Disclosure Regulation (UE) 2019/2088
Date of publication: March 9, 2021
Last update: August 6, 2021
Under review: August 1, 2022
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 – 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.
Information to be provided to investors pursuant to art. 10(1) of Regulation (EU) no. 2019/2088 of 27 November 2019 on sustainability‐related disclosures in the financial services sector, with regard to ITALIAN ENERGY EFFICIENCY FUND II
Italian Energy Efficiency Fund II (the “Fund”), established by Fondo Italiano per l’Efficienza Energetica SGR S.p.A. (the “SGR”), promotes environmental or social characteristics by investing in projects that contribute to the energy transition and decarbonisation process.
The financial product promotes environmental or social characteristics, but does not have the objective of sustainable investment.
The Fund’s investment strategy set out in the Management Rules (the “Rules”) pursues the promotion of environmental or social characteristics by (i) limiting investments in companies not in line with those characteristics, (ii) integrating specific environmental, social and governance characteristics into investment choices, and (iii) implementing principles of transparency and reporting practices in the portfolio companies that permit constant monitoring of such characteristics.
Investments are exclusively allocated in companies that comply with the restrictions established in the Fund’s investment policy summarised above.
The portfolio companies are periodically monitored based on the information provided by the companies held, and this monitoring is reflected in the sustainability reports that the SGR sends to its investors. Sustainability performance is measured using several general sustainability indicators and three specific indicators correlated with energy efficiency and the reduction of emissions.
In the phase prior to proceeding with an investment opportunity, the compliance with the environmental and/or social characteristics identified in the Rules is checked at the time when due diligence on those aspects is conducted by specialised advisors.
As part of the monitoring and management of its investments, the SGR has set up a strategy for exercising voting rights in the portfolio companies of the funds it manages to ensure that those rights are exercised consistently with the characteristics of the funds, thus including environmental and/or social characteristics.
The terms not otherwise defined herein shall have the same meaning assigned to them in the Rules.
2. Promotion of environmental and/or social characteristics
The Fund promotes environmental or social characteristics by investing in projects that contribute to the energy transition and decarbonisation process, which also include investments in energy efficiency projects and renewable energy projects, within the limits and according to the methods identified in the Rules.
The Fund promotes environmental or social characteristics, but does not have the objective of sustainable investment.
3. The financial product’s investment strategy
The Fund invests in qualified projects (“Qualified Projects”), which include investments in (i) energy efficiency projects (“Energy Efficiency Projects”) and (ii) renewable energy projects (“Renewable Energy Projects”), including those relating to the following sectors:
- Energy Efficiency Projects:
- energy efficiency, including construction, O&M and energy supply, relating (merely by way of example) to:
- street lighting;
- smart city projects, including (but not limited to) video surveillance, air pollution control, connectivity infrastructures and services;
- energy services in existing or newly-constructed buildings (including services to residential buildings/condominiums, public and private buildings and facilities);
- cogeneration and trigeneration plants, district heating/district cooling including rehabilitation or extension of existing networks as well as construction of new networks, energy efficiency in existing or newly-constructed industrial facilities and SMEs;
- heat and/or power generation from low-carbon energy sources (e.g., solar PV including rooftop PV and solar thermal, hydropower, biomass, biogas, geothermal, onshore and offshore wind, waste to energy), provided that the heat and/or power produced is partially or totally utilised, or are otherwise connected to, projects under a) above;
- production and storage of gaseous, liquid and solid energy carriers from low-carbon energy sources.
- Renewable Energy Projects: innovation, technologies, products and energy infrastructures related to energy efficiency (e.g., heat-air conditioning-ventilation products and technologies, batteries and storage, demand response, electrification of transport including electric vehicles, charging points and in general all related services, equipment and enabling infrastructure, heating, digitalisation projects, decentralised energy sources, etc.) – renewable energy plants, products and technologies.
The Fund invests in “Investee Companies”, i.e. any entity issuing the Instruments held (directly or indirectly) by the Fund. Those companies are as follows (see Article 4.5.3 of the Rules):
(i) ESCos and other services companies, equipment manufacturing or assembling companies or technology providers as well as other entities that develop, hold or manage a Qualified Project, and/or are active, in any capacity, in a Qualified Sector; or
(ii) companies set up in partnership with the entities under point (i) above.
An Investee Company may hold assets and/or investments other than the Investment effected by the Fund or effected before the Fund’s Investment, including, but not limited to, power generation projects with GHG emissions of more than 250 gCO2 equivalent per kWh-e. Such circumstance shall not affect the qualification of an Investment as an Eligible Investment, provided that the Commitments drawn for the Investment are destined entirely to the Qualified Project qualifying as Eligible Investment.
