NOTICE PURSUANT TO ART. 3, 4, 5 of Regulation 2088/19 (SFDR)
Foreword and definitions
As expressly requested by Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 (hereafter “SFDR”) on sustainability?related disclosures in the financial services sector, this notice provides information on:
To that end, the following definitions apply:
Art. 3 Transparency of sustainability risk policies
For Banca Finnat Euramerica S.p.A. (hereafter “the Bank”) it is fundamentally important to integrate ESG factors into its financial instrument investment decision-making processes based on the portfolio management service and the consultancy service on financial instruments, in the conviction that these elements, in addition to encouraging sustainable economic and social development, also contribute positively towards the financial results of clients' portfolios whilst, at the same time, reducing risks. Sustainability factors are integrated by adopting strategies aimed at excluding from the investable universe issuers/financial instruments with a high sustainability risk.
In particular for its portfolio management service, the Bank follows specific procedures formalised in a special document approved by the Bank's Products Committee setting out the methodology and associated quantitative limits for the above purposes.
To sum up, sustainability risks are mitigated by establishing:
The application perimeter concerns:
For its consultancy service the Bank considers ESG criteria in drawing up documents supporting the provision of the service to the client. In particular, model portfolios addressing the provision of consultancy services also identify financial instruments that are sensitive to ESG themes, based on the declarations of the issuers (e.g. KID) or a third-party provider rating.
Art. 4 Transparency of adverse sustainability impacts at entity level
The Bank, in compliance with art. 4 of Regulation (UE) 2019/2088 (“SFDR”) on sustainability?related disclosures in the financial services sector, has decided to adopt an “explain” approach to the obligation to consider the principal adverse impacts of its investment decisions on ESG sustainability factors.
The Bank communicates that although, as a general rule, it does consider the principal adverse impacts of its investment decisions on sustainability factors (i.e. environmental, social and personnel issues, respect for human rights and issues around the fight against active and passive bribery), it is not currently able to provide the above disclosure. This is due to the fact that, to date, it has not been possible to identify and objectively measure the principal adverse impacts of said investment decisions on sustainability factors, since precise indicators and metrics have not yet been defined through which to verify the degree of likelihood of their occurrence as well as their intensity and possible irremediable nature.
The Bank maintains a proactive approach to defining the indicators and metrics with which the aforementioned adverse impacts are determined, also monitoring changes to the relevant regulatory provisions. The Bank shall provide prompt updates on this aspect.
Art. 5 - Transparency of remuneration policies in relation to the integration of sustainability risks
SFDR provides that the Bank must include in its remuneration and incentive policies information on how coherent they are with the integration of sustainability risks.
The Bank has launched a review of its remuneration and incentive policies to make clearer the above coherence of the incentive system through the pursuit of objectives in terms of sustainability risk management.
For further information on the management of ESG risks, see the information on the sustainability risk policy under art. 3 SFDR.
Rome 10 March 2021
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