Statement on principal adverse impacts of investment decisions on sustainability factors
IMPact SGR S.p.A. (815600463D0CE2A96184) considers principal adverse impacts of its investment decisions on sustainability factors. The present statement is the consolidated statement on principal adverse impacts on sustainability factors of IMPact SGR S.p.A.
This statement on principal adverse impacts on sustainability factors covers the reference period from 1 January to 31 December 2023.
We consider Principal Adverse Impact at entity level by measuring and monitoring, depending on data availability and quality, the weighted average negative impact on sustainability factors of our investment funds; we consider and measure the mandatory principal adverse impact indicators and two voluntary indicators in compliance with the Sustainable Finance Disclosure Regulation (SFDR).
View the full “Statement” in pdf format here
Failure to take into account the negative effects of investment advice on sustainability factors
Within the scope of investment advisory, IMPact SGR declares that it does not take into account adverse impacts of investment decisions on sustainability factors when providing investment advisory services, with such scope of application being deemed appropriate in light of the following:
(i) the extremely residual nature of the advice provided;
(ii) the service model adopted whereby the investment advice, from an ESG perspective, is compliant with the sustainability criteria defined by the client;
(iii) the nature of the counterparty (i.e. professional client by right).
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 (hereinafter also “the SGR”), has a duty to act in the best interests of its clients through investment management that is aimed at generating sustainable, long-term value. By virtue of this fiduciary role, IMPact SGR believes that environmental, social and corporate governance (ESG) issues related to the issuers of securities may influence the performance of managed portfolios over time, at the level of individual companies, sectors, regions and asset classes. Consideration of these issues in the SGR’s investment decisions allows investors’ interests to be aligned with the broader objectives of the company.
Policy available here (english version)
Sustainability-related disclosures
The Sustainability-related disclosures for the individual products Art. 9 SFDR and Art. 8 SFDR is available here