The Investments will mainly be made in Italian businesses: Investments in businesses that do not qualify as Italian Businesses shall not exceed 30% of the Aggregate Commitment.
Investments in the same Qualified Project may not exceed 15% of the Aggregate Commitments, or up to 20% of the Aggregate Commitments with the prior approval of the Advisory Board.
In particular, within the term of the Investment Period, Eligible Investments shall represent at least 60% of the Fund’s Invested Capital. The Aggregate Invested Capital in equipment manufacturing, assembling companies and in e-mobility projects will be considered Eligible Investments for a maximum amount equal to 20% of the Eligible Investments, while the remainder shall not be accounted for as Eligible Investments. Investments in charging points for electric vehicles are considered Eligible Investments in any case. Investments in manufacturing companies may not exceed 30% of the Aggregate Commitments, or up to 40% of the Aggregate Commitments with the prior approval of the Advisory Board.
In selecting and managing investments, the SGR shall comply with the environmental and social regulations set out by the European Union as well as the Environmental and Social Standards of the European Investment Bank (“EIB”).
Moreover, Annexes 2 and 5 of the Rules set out additional conditions that must be met by all Investments, and the conditions for those Investments to be classified as Eligible Investments (which will represent at least 60% of the Fund’s Invested Capital by the end of the Investment Period).
In particular, Annex 2 requires that, in brief, the following criteria be met in order for an Investment to be classified as an Eligible Investment:
- Capex: the majority of the portfolio company’s investment program must be aimed at implementing coherent and clearly-defined projects;
- Countries: Investments in Non-Italian Businesses cannot exceed 30% of the Total Commitment;
- Sectors: Eligible Investments are those in Energy Efficiency Projects and Renewable Energy Projects;
- Stages of completion: Eligible Investments are those which meet specific characteristics in relation to their stage of completion at the time of investment (as a general rule, Eligible Investments are only those in new or ‘greenfield’ infrastructure, save for the exceptions indicated in Annex 2).
As regards Renewable Energy Projects and Energy Efficiency Projects, the criteria indicated in Annex 5 for all Investments and Eligible Investments are summarised below.
Renewable Energy Projects
|SECTOR: RENEWABLE ENERGY (RE)|
|TECHNOLOGY||TECHNICAL CRITERIA(Only for Eligible Investments)||ECONOMIC CRITERIA(Only for Eligible Investments)||ADDITIONAL SPECIFIC ENVIRONMENTAL AND SOCIAL CONDITIONS(For all projects)|
|All technologies||Only commercially proven technologies, TRL9, can be used. Site-specific resource assessment, irrespective of the project size|
|Solar EnergyOn and off-grid generation plants (Photovoltaic)||Use of Tier 1 manufacturers, as per BNEF PV module maker tier 1 list||For major plants located in arid regions, a water management plan is required, assessing the sustainability of the water consumption during operation.|
|Onshore wind||Use of IEC type certificate turbines, suitable for the site conditions Resource assessment based on MEASNET recommendations||Project’s Levelized Cost of Electricity generation (LCoE) below fossil fuel generation. Please refer to the note below.||Preoperational birds and bats baseline study, as an input for the micro sitting and EIA process.|
|Geothermal||– Geothermal resource to be proven. No exploration/resource risk can be taken. – Electricity generation: Emissions of GHG to the atmosphere below the EPS (250 gCO2 equivalent per kWh-e). Alternative use of released CO2 considered if not a means to postpone the release of the gas in the atmosphere.||Electricity:Project’s Levelized Cost of Electricity generation (LCoE) below fossil fuel generation. Please refer to the note below. Heat:Demonstrate economic competitiveness against fossil fuel alternative.|
|Biomass||Biomass electricity-only plants (biomass power plants with no or insignificant export of useful heat are not eligible). Biomass schemes above 50 MWth thermal input capacity shall comply with the Best-Available Technique standards for large combustion plants (LCBREF), as referred to in the Industrial Emissions Directive 2010/75/EU, or equivalent national performance standards.||For electricity generation, project’s Levelized Cost of Electricity generation (LCoE) below fossil fuel generation. No economic justification calculation necessary for heat-only applications. Operating expenses exclude fuel and electricity consumption and will depend on installation size and type.||Restricted biomass: Waste wood, landfill gas or waste heat projects, investments in incinerators and processing of hazardous/toxic waste will be excluded. Biomass co-firing with coal shall be excluded. Additional sustainability criteria are set out for biomass, as indicated in Annex 5 of the Rules.|
Energy Efficiency Projects
|TECHNOLOGY||TECHNICAL CRITERIA FOR ELIGIBLE INVESTMENTS|
|All technologies||Projects where the investment is motivated by energy efficiency.|
Energy efficiency –
of heat and power
