects in Greece within infrastructure and green transition sectors. These sectors include Clean Energy Transition & Climate, Sustainable Transport, Environment & Resources, Digital Connectivity & Data Infrastructure and Social Infrastructure.
The projects selected will be positioned in areas where Greece holds a clear competitive advantage, aligning with national and EU strategic priorities for sustainable development and innovation.
The Company will invest primarily through share capital increase and in specific cases more flexible financial structures (convertibles, preferred shares). The focus will be on minority stakes with enhanced minority rights and occasionally majority stakes
Article 29 SFDR – Proportion of investments
Aligned with E/S characteristics 80%
EOS ATLAS intends to promote the Characteristics through a minimum of 80% of the Company’s Investments (based on total capital invested), to be determined after the end of the investment period.
Investments meeting the binding elements of the investment strategy and deemed by the External AIFM to promote the Characteristics will be categorised in disclosures as ‘aligned with the E/S characteristics’. Investments which do not at the time of disclosure promote the Characteristics will be categorised as ‘other’.
The Company does not commit to making sustainable investments.
The remaining proportion of the investments may include :
– The proportion of assets that do not attain the minimum standard to meet environmental or social characteristics promoted by the financial product,
– Instruments which are mainly used for liquidity, efficient portfolio management, notably cash and term deposits
Article 30 SFDR – Monitoring of environmental or social characteristics
EOS monitors EOS ATLAS portfolio companies on a regular basis for E&S risks and review the efficient implementation of related policies during the life of the investment in cooperation with a third-party service provider. Investees must report on E&S performance and provide relevant info on an annual basis.
Article 31 SFDR – Methodologies
EOS ATLAS performs comprehensive ESG due diligence before investment, covering environmental, social, and governance aspects, including compliance with environmental and labour regulations, assessment of environmental and social risks and opportunities, and governance quality and transparency.
Data sources include information provided by portfolio companies, SPVs, and SMEs; publicly available reports and regulatory filings; and independent third-party assessments where available. The External AIFM performs internal verification of ESG data and may engage external experts for validation or impact measurement.
Data availability and quality may vary, particularly among SMEs and early-stage infrastructure projects. The External AIFM applies conservative estimates where necessary and aims to improve data quality through ongoing engagement and reporting capacity-building.
Before any investment decisions are made, the Company will ensure through a due diligence process that all of the projects comply with:
– applicable Do No Significant Harm technical criteria of the EU Taxonomy in force;
– the Minimum Social Safeguards; and
– applicable EU legislation and/or national legislation related to environment, climate and social issues.
Article 32 SFDR – Data sources and processing
a) the main data sources are the investee’s relevant departments
b) quality of data is a priority through active participation of EOS in BoD’s
c) the data are processed by third party service providers during the due diligence and the annually monitoring process
d) the proportion of data subject to estimation will depend on the availability, the quality of data provided and the sector
Article 33 SFDR – Limitations to methodologies and data
Limitations to the methodologies and data used may arise, including limited data availability or insufficient data quality, particularly in relation to small-cap companies. Where such limitations occur, ESG best-practice approaches will be applied to the extent possible.
Article 34 SFDR – Due diligence
As part of the E&S due diligence process EOS ensures compliance with the Commission Communication (2021/C 58/01) “Technical guidance on the application of the ‘Do no significant harm’ principle under the Regulation establishing the Resilience and Recovery Facility’ prior to the investment decision. For this purpose, EOS applies to the Commission’s technical guidance document on the sustainability proofing for the Invest EU Fund (Communication of the European Commission 2021/C 280/01),
Article 35 SFDR – Engagement policies
In all Investments, strong governance rights will apply such as a) board representation; b) reserved matters and veto rights (i.e. over mergers and acquisitions, asset dispositions, issuance of new equity); c) right to appoint officers; d) ability to approve business plan; e) related party transaction approvals; f) limits on debt levels; g) profit distribution provisions; h) information and inspection rights; i) conflict resolution mechanisms; j) anti-dilution protection rights.
In addition, the External AIFM actively engages with portfolio companies and SMEs to enhance ESG performance by encouraging the adoption of ESG policies and performance metrics, providing guidance on corrective actions, and supporting capacity building for ESG management systems.
Article 36 SFDR – Designated reference benchmark
No reference benchmark has been designated for the purpose of attaining the environmental or social characteristics promoted by EOS ATLAS.
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ANNEX 8
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