Disclosure on (EU) 2019/2088 Regulation


The goal of the Regulation EU 2019/2088 is to strengthen the protection of the end investor by enhancing disclosure regarding sustainability-related topics within the management of the fund, assessing the risk related to sustainability profiles of the investment decisions. The Regulation EU 2019/2088 defines “sustainability risk” as “an environmental, social or governance event or condition that, if it occurs, could cause an actual or a potential material negative impact on the value of the investment”.

With respect to the SFDR Regulation and the technical standards provided by the Regulation EU 2019/1288, the SGR will adopt a gradual approach of alignment for both its methodological framework and information disclosure.

Article 3, Regulation EU 2019/2088

“Transparency of sustainability risk policies”

P101 is aware that the integration of environmental, social and governance (“ESG”) factors into the investment process, as well as the implementation of efficient procedures to identify and prevent ESG risks, allows the promotion of innovation and the support of economic development, significantly contributing to the Italian sustainable growth. The SGR is therefore committed to include ESG values into its evaluation and selection of investment opportunities to create and manage alternative investment funds able to generate both social and environmental value.

Sustainability risk is defined as “an environmental, social or governance event or condition that, if it occurs, could cause an actual or potential material negative impact on the value of the investment”.

P101 has developed a responsible investment approach, which foresees the identification and assessment of potential ESG risks and opportunities for each target investment. The SGR has adopted an internal ESG Policy, which specifies the main responsible investment strategies adopted by P101, aligned with the sector’s best practices. In particular, before taking any investment decision, the SGR applies exclusion criteria for controversial industries and plans to conduct ESG assessment analyses of the target investment, involving external sectoral experts if needed.

Finally, the relevant information gathered during this process is included in the investment memorandum, which is provided to the board of directors/investment committee to be able to make informed investment decisions.

Adopted exclusion criteria

P101 does not make investments in, nor does it grant guarantees or offer other financial or non-financial support activities, directly or indirectly, to:

  • companies engaged or involved in illegal and/or unlawful economic activities (such as production, commercialisation or other activities that are illegal and/or unlawful under the legislation applicable to the Fund or to the relevant companies or entities, and/or applicable to such production, trade or activities, including by way of example Research and Innovation activities considered illegal) or otherwise in favour of Excluded Investments;
  • companies engaged or involved, or controlling, directly or indirectly, companies engaged or involved, in one of the following sectors:
    • production and/or commercialisation of tobacco and/or related products, of alcoholic beverages (excluding wines and beers), distilled spirits and/or related products;
    • human cloning (including, but not limited to, human cloning for reproductive purposes, research, development and technical applications relating to human cloning for research purposes);
    • genetically modified organisms;
    • production or commercialisation of military systems, firearms, armaments, military supplies or ammunition, unless such activities are part of, or otherwise ancillary to, EU policies;
      gold buying and trading in precious metals retail;
    • production or commercialisation of pornographic material or in general pornography;
      production or commercialisation of electronic solutions or programmes that are specifically designed to unlawfully allow access to electronic networks, or the downloading of data in electronic form;
    • gambling and betting (including casinos, online casinos, internet betting and the like), or the production or commercialisation of products related thereto;
    • research, development, production, commercialisation or technological application relating to programmes, electronic solutions or other activities which are designed for (or specifically support any of) the areas referred to in the preceding paragraphs, or which are designed or intended to allow unlawful access to electronic networks or the unlawful downloading of data in electronic form;
  • companies that do not guarantee a respect for human rights in the exercise of any of their activities.

Article 4, Regulation EU 2019/2088

“Transparency of adverse sustainability impacts at entity level”

P101 focuses on early-stage investments in companies operating in the digital sector, mostly Italian, and it supports their growth particularly in terms of technological skills development, job creation, gender equality. The SGR is aware that in its investment universe, corporate social responsibility as well as social and environmental impact are crucial for long-term financial targets.

In this context, the SGR is currently collecting specific Key Performance Indicators (KPIs) for all of its investee companies. In particular, the SGR is considering taking into account the PAI for the Fund P101 and the Fund P102 gradually over the next period, while the Fund P103 identified and currently monitors PAI indicators for its investee companies and will start reporting on those indicators on 2024.

P101 is committed to include, within the monitoring and reporting system of the investee companies, the KPIs and information required by the RTS in order to fully disclose information regarding the consideration of negative effects of investment decisions on sustainability factors, as per article 4 of the SFDR.

Article 5, Regulation EU 2019/2088

“Transparency of remuneration policies in relation to the integration of sustainability risks”

The remuneration and incentive policies adopted by P101 currently do not consider sustainability risks as relevant criteria for quantifying the variable remuneration component. In the future, P101 will valuate to consider  variable remuneration components for the management team based on ESG sustainability factors, which are crucial for effectively managing sustainability risks.
In order to achieve this objective, P101’s Remuneration and Incentive Policy will incorporate assessments and incentive mechanisms for  bonus allocated to senior management and Investment team strictly related to the achievement of specific goals by the portfolio companies.