|The cogeneration plant has to meet the following three criteria. Calculations shall be pursued using the methodology for high-efficiency cogeneration as provided by EU Directive 2012/27/EU and its related Decisions 2011/877/EU and 2008/952/EC: · At least 50% of generated electricity comes from high-efficiency cogeneration, i.e. at least 50% of the generated electricity is cogenerated and Primary Energy Savings (PES) for this cogenerated electricity and useful heat reach at least 10% (principal condition);· At least 5% net primary energy savings are achieved on an annual basis for the entire generated electricity and useful heat (additional safeguarding criterion).· Cogeneration from fossil fuels is eligible only if CO2 emissions are below the threshold for the Bank’s emission performance standard of 250 gCO2/kWhel.- Small scale and micro cogeneration (< 1 MWel) leading to primary energy savings are also eligible.- Cogeneration investments using biomass that do not meet the above criteria are eligible as ‘Renewable Energy Investments’ by the percentage of the energy content provided by biomass, provided that they comply with the applicable eligibility criteria for biomass schemes.- Recovery of industrial waste gas is considered energy efficiency and is not subject to the minimum efficiency requirements of the directive.|
|Public lighting projects||Investments to improve the energy performance of public lighting are eligible. Extension or construction of new public lighting systems is generally excluded. Only measures identified by an energy audit carried out in line with EN 16247 (or another equivalent standard) are eligible.Economic assessment: A cost-benefit analysis that includes the multiple benefits of energy efficiency, when they are measurable and quantifiable, and the externalities. The expected energy savings will derive from a comparison with the baseline.|
|Energy Savings/Energy Efficiency in Buildings (Inside EU)||Building renovations are eligible ifa. Renovation measures are compliant with national energy performance standards and in line with the list of eligible measures (see below), or are indicated by an energy audit (in line with the European Standard for Energy Audit EN 16247 Energy), or by any other acceptable method to estimate the EE investment and the savings (i.e. a building EPC before and after (energy performance certificate according to the EPBD)).b. National energy performance standards for buildings comply with the EPBD, i.e. are in line with the cost optimum level.The construction of new buildings is not eligible.|
FOR THE BUILDING ENVELOPE
· Thermal Insulation of building envelope: Insulation materials (including water vapour barriers, weather membranes, measures to ensure air-tightness, measures to reduce the effects of thermal bridges and scaffolding) and products for application of the insulation to the building envelope (mechanical fixings, adhesive, etc.) — Design costs — Installation costs — Energy-related costs of other building materials, if applicable.
· Thermal insulation of Windows and doors: Glazing and/or glazing enhancement, frame, gaskets and sealants, installation costs.
· Other thermal refurbishment components, building-related measures, with impact on thermal performance: This can include e.g. external shading devices, solar control systems, and passive systems not covered elsewhere.
· Retrofit of existing buildings: Architectural or building changes that enable the reduction of energy consumption.
FOR BUILDING SYSTEMS
· Space heating: Generation and storage equipment (boiler, storage tank, heat generation controls) — Distribution (circulator, circuit valves, distribution controls) — Emitters (radiators, ceiling/floor heating, fan coils, emission controls) — Design costs — Installation costs.
· Domestic hot water: – Generation and storage (including solar thermal systems, boiler, storage tank, heat generation controls) — Distribution (circulator, circuit valves/mixing valves, distribution controls) — Emitters (tap valves, shower head) — Design costs — Installation costs (including insulation of the system and pipes).
· Ventilation systems: Heat generation and recovery equipment (heat exchanger, pre-heater, heat recovery unit, heat generation controls) — Distribution (fans, circulators, valves, filters, distribution controls) — Emitters (ducts, outlets, emission controls) — Design costs — Installation costs.
· Cooling: As a comfortable indoor temperature needs to be ensured, passive or active cooling measures or a combination of both (supplying remaining cooling demand) can be taken into account, depending on the specific climate conditions. In this category, the costs of active cooling systems are referred to. Passive cooling measures are either covered with the choice of reference buildings (e.g. building mass) or covered in the category ‘thermal insulation’ (e.g. insulation of roofs to reduce cooling demand) or the category ‘Other building-related measures with impact on thermal performance’ (e.g. external shading). Investment costs of active cooling systems include: Generation and storage equipment (generator, heat pump, storage tank, heat generation controls) — Distribution (circulator, circuit valves, distribution controls) — Emitters (ceiling/floor/beams; fan coils, emission controls) — Design costs — Installation costs.
