General Information
As of March 10, 2021, the European Sustainable Finance Disclosure Regulation (“SFDR”) has come into effect. Under this Regulation, investment managers such as Millwood Asset Management (“Millwood”) are required to disclose the extent to which they incorporate sustainability criteria in their investment policies. This includes aspects such as environmental, social, and employment matters, respect for human rights, and the prevention of corruption and bribery.

Millwood is a professional non-regulated asset manager that initiates investments/investment funds, focusing on both existing and newly constructed rental properties in the Dutch market with the goal of achieving solid and reliable returns for its investors. Millwood acknowledges the importance of the transition to a sustainable society, though it does not explicitly focus on sustainability. Nevertheless, in the case of newly developed rental properties, Millwood complies with legislation aimed at more sustainable housing construction and considers sustainability options in new acquisitions.

Sustainability Risks
When acquiring residential portfolios and managing our investment funds, we consider all relevant risks, including sustainability risks. Sustainability risk refers to the risk that national or local governments may implement stricter regulations to accelerate property sustainability efforts. Although properties are built to meet current standards and sustainability requirements, it is possible that future additional investments will be required to comply with updated regulations on sustainability. As a result, returns may decrease due to unexpected investments, and the value of the investments may decline, which could lead to lower overall returns.

Statement
Millwood’s policy and investment strategy take sustainability risks into account but are not explicitly focused on sustainable investing. We explicitly do not offer investments aimed at sustainable investments (“dark green investments” as defined in Article 9 of SFDR) or promote such investments (“light green investments” as defined in Article 8 of SFDR).