Disclosure Regulation (UE) 2019/2088
Date of publication: March 9, 2021
Last update: April 21, 2021
Disclosure pursuant to Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 relating to information on sustainability in the financial services sector
Art. 3 – Transparency of sustainability risk policies
Italian Fund for Energy Efficiency SGR S.p.A. (the “Company”), is among the first Italian managers to deal specifically with energy efficiency and, in this context, pays particular attention to the issue of sustainability and the impact of its investment activities. To this end, the Company has signed the Principles for Responsible Investment adopted by the United Nations and has integrated the assessment of sustainability risks, as defined by Regulation (EU) 2019/2088, as part of its investment process, in order to identify and manage those sustainability risks that are likely to create potential impacts for the Company and for the AIFs managed.
In particular, the regulations of the AIFs managed by the Company require it to exclude investments in business sectors characterized by greater exposure to sustainability risks due to their specific characteristics.
From another point of view, the identification, analysis and management of sustainability risks is integrated into the Company’s investment process also through the adoption of specific procedures which require the Company to identify, during the evaluation and selection phase of investment opportunities, sustainability risks that may be relevant in relation to the specific characteristics of the potential investment, the target company and the economic sector or geographical areas in which it operates. To this end, in the preliminary phase of the investment, these processes require that before pursuing an investment opportunity, due diligence is carried out by external advisors with the aim of assessing the risks and opportunities, including with reference to sustainability risks. The results of this analysis are included in specific due diligence reports which are subjected to examination by the management team, the risk management function and the Environmental & Social Officer identified by the Company. These documents, together with the risk report prepared by the risk management function which also highlights any sustainability risks associated with the potential transaction, constitute, in addition to other evaluation elements, the documentary basis that is used by the Board of Directors to make its decisions in on the related investment opportunity.
During the holding period of an investment, the Company finally carries out a periodic monitoring of the sustainability factors based on the information provided directly by the portfolio companies in relation to specific KPIs in terms of sustainability.
Art. 4 – Transparency of the negative effects for sustainability at the level of the subject
The Company does not currently take into consideration the negative effects of investment decisions on sustainability factors but, following the adoption and entry into force of the regulatory technical standards that will establish detailed requirements regarding the content, methodologies and presentation of the information about the sustainability indicators identified by the SFDR Regulation, and following the clarification of the relevant interpretative issues currently still open, the Company will re-evaluate its position in relation to the publication of the negative impacts on the sustainability factors and, if it decides to provide such information, will update the website accordingly. At the moment, the SGR does not take into consideration the negative effects of investment decisions, nor has it defined policies relating to the identification and prioritization of the main negative effects for sustainability and the related indicators given the difficulty of defining objective indicators and metrics at present with which to be able to carry out a realistic assessment of the potential negative impacts of one’s investment activity on environmental, social matters or in relation to factors – among other things – concerning personnel, respect for human rights and issues relating to the fight against active or passive corruption.
Art. 5 – Art. 5 – Transparency of remuneration policies relating to the integration of sustainability risks
The Company is required to adopt sound and prudent remuneration and incentive policies that reflect and promote sound and effective risk management and that do not encourage risk taking that is inconsistent with the risk profiles and regulations of the funds it manages. In application of this principle, the Company’s remuneration policies do not encourage the assumption of sustainability risks.
In particular, the assessment of the results taken into consideration by the Company for the purpose of the allocation of variable remuneration is carried out net of any negative impacts deriving – ex ante or ex post – from the risks assumed by the company, including any sustainability risks.