· Lighting: Light sources and luminaires — Associated control systems — Applications to increase use of daylight — Design costs — Installation costs.
· Building automation and control: Building management systems which introduce supervising functions (separate system controls are accounted for within the specific system) — Technical intelligence, central controller — Controls (generation, distribution, emitters, circulators) — Actuators (generation, distribution, emitters) — Communication (wires, transmitters) — Design costs — Installation and programming costs.
· Connection to energy supplies (grid or storage): Investment costs could include: — Costs for first connection to the energy network (e.g. district heat, PV-system) — Necessary related installations.
· Decentralised energy supply systems based on energy from renewable sources: Investment costs could include: Generation, Distribution if applicable, Storage, Control devices, Design costs, Installation costs.
· Energy efficient building systems (Co-generation plants): Substitution of existing heating/cooling systems for buildings by (co-) or (tri-) generation plants that generate electricity in addition to providing heating/cooling (at substantially higher energy efficiency than separate production), associated Energy Audits, design and installation costs.
· Rehabilitation of district heating systems (expansion of district heating systems is excluded): Generation and distribution network improvements (circulator, circuit valves, distribution controls), Emitters (ceiling/floor/beams, fan coils, emission controls). Associated energy audits, design and installation costs.
The Rules also set out limits to the investment: sectors and companies that have a proven negative impact on society and the environment are excluded from the scope of investment of the Fund (inter alia, forced labour, non-sustainable fishing and production or trade in pesticides or herbicides).
During the holding period of investments, the Company conducts periodic monitoring of sustainability factors based on the information provided directly by the companies held, in relation to specific sustainability indicators. Lastly, the performance of the portfolio companies is the subject of a sustainability report that is also sent to investors, and summarizes the results of the portfolio companies in light of the sustainability indicators identified by the SGR.
4. Allocation of investments
The Fund’s asset allocation is 100% allocated to investments aligned with the environmental and social characteristics described above. Investments in non-Italian businesses cannot exceed 30% of the Fund.
5. Monitoring of environmental and social characteristics
As stated, during the holding period of investments, the company conducts periodic monitoring of sustainability factors based on the information provided directly by the companies held, in relation to specific indicators.
The investment strategy described in paragraph 3 above is actively pursued by the manager. Compliance of the strategy is continuously monitored by the control functions, based on information provided directly by the Investee Companies in relation to specific sustainability indicators. For each Investee Company, the SGR appoints an Environmental and Social Officer (“ESO”). The ESO of the Investee Company provides the SGR’s ESO with a report, at least annually, on the social and environmental management of the Investee Company, which also provides updates on the compliance of the investments with the eligibility criteria set out in the Rules, identifying any correlated risks and suggesting measures for their mitigation.
Moreover, at the end of each quarter, the ESO of the Investee Company sends the SGR’s ESO the scores assigned for each of the indicators identified, to assess and quantify the social and environmental impact generated by the activities carried out by the Investee Company.
The Fund also establishes and maintains an Environmental and Social Management System (ESMS) to ensure that each investment complies with the environmental and social safeguards identified. The Fund uses as guidance the ‘EIB Statement on Environmental and Social Principles and Standards’ and the ‘EIB Environmental and Social Standards.
In the divestment phase, the SGR also assesses the improvement of environmental, social and governance aspects of the investment, and verifies the related residual degree of risk. Based on those results, the best divestment strategy is defined, considering, among the possible options, also the ability to generate sustainable value over the long-term.
6. Methodology and data source
In order to measure the fund’s performance regarding sustainability, the SGR has identified the following indicators:
- Business Continuity: the commitment of the Investee Companies to maintain a high economic-financial profile;
- Anti-Corruption Measures: the mechanisms put in place to prevent corruption between private companies and in relation to the Public Administration;
- Health and Safety in the Workplace: creating and maintaining a health and safety management system to reduce accidents, and committing to creating awareness of the importance of the safety of employees and the main suppliers;
- Compliance with Environmental Regulations: compliance with municipal, regional and national regulations on environmental matters, linked to the energy service activities of the Fund’s Investee Companies;
- Waste Management: efficient management of the waste produced during energy service activities of the Fund’s Investee Companies;
- Relations with Financial and Institutional Stakeholders: strategies and mechanisms implemented to enhance and develop internal and external relationships;
- Training and Skills: investments in employee training;
- Energy Efficiency and Avoided Emissions: launch of strategies to increase energy efficiency operations and the related reduction in greenhouse gas emissions relating to the services offered by the Investee Companies. Three additional specific indicators have been identified under that indicator:
- Energy Savings: defines the energy savings obtained due to the implementation of energy efficiency projects by the Investee Companies;
- CO2 Emissions Avoided: defines the tons of CO2 emissions avoided through the implementation of Energy Efficiency Projects and Renewable Energy Investments by the Fund;
- Electricity from Renewable Sources: quantifies the generation of electricity from photovoltaic sources.
