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SFDR Sustainability information

Ethics Statement


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:

  • Integration of sustainability risks into investment decision-making processes (art. 3 SFDR)
  • Statement of the main negative effects on sustainability factors (art.4 SFDR)
  • Integration of sustainability risks into the remuneration policy (art.5 SFDR)

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.

Specifically, the Company:

  • integrates considerations relating to ESG factors in investment analyses and the resulting decision-making process;
  • adopts an active approach in the management and consideration of ESG factors in investments, adapting internal processes and procedures accordingly;
  • acquires adequate information on ESG investments from the delegated Asset Manager who manages the investments on behalf of the Company.


Specifically, the delegated Asset Manager 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 portfolios 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 underlying the product entail the updating of the relevant offer documentation.

Finally, the delegated Asset Manager considers exclusion criteria which include:

  • corporate issuers directly engaged in the production or marketing of non-conventional weapons prohibited by treaties promoted by the United Nations and whose use violates fundamental humanitarian principles;
  • government issuers who are involved in systematic human rights violations.


Non consideration of the negative effects on sustainability (Art. 4 SFDR)

The Company, which is part of the Cattolica Assicurazioni Group, currently does not take into account the main negative effects of investment decisions on sustainability factors. The Group has started to delineate the methodology for an initial definition of the due diligence policies to identify, assess and prioritize these effects starting from June 2021.


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.