COMMITMENT TO SUSTAINABILITY.

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At VR ASSET MANAGEMENT, a VR Corporatenext S.r.l. firm, briefly named "VRAM", we promote a corporate culture deeply rooted in sustainability through the adoption of a comprehensive ESG Policy that outlines VRAM's fundamental principles in the fields of Environmental, Social, and Governance.

VRAM's mission is to contribute to the sustainable development and enhancement of public and private real estate assets by integrating energy efficiency, urban regeneration, and environmental impact reduction across all VRAM investment and management activities.

In alignment with this vision, we have endorsed the United Nations Principles for Responsible Investment (UN PRI) and are progressively integrating ESG criteria into VRAM corporate strategy, investment processes, and risk management systems, with a particular focus on Sustainability Risk Assessment.

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SUSTAINABILITY RISK AND RESPONSIBLE INVESTMENT.

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We believe that effective management of sustainability risk is essential to guiding investments toward projects that promote the rationalization and valorization of public assets, while also contributing to the reduction of public debt.

Over the long term, the systematic analysis and continuous monitoring of ESG-related risks are expected to generate a positive impact on the performance of the funds under VRAM management, reinforcing both financial resilience and social value creation.

For further details on VRAM approach to sustainability risk management, please refer to VRAM official ESG Policy, available below.

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PRINCIPAL ADVERSE IMPACTS.

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In accordance with Article 4 of Regulation (EU) 2019/2088 (SFDR) on sustainability‐related disclosures in the financial services sector, VR ASSET MANAGEMENT declares that - although the process of alignment with Article 4, paragraph 1(a) of the SFDR has already been initiated - we currently do not consider the principal adverse impacts (PAIs) of investment decisions on ESG factors.

This position reflects the current complexity of obtaining consistent and reliable data, as well as the lack of universally defined metrics and indicators capable of objectively measuring such impacts.

We remain fully committed to advancing the implementation of the SFDR framework and will provide updates as soon as new developments and validated methodologies become available.

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VRAM ESG Policy is built upon three interdependent pillars:

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1. Environmental Responsibility - Promoting energy efficiency, waste reduction, and low-impact development models.

2. Social Engagement - Fostering inclusion, professional growth, and community well-being through ethical governance.

3. Governance Integrity - Ensuring transparency, accountability, and the integration of sustainability principles into all strategic and operational decisions.

 

Through this framework, VR ASSET MANAGEMENT reaffirms its dedication to building long-term value, empowering people, and shaping a sustainable future across the global asset management and energy-tech landscape.

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GOVERNANCE AND ETHICAL INTEGRITY.

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At VR ASSET MANAGEMENT, strong governance and uncompromising ethical standards are the foundation of VRAM corporate culture and operational excellence. We recognize that sustainable value creation depends on the trust of clients, partners, operators, and society at large.

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TRANSPARENT DECISION-MAKING

VRAM governance framework ensures that all strategic and operational decisions are guided by clarity, accountability, and consistency.

• Roles and responsibilities are clearly defined across executive and operational teams.

• Investment and project approval processes include robust ESG and risk assessment checkpoints.

• Key decisions are reviewed periodically by a dedicated Board-level ESG and Governance Committee, ensuring alignment with corporate strategy and sustainability objectives.

 

REGULATORY COMPLIANCE

VR ASSET MANAGEMENT operates in full compliance with national and international legal frameworks, including EU regulations and global best practices:

• We adhere strictly to financial, environmental, and social regulations affecting VRAM operations.

• Policies are regularly updated to reflect evolving regulatory requirements and industry standards.

• Internal audits and compliance reviews are conducted systematically to maintain operational integrity.

 

ETHICAL CONDUCT AND ANTI-CORRUPTION

Ethics is at the heart of every interaction and transaction. We maintain a zero-tolerance policy towards corruption, conflicts of interest, and unethical behavior:

• All operators, contractors, associated specialists and partners are required to adhere to a Code of Conduct, emphasizing integrity, fairness, and transparency.

• Mandatory training programs equip VRAM teams with the knowledge to identify and mitigate ethical risks.

• Anonymous reporting channels are available to report misconduct, with full protection for whistleblowers.

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Through these commitments, VR ASSET MANAGEMENT ensures that every action, decision, and investment is guided by integrity, transparency, and accountability, reinforcing VRAM position as a trusted leader in sustainable asset management.

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SUSTAINABILITY RISK MANAGEMENT.

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At VR ASSET MANAGEMENT, sustainability risk management is a cornerstone of VRAM investment philosophy.
We systematically identify, assess, and mitigate environmental, social, and governance risks that may influence both the performance of VRAM assets and the long-term value for stakeholders.

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VRAM approach includes:

• Risk Identification: Leveraging advanced data analytics, AI, and ML tools to detect emerging ESG risks across sectors, regions, and asset types.

• Risk Assessment: Evaluating potential impacts on financial performance, operational continuity, and social/environmental outcomes.

• Mitigation Measures: Implementing targeted strategies to reduce exposure, including energy-efficient renovations, resilient urban design, and community engagement initiatives.

 

VRAM investment decisions aim to direct capital toward projects that generate measurable positive outcomes, including:

• Rationalization and enhancement of public assets, ensuring optimized use and value creation;

• Energy efficiency and urban resilience, promoting low-carbon, climate-adaptive infrastructure;

• Reduction of public debt through sustainable redevelopment, contributing to the fiscal health of local and national governments.

 

By embedding sustainability into risk management, we not only safeguard investments but also support responsible resource use, social well-being, and intergenerational equity. Over the long term, this proactive approach is expected to produce stable, positive financial returns while creating lasting societal value.

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MONITORING, REPORTING & CONTINUOUS IMPROVEMENT.

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We maintain a rigorous ESG monitoring framework to ensure that all initiatives, investments, and operations align with VRAM sustainability objectives.

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Key pillars of VRAM approach include:

• Performance Monitoring: Tracking ESG outcomes using quantitative metrics (carbon footprint, energy efficiency, social impact) and qualitative assessments (stakeholder satisfaction, governance effectiveness).

• Transparent Reporting: Annual ESG reports are published to provide clear insights to clients, regulators, and the public, demonstrating progress, challenges, and future goals.

• Continuous Improvement: ESG objectives are revisited periodically to incorporate lessons learned, innovations, and evolving regulatory expectations.

 

We leverage advanced technologies such as AI, ML, and big data analytics to enhance environmental and social intelligence, improve decision-making, and identify opportunities for sustainable value creation.

Additionally, we actively engage with partners, industry networks, and institutions to exchange best practices, adopt emerging ESG standards, and strengthen VRAM impact across all operational areas.

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LONG-TERM VISION.

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The ESG Policy of VR ASSET MANAGEMENT reflects a strategic, forward-looking vision: to build sustainable value that endures across generations.

 

We aim to integrate human potential, technological innovation, and responsible investment to deliver solutions that simultaneously:

• Drive economic growth and financial stability;

• Enhance environmental stewardship and climate resilience;

• Generate meaningful social impact and community value.

 

For VR ASSET MANAGEMENT, sustainability is not a regulatory requirement or obligation - it is an opportunity to innovate, inspire, and create lasting prosperity. VRAM long-term vision is to merge people, technology, and capital into a coherent framework that shapes the future of sustainable asset management globally.