SFDR

Statement on adverse impacts on sustainability pursuant to Article 4 of Regulation (EU) 2019/2088

IMPact SGR has already adopted a negative and positive ESG screening, as described in the Policy for the Management of Sustainable Finance Products; however, considering that…

  • the reference regulatory framework needs to be supplemented by the detailed provisions contained in a specific delegated regulation of the European Commission, currently published in draft form, which is scheduled to enter into force on January 1st 2022;
  • the detailed provisions referred to in the previous point do not serve as a further specification of the provisions contained in Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability disclosures in the financial services sector, as amended by Regulation (EU) 20230/852 of the European Parliament and of the Council of 18 June 2020 on establishing a framework to encourage sustainable investment and amending Regulation (EU) 2019/2088, but as a necessary complement to the first-level framework;
  • IMPact SGR employs less than 500 people directly;

although IMPact SIM has already embarked on an internal process aimed at integrating risk and sustainability factors into its decision-making processes, at this first stage it declares that it does not take into consideration the negative effects of investment decisions on sustainability factors pursuant to Article 4(1)(b) of Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019, for the reasons referred to above.

IMPact SIM, in the future, intends to take into consideration the negative effects of investment decisions pursuant to Article 4(1)(a) of Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 once the relevant regulatory framework is fully established.

Remuneration policies

IMPact SGR S.p.A. has adopted and published on its website a “Remuneration Policy” consistent with the integration of sustainability risks. In particular, the Policy aims to ensure, inter alia, the consistency of workforce remuneration with the SGR’s sustainability objectives: it is therefore expected that the SGR Board of Directors shall determine the criteria for the remuneration of all key personnel, ensuring that the remuneration system and related mechanisms are also consistent with the integration of sustainability risks. Lastly, it is established that the variable component of the remuneration of the most relevant personnel is determined on an annual basis, also assessing qualitative indicators, enhancing the achievement of the ESG objectives and impact objectives of the SGR for the products pursuant to Articles 8 and 9 of Regulation (EU) 2019/2088. For further details, please refer to the text of the Policy, available here (italian version)

Policy on the Management of Sustainable Finance Products

IMPact SGR (also referred to “the SGR”), has the duty to act in the best interests of its clients by aiming to generate sustainable, long-term value. By virtue of this fiduciary role, IMPact SGR believes that company-level environmental and social performance may influence the financial performance of managed portfolios over time, at the level of individual companies, sectors, regions and asset classes. Consideration of these aspects in the SGR’s investment decisions thus allows investors’ interests to be aligned with the broader objectives of society at large.” Policy available here (english version)