Statutory instrument SI no. 81 of 2020 (European Union shareholder rights Regulation) has implemented into Irish law Directive (EU) 2017/828 of the European Parliament and of the Council of 17 May 2017 (Shareholder Rights Directive II, hereinafter “SHRD2”) which amends Directive 2007/36/EC on the exercise of certain rights of shareholders in listed companies (“Shareholder Rights Directive” or “SHRD1”) as regards the encouragement of long-term shareholder engagement.

With SHRD2, the EU legislator has introduced transparency obligations aimed at promoting the engagement and long-term orientation of institutional investors (insurance and reinsurance companies that carry out life insurance and pension funds) and asset managers in investing in European listed companies in life portfolios and to ensure adequate information flows in the contractual relationship between institutional investors and asset managers.

BBPM Life dac (hereinafter also “the Company”) offers Unit Linked insurance products that invest in shares of Internal Funds and External Funds. The Company also manages the investments relating to the availability of the Company itself.

The strategic investment policy adopted in the individual Internal Funds is determined at the time of their constitution and is represented in the regulation of each Fund. The management of the individual Internal Funds is delegated by the Company to Anima SGR S.p.A. on the basis of a specific agreement that binds the manager to comply with the regulation of each Internal Fund, as well as to comply with the risk policy defined by the Company for each Internal Fund.
The details of the policies adopted by Anima SGR can be consulted on the institutional website at the following link: https://www.animasgr.it/IT/.

The strategic investment policy adopted in the individual External Funds is delegated by the Company to each manager of the External Funds; therefore, reference is made to the policies adopted by the individual managers, which can be consulted on the relevant websites.

Since the Company's equity investment strategy relating to the Internal Funds and External Funds, as well as the proprietary portfolio, does not envisage investing directly in shares and is carried out exclusively through OICR investments, BBPM Life has decided not to adopt a specific commitment policy.