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