Introduction
In view of the commitment made by the European Union in the "Sustainable Action Plan", the EU Regulation 2019/2088 (hereinafter "SFDR") of 27 November 2019 establishes new information transparency objectives for financial market participants, with particular reference to the integration of sustainability risks - defined as "an event or condition of an environmental, social or governance nature that, if it occurs, could cause an actual or potential negative impact on the value of the investment" - in the investment decision-making processes, including the organizational, risk management and governance aspects of these processes.
Within this section, information is available regarding the Company, concerning:
For a better understanding of the section, it should be noted that "sustainability factors" relate to environmental, social and personnel issues, respect for human rights, and issues related to combating active and passive corruption, while "Main negative effects" refers to the impacts of investment decisions that may result in significant negative effects in any of the sustainability factors.
Integration of sustainability risks into investment decision-making processes (Art. 3 SFDR)
The Company has adopted a responsible investment approach that integrates the sustainability risk, as defined above, into its investment choices on the various asset classes in its portfolio: equity instruments, corporate bonds, government bonds, funds, ...
The integration of environmental, social and governance sustainability factors (summarized by the acronym "ESG") in the decision-making mechanisms related to investments is also driven by the awareness that the consideration of these factors can integrate the management of risks related to investments with a view to medium-long term sustainability.
The ESG criteria are applied by the Company to investments of a direct nature (equity instruments, corporate bonds, government bonds), while as regards investments of an indirect nature (funds, ETFs), the classification is made directly by the manager and / or by the delegated manager.
Specifically, the Company:
Specifically, the Company controls sustainability risks through the processing and monitoring of ESG ratings of the issuers, based on ESG scoring provided by specialized info providers. The monitoring activity takes into account, in addition to the level of the ratings themselves, the percentage of the portfolio on which an ESG rating is available and the concentration of the portfolio by rating classes.
The monitoring of sustainability risks is carried out through the evaluation of ESG strategies and approaches of the funds in which the product funds are invested.
The monitoring of sustainability risks also includes the qualitative assessment of other factors, such as whether issuers belong to certain business sectors that are considered more risky from an environmental or social perspective.
The sustainability risk monitoring activity described above leads to a classification of the funds in an increasing order of sustainability risk (ie risk classes from 1 to 4), with a view that a greater risk is associated with a greater potential negative impact on the returns of the product itself. The classification of the funds is monitored on a regular basis in accordance with predefined procedures and timelines. Any changes to the classification of the fund linked to the product entail the updating of the relevant offer documentation.
Statement on the Principal Adverse Impacts (PAI) of investment decisions on sustainability factors (Art. 4 SFDR)
The Company does not currently take into consideration the main negative effects of investment decisions on sustainability factors (PAI), as required by art. 4 of Reg. (EU) 2019/2088. The decision is mainly due to the current limited availability of the data necessary for the calculation and subsequent monitoring of PAIs at the entity level. A further limitation is due to the divergent methodology of each asset manager, often proprietary and influenced by the quality of the data made available by the issuers of the securities in which the fund invests.
Integration of sustainability risks into the remuneration policy (Art.5 SFDR)
The remuneration policy is consistent with the integration of sustainability risks, taking into account, for the purposes of variable remuneration, indicators that measure financial results, cost containment and regulatory compliance as required by the internal procedures adopted. At present, there is no explicit consideration of indicators measuring behaviours that promote investments with environmental and/or social characteristics and/or sustainable investments. However, the Company has initiated a process that will lead to take on specific indicators to promote the adoption of “green” behaviours.