Non-consideration of negative impacts on sustainability
As part of its investment process, Innogest SGR S.p.A. does not consider the main Environmental, Social and Governance (“ESG”) risks for the following reasons:
- (i) the secondary legislation has not yet entered into force and there are still interpretative issues to be solved with reference to current legislation;
- (ii) the Alternative Investment Funds currently managed by Innogest SGR S.p.A. do not have ESG strategies, compliant to the current legislation.
Innogest SGR S.p.A. has in any case identified excluded investment sectors which could have negative impact on ESG risks.
For the same reasons, Innogest SGR S.p.A., as a participant in the financial markets that employs less than 500 employees directly at the closing date of the 2019 financial statements, does not consider the main negative effects of investment decisions on sustainability factors.
Innogest SGR S.p.A. is currently providing, for alternative investment funds in marketing period, that it shall commit to investing responsibly which shall include:
- (i) recognising the importance of the UNPRI Six Principles for Responsible Investments;
- (ii) incorporating ESG into its investment analysis and decision-making processes; and
- (iii) using commercially reasonable efforts to maintain and/or introduce appropriate ESG strategies to the management of the portfolio companies.
The current remuneration policy takes into account, when identifying and assessing the performance parameters, all the risks that may affect the aforementioned parameters, including sustainability risks. The possible occurrence of such risks is also taken into account in case of ex-post adjustments. On the other hand, it was not considered necessary, at present, to identify specific performance indicators linked to ESG objectives.
This declaration is issued on 10 th March 2021 and will be updated in case of substantial changes. Innogest SGR S.p.A. will evaluate whether to consider the main ESG risks as part of its investment process, and whether to take into account the main negative effects of investment decisions on sustainability factors pursuant to Article 3, No. 1 and to Article 4, No. 1, letter b) of the EU Regulation 2019/2088, when new Alternative Investment Funds will be set up, on a case-by-case approach.