Compliance
You will find this sustainability information on this page.
The Principal Adverse Impacts (PAI) Statement for 2024 can be found here:
The sustainability features of our funds can be found here
1. Sustainability risk management policy
(Article 3 SFDR)
General
PGGM is convinced that the sustainability factor has a material impact on the risk-return profile of the investments and that this influence will continue to increase in the future. By integrating sustainability, we provide insight into risks and opportunities for the investment portfolio that we would not otherwise see. With the management of sustainability risks, a better risk-return trade-off can be made. This ensures a portfolio that is sustainable in the long term.
Responsibility
The management of sustainability risks is primarily the responsibility of the investment teams. In the relevant Investment Committees, they must be able to account for each investment on the three dimensions (3D) of return, risk and sustainability. The investment teams are supported by sustainability specialists in other departments such as Total Portfolio Management, Mandate Management and (if desired) Research. The same requirements are imposed on external managers under the responsibility of Mandaat Management.
Framework
The investment teams use sustainability risk assessment frameworks such as the Sustainable Accounting Standards Board (SASB) Materiality Map. Where necessary and possible, investment teams are also looking at alternative frameworks.
Lawsuit
The way in which the various investment teams manage sustainability risks is detailed in their mandates and fund conditions.
The process for ESG due diligence varies by investment team and by type of investment. For investments in private markets such as Private Real Estate or Private Equity, this due diligence mainly takes place in the investment proposal phase. This is carried out by the portfolio manager and ESG specialist involved, followed by an independent assessment by the Investment Risk Analysis department, based on the SASB Materiality Map and (sector) data from various external data providers such as Sustainalytics and MSCI. In the portfolio management phase, sustainability risk management consists of monitoring the ESG aspects of the investment.
For active investment mandates in public markets such as Listed Real Estate, the investment teams will further determine how ESG risk management takes shape within the mandate or fund conditions. The SASB Materiality Map serves as the basis for this. The stewardship team within Total Portfolio Management assists in conducting the dialogue with the companies concerned, and conducts ESG risk management for the passively filled mandates based on screening the investments for material sustainability risks in consultation with the Mandate Management department.
More information about how we manage sustainability risks can be found in our SFDR reports
2. How do we deal with adverse effects on investment sustainability? Art. 4 SFDR)
General
PGGM Vermogensbeheer B.V. ('PVBV') feels the responsibility to contribute to a liveable, more sustainable world. After all, a good pension is worth more in a liveable world. Therefore, PVBV takes into account the most important negative sustainability effects of investments when making investment decisions (both in the selection of investments and in the management of the investments). Sustainability impacts include, for example, the environment, human rights and labour rights, and corruption and bribery. The ways in which we do this are explained below.
Due diligence
First of all, we conduct due diligence on (potential) investments to identify any negative sustainability effects of an investment. We look at:
- The likelihood and severity of the negative impact;
- The size of the company in the portfolio;
- The extent to which the company contributes to the focus areas and sustainability objectives.
For the selection of external investors, the Mandate Management department expects external managers to adhere to our responsible investment beliefs and to demonstrably manage sustainability risks. The assessment of external managers looks at the extent to which they are a clear forerunner with regard to the management of sustainability risks as a visible part of the organisation and investment processes.
Furthermore, the investment performance of external investors is not only assessed against financial objectives, but also against social objectives. This includes the ESG scores of the portfolio and the contribution to the Sustainable Development Goals (SDG) and/or the Paris Climate Agreement. The ESG scores and sustainability contributions of the external managers are tested against the mandate and compared with the performance of other managers who have a similar mandate under management.
For the due diligence of the investments, we use data from specialised data providers, civil society organisations, media and the companies themselves. The investment teams then conduct additional research themselves.
We have developed a screening method to assess the severity of the negative effects of companies on people and the environment. This is based on the OECD Guidelines for Multinational Enterprises. Companies are given a score based on incidents within their own production locations or in the supply chain. This screening is applied to equity and bond investments and to private investments.
When we identify negative sustainability effects of a potential investment, we can take various measures. We can try to change the situation by means of active ownership or (in extreme cases) not include the company in question in the investment universe. Based on our findings, we decide whether to invest in a particular company and, if so, how to position ourselves as a shareholder.
These measures are described in more detail in the following paragraphs.
Inclusions
We choose to only include companies that meet the minimum sustainability conditions in the investable universe. For example, we only invest in companies that fit the standards and values of PVBV, its customers and their participants. We apply a strict lower limit that applies to all mandates and funds managed by PVBV (after consultation with the fund participants).
This lower limit relates to both the products and the behaviour of companies and governments. For example, producers of tobacco, controversial weapons, coal or tar sands are not included, nor are government bonds of countries on sanctions lists.
Stewardship
In addition to the inclusion policy and initial due diligence, PVBV also uses its influence as a shareholder to monitor developments at the companies in its portfolio and, where necessary and possible, to make them more sustainable. We do this by engaging in dialogue and achieving predefined sustainability improvements, by exercising our voting rights, and in extreme cases by conducting legal proceedings.
