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alstria office REIT-AG

alstria

Die alstria office REIT-AG ist der führende Immobilienmanager in Deutschland und konzentriert sich ausschließlich auf deutsche Büroimmobilien in ausgewählten Märkten.

Lobbying Activity

Response to Initiative on EU taxonomy - environmental objective

30 Apr 2023

Please find attached the feedback of alstria office REIT-AG to the consultation. Kind regards
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Response to Commission Delegated Regulation on taxonomy-alignment of undertakings reporting non-financial information

2 Jun 2021

Dear Sirs, alstria office REIT-AG is the largest German office owner listed on the Frankfurt stock exchange. We would like to thanks the Commission for the opportunity to provide feedback on the draft Delegated Act on Article 8 of the EU Taxonomy Regulation (TR). We welcome the Commission’s endahevor to specify the content, methodology, and presentation of the information to be disclosed by both non-financial and financial undertakings. We consider the proposed draft a good starting point for the conversation, with however still a substantial amount of clarification needed in order to acheive a workable document that can be both used for the purpose of corporate reporting and provide meaningful information to the users. (i) the current porposal is not fully aligned with IFRS. The notion of Capex, Opex are not IFRS GAAP items and therefore cannot be retraced back to the IFRS Account. Moreover it seems that the net turnover as defined in Article 2, point (5) of Directive 2013/34/EU might not be in full alignment with for example IFRS 15 and IFRS 16 definitions. The rules defined by ESMA with respect to reporting of Non GAAP KPI require that theses KPI are reconciled back to IFRS account (which is also a precondition for their auditability). The purpose of this reconciliation is essentially to allow the users to acheive comparabikity accross companies. It would be in that respect odd, if this new reporting requirement would lower the bar and does not allow for a clear reconcilation. (ii) The Capex plan, Under the current Green Bond frameworks a company allocated 100% of the proceeds of a green bonds to specific project which are (for the purpose of the Green Bond investor) assumed to be 100% financed with the Green Bond. The introduction of the capex plan seems to ignore the source of financing of the capex itself. The risk is that this will lead to the amount of financing allocated to the specific project is claimed twice. One at the level of the Green Bond fund (which will claim 100% credit) and once at the level of the equity fund investing in the corporate (which will claim the relevant Capex as per the SFDR), leading to the double counting of certain green finance and an over-estimation of the Green finance deployed. In order to avoid this effect, it could be recommendable that the company have separate capex plans for project financing vs corporate financing. This would be consistent with the way rating agencies requires corporate to make a difference between secure financing (at the project level) and unsecured financing (at the coporate level). (iii) timing of the investment and timing of reporting. While the proposal specific the timeframe underwhich the capex need to be invested, it does not specify the timing at which it need to be reported. The problem arise also in accounting and relate to a project that is undertaken over a mutiple reporting year. The risk is that in the absence of clear reporting rules, the same amount of capex is reported multiple times. (a measure which is accounted in the capex plan in year x, but only due in year x+1, will be reported twice (once in year x and once in year x+1). (iv) Net Capex vs Gross Capex, The inclusion of Capex under IAS 40, 38, 16, and 41, could imply that acquisition and disposals would be captured. If company sells a compliant asset for 100, and buy a compliant asset for 100, it could in the absence of clarification report an new capex of 100, while in actual fact the net change is 0. Theses are only selective examples which we believe however highlight the amount of additional clarification which is needed in order to allow a meaningful output of the reporting process. We are available to discuss theses forward if needed. Kind Regards, alstria office-REIT-AG
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Response to Climate change mitigation and adaptation taxonomy

17 Dec 2020

Demonstrably, the Technical screening criteria are prominently supportive of construction and/or acquisition of new buildings, while fully disregarding the most meaningful real estate activity to substantially support climate change mitigation, i.e. acquisition of existing buildings with the aim of renovating them. This is one of the key provision which demonstrates inconsistency of the EU Taxonomy with the objectives of the EU Green Deal and the Renovation Wave strategy. There are many other inconsistency, however, we think this is the most urgent issue to be addressed by the European Commission. The NZEB requirements fail to relate to embedded carbon, meaning that the current Taxonomy requirements do not seek to consider embedded carbon. We stress that a CO2 life cycle assessment plays a central role in the context of climate change mitigation. Embedded carbon represent the lion share of emission by the building industry in the next 30 years. The NZEB defined by the EU as “building that has a very high energy performance, as determined in accordance with Annex I. The nearly zero or very low amount of energy required should be covered to a very significant extent by energy from renewable sources, including energy from renewable sources produced on-site or nearby;” (DIRECTIVE 2010/31/EU, Energy performance of buildings”). We understand the principles of energy efficiency first is a core principle of the EU Renovation Wave and are supportive of the measure. However, we warn against undue inconsistencies between the various EU policies and also against the legitimacy of the decision making process which could undermine the democratic policy making process within the European Union. We call the Commission to align to its own NZEB definition as adopted by the EPBD. We also call on the Commission to review the EPBD, NZEB and EPC as part of the Renovation Wave agenda to better reflect the needs of the European climate policy objectives. This, however, should be at the level of the ordinary legislative procedure (Level 1 – legislative power) and not at the level of creating delegated acts (Level 2 – executive power). Furthermore we would like to stress that it is the actual performance of the buildings which is sought after by the investors (rather than the modelled one), and should be taken into consideration by the Taxonomy. There is significant evidence showing a gap between the modelled and actual performance of the buildings. We draw your attention to successful EU funded projects addressing the issue, e.g. The ALDREN project. The technical screening criteria are exclusively requiring absolute EPCs targets. This will lead to substantial unintended consequence of which the more important are : EPC [A, B, C, … E] rating is not something which is required by EU regulations resulting in several Member States not having them at all (eg.Germany, Belgium and Poland). Therefore, the exclusive use of EPCs will pose significant problems in the application of the EU Taxonomy. We want to remind the Commission that the objective of the EU Taxonomy is to help re-direct the financial flows into sustainable activities and thus help addressing climate change. The objective of the EU Taxonomy cannot be to make use of EPCs mandatory in a delegated act, while it has not been made mandatory in the ordinary legislative decision making process of the adoption of the EPBD. We also warn against the use of a standard as an absolute target (whether EPC and/or other schemes). For example, countries with the more stringent EPC A emission/consumption target, will have a strong incentive to reduce the target level in order to still be in position to attract capital, therefore moving in the wrong direction. Furthermore, what should matters is not the absolute level achieved but the overall improvement achieved. Improving a standing building from an EPC E, to EPC C, will have a better and more sustainable impact then building a new EPC A building.
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