RESPONSIBLE INVESTMENT

The Fund is structured in accordance with SFDR Article 8, promoting environmental and social characteristics alongside financial performance. Our objective is to invest in sustainable, scalable companies that deliver superior outcomes for all stakeholders.

RESPONSIBLE INVESTMENT

The Fund is structured in accordance with SFDR Article 8, promoting environmental and social characteristics alongside financial performance. Our objective is to invest in sustainable, scalable companies that deliver superior outcomes for all stakeholders.

OUR APPROACH

We embed ESG considerations into every phase of the investment process:

Pre-Investment

Systematic ESG screening and due diligence to identify risks, opportunities, and alignment with our investment strategy

Investment

Implementation of tailored ESG action plans with clear objectives, KPIs, and ongoing monitoring

Exit

Assessment of ESG progress and value creation achieved over the investment period.

CLEAR PRINCIPLES

Our investment activities
are guided by

Alignment with international standards

Focus on material ESG factors

A defined exclusion framework

Full respect for human rights
and ethical business practices

ESG Disclosure

Regulation (EU) 2019/2088 on sustainability-related disclosures in the financial services sector (the “SFDR Regulation” or “SFDR”), which entered into force on 10 March 2021, requires financial market participants, including asset management companies, to comply with specific transparency obligations regarding sustainability risks in relation to their investment management activities.

The SFDR Regulation has been supplemented by Commission Delegated Regulation (EU) 2022/1288, which sets out regulatory technical standards specifying, inter alia, the content and presentation of information relating to the promotion of environmental or social characteristics and sustainable investment objectives in pre-contractual documents and on websites. 

The transparency obligations applicable to financial market participants vary depending on the type of financial product. In particular, the SFDR places specific emphasis on financial products that promote, among other characteristics, environmental or social characteristics or a combination thereof (Article 8 SFDR), or that have sustainable investment as their objective (Article 9 SFDR), with differing implications for the investment process.

In particular, pursuant to Article 2(17) of the SFDR Regulation, a “sustainable investment” is defined as an investment in an economic activity that contributes to an environmental objective, as measured, for example, by key resource efficiency indicators relating to the use of energy, renewable energy, raw materials and water, land use, waste production, greenhouse gas emissions, biodiversity impact, and the circular economy; or an investment in an economic activity that contributes to a social objective, in particular addressing inequality, promoting social cohesion, integration, labour relations, or investment in human capital or economically or socially disadvantaged communities—provided that such investments do not significantly harm any of those objectives and that the investee companies follow good governance practices, including sound management structures, employee relations, remuneration policies, and tax compliance.

To comply with the transparency obligations set out in the SFDR Regulation, financial market participants are required to integrate into their decision-making processes policies aimed at assessing and continuously measuring sustainability risks associated with investments.
Pursuant to Article 2(22) of the SFDR Regulation, a “sustainability risk” is defined as an environmental, social or governance event or condition that, if it occurs, could have a material negative impact on the value of an investment.
Italia Independent Investment Partners SGR S.p.A. (the “SGR”) recognises that the management of risks and opportunities related to Environmental, Social and Governance (“ESG”) factors, and their integration into investment and risk management processes, contributes to enhancing value creation over the medium to long term.

The SGR acknowledges that the adoption and implementation of investment processes and strategies aimed at identifying and mitigating ESG risks can promote stable and sustainable economic growth, generating a positive impact on the broader development of the national economic system.

To this end, the SGR has adopted a Sustainable Investment Policy (the “ESG Policy”) to incorporate non-financial considerations into the structuring, planning and management processes of its investment funds, with the objective of generating additional social and environmental value through the integration of sustainability and social responsibility standards in the evaluation and selection of investment opportunities.

The SGR has integrated ESG principles into its investment decision-making process with the aim of assessing their potential negative impact on the performance of managed funds, while monitoring investments throughout their lifecycle.

At the same time, the SGR seeks to identify investment opportunities in companies that, while already compliant with minimum ESG standards at the time of investment, demonstrate potential for improvement in terms of environmental, social and governance impact. Such improvements may be supported through the SGR’s investment and are expected to generate positive returns both for investors, in economic terms, and for society as a whole, in terms of broader ESG value creation.

During the evaluation and selection phase, the SGR assesses:

  • the ESG risk profile of the target company
  • specific ESG issues and criticalities
  • the company’s approach to ESG matters (including any existing ESG policies)
  • and its capacity to address identified ESG risks

ESG due diligence is carried out by the SGR’s investment team using a proprietary assessment framework, with the support of external specialists where appropriate. The results are documented within the “ESG Assessment” section of the investment decision-making documentation.
Following the acquisition of a target company, the SGR evaluates how, through available governance and ownership tools, it can support the achievement of identified sustainability objectives.

ESG Products
The SGR currently does not manage any alternative investment funds classified under Article 8 or Article 9 of the SFDR.

Non-Consideration of Principal Adverse Impacts on Sustainability Factors
Statement pursuant to Article 4(1)(b) of Regulation (EU) 2019/2088 (SFDR) and Article 12 of Delegated Regulation (EU) 2022/1288 (RTS)

The SGR acknowledges the general principle that investment decisions made in respect of the funds it manages may have adverse impacts on sustainability factors (environmental, social and governance factors).

However, at this stage, taking into account the size of the SGR, the nature of its activities, the overall characteristics of the financial products managed, their stage of development, the sectors in which they invest, and the social characteristics they intend to promote, the SGR does not currently consider principal adverse impacts of investment decisions on sustainability factors.

The SGR reserves the right to reassess this position in the future, particularly in connection with the launch of investment activities relating to Article 8 SFDR funds. In such case, the SGR will update this statement accordingly, in line with the requirements set out under the SFDR and the related RTS.

Notwithstanding the above, from the launch of its first Article 8 SFDR product, the SGR intends to implement a structured investment selection process including:

  1. Screening activities;
  2. ESG due diligence; and 
  3. Ongoing monitoring of portfolio companies,


with the aim of progressively collecting the data necessary to prepare, in due course, the Principal Adverse Impact (PAI) Statement, in accordance with Annex I of Delegated Regulation (EU) 2022/1288.