To promote the objectives of active and engaged ownership, we strive to work with like-minded institutional investors in line with the Dutch Stewardship Code. To this end, we participate in a large number of different international partnerships such as UNPRI, Eumedion, the Asian Corporate Governance Association, Climate Action 100+, Institutional Investors Group on Climate Change (IIGCC) or the Living Wage Platform (PLW) and further endorse relevant standards such as the Climate Agreement.
a. Dialogue and engagement
PVBV aims to enter into a constructive dialogue with companies in the investment portfolio or market participants about their policy or activities and to achieve predefined improvements in the field of sustainability (engagement). In this way, PVBV aims to prevent, mitigate and solve the possible negative sustainability effects of investments. Where appropriate, we also enter into dialogue with relevant stakeholders.
b. Vote
PVBV aims to vote at every shareholders' meeting and on all agenda items relating to every company in which it invests. This typically covers key strategy, financial and non-financial performance and risks, capital structure, and ESG topics. Our views on the usual agenda items can be found in the Proxy Voting Guidelines. Where necessary and possible, coordination is sought with other institutional investors.
The stewardship team within Total Portfolio Management is responsible for the implementation of the voting policy.
c. Legal proceedings
PVBV is actively involved in investigating (or having investigated) events that have caused damage to customers through misconduct on the part of listed companies on their legal merits and the collection of damage suffered as a result.
PVBV has set up internal systems that enable it to monitor worldwide where procedures can be conducted in the interest of its customers. PVBV investigates these possibilities and advises its customers with motivation whether or not to participate in these procedures, and if so, in what way.
A detailed description of how we enter into dialogue, vote, and are involved in legal proceedings is here .
Learn more
You can read more about how we deal with the negative sustainability impacts of our investments in our Implementation guidelines. Beliefs, Principles and Implementation Framework for Sutainable Investment
3. How do we take sustainability risks into account in our remuneration policy? art. 5 SFDR)
One of the principles of the remuneration policy is that it does not encourage short-term and risky behaviour. As indicated above, PVBV is convinced that sustainability risks affect the risk-return profile of investments. This conviction logically leads to the fact that the remuneration policy should not encourage the disregard of the sustainability risks of the investments.
Various measures have been taken to ensure this.
Firstly, a risk analysis is carried out every year on the remuneration policy. This risk analysis pays attention to, among other things, perverse incentives that prevent employees from behaving with integrity, such as:
- Activities that are purely focused on short-term results;
- Taking on undesirable risks, including sustainability risks;
- Acting contrary to the interests of the customers or the company
Secondly, HR has set up the performance cycle for the annual assessment of employees in such a way that employees are not (or cannot be) rewarded for taking undesirable sustainability risks.
Finally, employees with variable remuneration will only be awarded if they have achieved predetermined targets in a given year. These targets are a derivative of the objectives of the customers, PVBV or department. The possibility of reducing or reclaiming the variable remuneration also ensures that employees do not take unnecessary (sustainability) risks.
4. How do we integrate sustainability risks? art. 6 SFDR)
PVBV manages the sustainability risks in the funds and mandates and provides (pre-contractual) information to our clients on how sustainability risks are integrated into the investment decisions.
Funds
The information on how sustainability risks are integrated into their investment decisions and the assessment of the likely impact of sustainability risks on returns are included in the fund prospectus. It also refers to the Beliefs, Principles and Implementation Framework for Sustainable Investment.
Mandates
The information on how sustainability risks are integrated into investment decisions and the assessment of the likely effects of sustainability risks on returns have been or will be included in the mandate agreement with PFZW.
5. What are the main adverse effects on sustainability? art. 7 SFDR)
For the mandates (agreement) and the funds (prospectus), the principal adverse effects (PAI) are included in the pre-contractual information.
6. What are the environmental or social characteristics of our funds and/or mandates? art. 8 SFDR)
Where the funds and/or mandates promote environmental or social characteristics within the meaning of the SFDR, we provide additional (pre-contractual) information to our clients.
Funds
We have included the additional information about the ecological or social characteristics in Annex II to the prospectus with reference to the Beliefs, Principles and Implementation Framework for Sutainable Investment.
Mandates
We have included the additional information about the ecological or social characteristics in the mandate agreement with PFZW.
7. Sustainable investments as a goal( art. 9 SFDR)
Additional requirements apply to funds and/or mandates that aim at sustainability and meet certain criteria. At this time, we have not yet designated any of our funds and/or mandates as such a product within the meaning of the SFDR.
8. More information on the methods used to assess, measure and monitor environmental or social characteristics is given below. art. 10 SFDR)
Inclusions
Companies that do not meet minimum sustainability standards are not included in the investable universe. In this way, we prevent investments managed by PVBV from contributing financially to negative sustainability effects and therefore not in line with the norms and values of PVBV, its customers and their participants.
We apply a strict lower limit that applies to all mandates and funds managed by PVBV (after consultation with the fund participants). We use external data suppliers and our own analyses to determine the investable universe.