For each indicator identified, the related current or potential internal and external impacts are considered, in line with the GRI Standards defined in 2016 by the Global Reporting Initiative (GRI), and a score is assigned based on those impacts. Lastly, the scores are processed in aggregate form for each Investee Company, in order to assign a sustainability rating to each Investee Company in the Fund’s sustainability report.
The Company does not currently possess an IT system for data acquisition, aggregation and management as part of its reporting on the fund’s social and environmental performance using the indicators set out in point (6.). The data acquisition process, which uses information sheets for input to off-line excel files is therefore divided into a number of manual stages to aggregate the information. This could generate procedural and control limitations on the determination of indicators with regard in particular to the accuracy, assessment and presentation of the indicators in question. The methodology applied is described as follows:
- Business continuity: reclassification of the income statement in the Company’s and investees’ financial statements in accordance with the requirements of disclosure GRI 201-1: Direct economic value generated and distributed (201: Economic Performance);
- Anti-corruption measures: accurate information from the Company’s and investees’ legal departments upon any ascertained commission of corruption and its consequences;
- Health and safety at the workplace: identification of the number of fatal injuries, high-consequence injuries and recordable injuries and calculation of the respective rates as specified in disclosure GRI 403-9: Work-related injuries. If no official database exists for recording hours worked, investee companies will make use of reasonable estimates. The estimation method is shared with the management team and included in the definition of indicators because the data are monitored over time both by the subsidiaries and the Company itself
- Compliance with environmental legislation: this indicator is monitored quarterly by the Company and subsidiaries by means of a dashboard designed to identify possible instances of non-compliance with environmental legislation. Further monitoring is provided by external audits carried out for the subsidiaries with the Environmental management system (ISO 14001);
- Waste management: data are provided starting from the fourth copy in compliance with the Consolidated Environmental Law (Legislative Decree No. 152 of 3 April 2006). If the fourth copy is not available to the company, then data from the first copy are considered;
- Relations with financial and institutional stakeholders: this is a qualitative indicator;
- Training and skills: this indicator is defined starting with the number of training hours that the Company and investees deliver to their employees. If an official database for recording training hours does not exist, investee companies will make use of reasonable estimates. The estimation method is shared with the management team and is included in the definition of indicators because the data are monitored over time both by subsidiaries and the Company itself;
- Energy efficiency and avoided emissions:
- Energy savings: this indicator is defined as the difference between newly introduced high-efficiency technology and the previous technology. If accurate consumption data are not available, an estimate is used for energy efficiency generated by new technology compared with previous technology;
- CO2 emissions avoided: emissions avoided are calculated by using emission conversion factors and emission coefficients taken from national sector documents (e.g., Terna, ISPRA, etc.). These factors and coefficients are applied to energy savings generated before and after action taken by subsidiaries. The data published are restated if emission conversion factors and/or emission coefficients for the years considered are updated;
- Electricity from renewable sources: this indicator quantifies energy generated from renewable sources by investees that operate in the power generation sector. If accurate data on consumption are not available, a special estimation criterion is applied to determine it.
The Company has not encountered significant effects on the reliability of the environmental and social characteristics of products from the application of estimates and from the calculation methods used to define social and environmental performance indicators as described above.
8. Due diligence
The correct application of the sustainability assessments to fund assets is ensured by preliminary due diligence carried out by external advisors and contained in specific reports.
The Management Team, the Risk Management Function and the Environmental & Social Officer examine the results of those analyses, which represent the supporting documents used by the Board of Directors to make its decisions on whether or not to make investments.
9. Commitment policy
As part of the monitoring and management of its investments, the Company has set up a strategy for exercising voting rights in the investee companies of the funds it manages. Specifically, the strategy adopted by the SGR is based on the following principles:
- the Company constantly exercises the right to participate and vote in the shareholders’ meetings of the investee companies and constantly monitors the corporate events relating to the financial instruments held by the funds managed from time to time (thus, including the Fund);
- the methods for exercising the voting rights connected with the financial instruments held by the funds managed are determined in full compliance with the related management regulations and, therefore, also with the environmental and social characteristics promoted by them.