Programma 103 (hereinafter, “P103” or the “Fund”) is a reserved Alternative Investment Fund (AIF) established by P101 SGR S.p.A., an EuVECA Manager (hereinafter, “P101”), which promotes, among its portfolio companies (hereinafter, “PC”), environmental and social characteristics (hereinafter, “Characteristics”) in accordance with Article 8 of Regulation (EU) 2019/2088 (hereinafter, “SFDR Regulation”).

The Characteristics promoted by the Fund are aligned with the United Nations Sustainable Development Goals (hereinafter, “SDGs”) and specifically focus on gender equality (SDG 5), decent work and economic growth (SDG 8), industry innovation and infrastructure (SDG 9), reduced inequalities (SDG 10), and climate action (SDG 13).

P103 exclusively invests in PCs that can contribute to the Characteristics promoted by the Fund. To this end, P101 has adopted an investment strategy that includes verifying compliance with the requirements of Article 8 of the SFDR Regulation both during the pre-investment phase (negative screening and positive screening) and during the holding period (periodic monitoring and annual reporting).

The promotion of the Characteristics by the PCs is measured through specific indicators (“KPIs”) that have been defined based on the targets associated with the five SDGs that P103 used as a reference for identifying the Characteristics, and on the indicators of the B Impact Assessment as an internationally recognized impact measurement framework. The relevant data are collected from the PCs or, if not available, directly by the SGR through public sources or estimated data. In any case, P103 is committed to supporting the PCs in data collection to progressively increase the quantity and quality of such data.

P101 exercises a high degree of diligence over the Fund’s underlying assets with reference to (i) managing ESG risks, (ii) considering the principal adverse impacts of investment decisions on sustainability factors (“PAI”), (iii) promoting the Characteristics, and (iv) adhering to good governance practices.

The Fund has not yet identified a benchmark index to measure whether the Characteristics have been met.