Guidelines adopted by the Ersel Group in terms of environmental, social and governance sustainability (Environmental, Social and Governance, hereinafter also "ESG").

Communication pursuant to Art. 3, 4, 5, 10 of Regulation 2088/2019 (SFDR)

Introduction and definitions
The Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019, relating to the disclosure on sustainability in the financial services sector (hereinafter, SFDR), was adopted in November 2019 and amended in June 2020 with the adoption of Regulation (EU) 852/2020 (the so-called Taxonomy of eco-sustainable activities). The SFDR, which is set within the context of the European Union Action Plan for Sustainable Finance,™ requires investment fund managers (“IFM”) of undertakings for collective investment in transferable securities and alternative investment funds (“AIFM”) to comply with harmonised rules on transparency with regard to sustainability risks and the consideration of adverse sustainability impacts and the provision of sustainability-related information. In particular, the SFDR introduces the specific disclosure obligations listed hereinafter:

  • information about the policies on the integration of sustainability risks adopted by the IFM in their decision-making processes relating to investments and in the provision of the advisory service (Article 3 SFDR); 
  • information whether the IFM takes into account or does not take into consideration the main negative effects of investment decisions on sustainability factors (art. 4 SFDR);
  • information on how the remuneration policy of the IFM is consistent with the integration of sustainability risk (Article 5 SFDR).

Some definitions useful for understanding the aforementioned communication are provided below. 

  • Sustainability risk: an environmental, social or governance event or condition which, if it occurs, could cause a significant actual or potential negative impact on the value of the investment;
  • Sustainable investment: investment in an economic activity that contributes to an environmental objective, measured, for example, by key resource efficiency indicators concerning the use of energy, the use of renewable energies, the use of raw materials and water resources and land use, waste generation, greenhouse gas emissions as well as the impact on biodiversity and the circular economy or an investment in an economic activity that contributes to a social objective, in particular an investment that contributes to the fight against inequality, or which promotes social cohesion, social integration and industrial relations, or an investment in human capital or in economically or socially disadvantaged communities provided that such investments do not cause significant damage to any of those objectives and that the companies benefiting from such investments comply with good governance practices, in particular with regard to solid management, staff relations, staff remuneration and compliance with tax obligations.
  • ESG: Enviromental, Social, Governance. 

Art. 3 Transparency of sustainability risk policies
The Ersel Group has always been attentive to environmental and social issues, the evolution of technical and scientific research in every area of activity. In this context, compliance with the principles of environmental, social and governance sustainability, together with the values that have always been supported by the Group throughout its history and already referred to in the Code of Ethics, are essential.

The factors on which the Ersel Group bases its sustainable commitment are:

  • Environment: the Group promotes and supports a culture of enhancement and respect for the environment through policies aimed at reducing environmental impact such as reducing the use of plastics, preferring suppliers who adopt environmental and ethical standards and who guarantee the socially responsible supply chain.
  • Social: the Group has been involved for over twenty years in the social field through the Paideia Foundation which works every day alongside families and children in difficulty, promoting effective and innovative projects, ensuring the creation of contexts that are attentive and respectful of the needs of smaller. The Group also adopts welfare policies for all company personnel belonging to the Group.
  • Governance: the Group has adopted a specific Governance structure aimed at managing and monitoring ESG issues. The corporate functions responsible for the supervision and management of ESG issues are:
    a. Board of Directors: approves the ESG policy and supervises the sustainability aspects thanks to the support of the Sustainability Committee (hereinafter also the "ESG Committee")
    b.ESG Committee: it is a committee with advisory and propositional functions. It is dedicated to the supervision of sustainability issues related to the company's business and its interaction dynamics with all stakeholders. With reference to ESG issues, it is not limited to carrying out an exclusively evaluative and advisory function in favor of the Board, but also has a propositional and investigative role, helping to ensure better monitoring of ESG risks.
    c. Investment Committee: makes appropriate investment choices taking into account the guidelines and indications provided by the ESG Committee.
    d. Risk management: periodically and continuously, compliance with ESG policies of the investments made.

The integration of ESG criteria into the investment strategy can in fact generate sustainable profits over time and, consequently, a solid prospect of creating value for all stakeholders. This also allows for more efficient management of financial, environmental and social risks, which can negatively affect the value creation of individual investments. Therefore, identifying and managing environmental, social and governance risks is part of the fiduciary duty to protect the value of investors' assets.

On this basis, the Group intends to integrate non-financial considerations into its product governance and investment process, which aim to generate added social and environmental value, through the integration of risks and sustainability factors, in the assessment and selection of investment opportunities.

The Group has decided to adopt specific tools aimed at defining the relevance of sustainability risks within the investment decision-making processes.
These tools are identified in: 

  • a system for assessing and measuring sustainability risks
  • a Due Diligence process for the definition of target investments based on the different types of product, investment and characteristics of the underlying and an approach and guidelines for assessing the risks to be applied to the different types of investment.

The Group maintains a proactive approach in reviewing internal policies relating to the integration of ESG risks into investment processes, and to assessing and monitoring their impact on product returns.Therefore, the information on the website in this area will be updated on an ongoing basis and in a manner consistent with the updates of internal policies. 

Art. 4 Transparency of the negative effects for sustainability
The Group, in compliance with art. 4 of EU Regulation 2019/2088 ("SFDR") relating to disclosure on sustainability in the financial services sector, has decided to adopt an "explain" approach to the consideration of the main negative effects of its investment decisions on ESG sustainability factors (Environment, Social, Governance). The Company announces that although, in general, it takes into consideration the main negative effects on sustainability factors in its investment decisions, the Company is currently unable to provide the information pursuant to art. 4, c. 1 letter a) of the SFDR, as detailed in art. 4, c. 2 of the SFDR. This is due to the fact that, at the moment, it has not been possible to identify, prioritize and, therefore, objectively measure the main negative effects of its investment decisions on sustainability factors (i.e. environmental, social and personnel issues, respect for human rights and issues relating to the fight against active and passive corruption). The Group maintains a proactive approach in defining the indicators and metrics through which to determine the aforementioned negative impacts, also monitoring the evolution of the reference regulatory provisions. The Group will be responsible for providing promptly.

Art. 5 Transparency of remuneration policies in relation to the integration of sustainability risks
The SFDR regulation requires the Group to include in its remuneration policy information on how these policies are consistent with the integration of sustainability risks. The Group has started the procedure for reviewing its remuneration policy in order to make the correlation of the incentive system with the pursuit of the objectives in terms of reducing the sustainability risk more evident. For more details on ESG risk management, see the information on the sustainability risk policy pursuant to art. 3 SFDR.


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