Agreements have been made with all internal and external managers about the investable universe. PVBV has set up monitoring, control and compliance systems for our internal managers, including in Bloomberg. An 'exclusion list' prevents investments from being made outside the investable universe.
External managers bear their own responsibility for compliance with and monitoring of this exclusion list in accordance with the contractual agreements. Mandaat Management monitors this. Every month, every external manager must issue a compliance statement, signed off by an independent compliance officer. PVBV checks its funds and mandates after each trading day to ensure that no investments have been made outside the investable universe.
CO2
PVBV uses three ways to measure and steer the positive contribution to the climate. First, PVBV will reduce the financed CO2 emissions of listed shares, credit and real estate portfolios by 50% between 2019 and 2030. The methodology followed is that of the Platform Carbon Accounting Financials (PCAF). This includes scope 1, scope 2 and (where possible per subsector) also scope 3 emissions.
This absolute target is steered on the basis of the CO2 intensity of the portfolios with specific targets for 2030. We use various external data suppliers, especially Trucost.
For the private markets, we determine which part of the portfolio is in line with the Paris Climate Agreement. That percentage is gradually being increased. The data comes from various sources, including GRESB.
We engage with companies to accelerate sustainability. Where necessary, we adjust our allocation by investing less or no longer in companies that are not making sufficient progress towards 'Paris' or by investing more in companies with clear transition plans.
Sustainable Development Investments in Listed Equities (SBA)
The actively managed part of the listed equity portfolio (SBA) is based on companies that qualify as 'Sustainable Development Investments' based on the revenue they generate from solutions for one or more of the Sustainable Development Goals. Since 2025, the SBA investment universe is no longer limited to SDIs, but also allows other companies as long as they meet the minimum sustainability standard, and the average SDG turnover percentage for the entire SBA portfolio grows from 25% to 35% in 2030. Revenue data is sourced from the SDI-Asset Owner Platform and Entis.
Stewardship
PVBV uses its influence as a shareholder to continuously monitor developments at the companies in its portfolio and to make them more sustainable where necessary and possible. We do this by entering into dialogue (dialogue), by achieving predefined sustainability improvements (engagement), by exercising our voting rights, and by conducting legal proceedings in extreme cases.
(i) Dialogue and engagement
PVBV has a stewardship team within Total Portfolio Management to coordinate the execution of engagement and to carry out the passively managed mandates itself.
The stewardship team determines in consultation with PFZW in which sectors and with which companies engagement will be conducted. Various (external) data sources and data suppliers such as Sustainalytics and MSCI are used to screen these companies.
PVBV monitors the progress of engagement processes carried out by recording them in a database. At the end of the engagement programmes and processes, PVBV determines whether the engagement programme has had the desired result and determines whether and which escalation steps should follow.
(ii) Stemmen (proxy voting)
PVBV votes actively and informed on behalf of its customers. PVBV does this on the basis of publicly accessible voting guidelines (the Global Voting Guidelines that are evaluated and updated annually). For the voice implementation, PVBV uses specialized voting service providers. These also provide voting advice based on the aforementioned voting guidelines of PVBV. With the voting platform, PVBV is able to cast its vote remotely at the listed companies. Every quarter, a sample is used to check whether the voting advice given is in line with PVBV's voting guidelines and the voting service provider itself issues a compliance statement in which they confirm compliance.
(iii) Legal proceedings
PVBV has set up internal systems that enable it to monitor globally where possible procedures can be conducted with regard to our investments that are in the interest of its clients. PVBV investigates these possibilities and advises its customers with motivation whether or not to participate in these procedures, and if so, in what way. In some cases, we use specialised law firms for a feasibility analysis and/or conducting proceedings, whether or not jointly with other injured institutional investors.
Article 8 SFDR information on website
The pre-contractual information on the environmental or social characteristics of our funds and mandates is set out above (see also below for each fund).
Investment funds
Our clients are sent all SFDR information, including the prescribed website information of all investment funds and/or the mandates in which they invest. However, on this compliance website we only place the SFDR website information of the investment funds.
PGGM Emerging Markets Equity PF Fund
1. Beliefs, Principles and Implementation Framework for Sutainable Investment
2. ESG guidelines
3. Annex II (in the context of Article 8 SFDR)
4. Website Disclosure (art. 10 SFDR/ art. 23 – 36 RTS)
5. Annex IV
PGGM Infrastructure Fund
1. Beliefs, Principles and Implementation Framework for Sutainable Investment
2. ESG guidelines
3. Annex II (in the context of Article 8 SFDR)
4. Website Disclosure (art. 10 SFDR/ art. 23 – 36 RTS)
5. Annex IV
PGGM Private Real Estate Fund
1. Beliefs, Principles and Implementation Framework for Sutainable Investment
2. ESG guidelines
3. Annex II (in the context of Article 8 SFDR)
4. Website Disclosure (art. 10 SFDR/ art. 23 – 36 RTS)
5. Annex IV
Last updated: 5 August 2025