Article 4, Regulation EU 2019/2088 “SFDR”
“No consideration of adverse impacts of investment decisions on sustainability factors”
Premise
P101, in accordance with Article 4, paragraph 1, letter b) of the SFDR, does not take into consideration the principal adverse impacts (“PAI”), i.e., the most significant negative impacts of investment decisions on sustainability factors relating to environmental, social, and employee matters, respect for human rights, anti-corruption and anti-bribery matters.
Reason for not considering the PAI
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 collection of PAI indicators across the entire investment portfolio is therefore not always straightforward, and, in accordance with the principle of proportionality, P101 has embarked on a gradual approach to considering PAI, which is currently limited to the investments of Fund P103.
Additionally, the SGR is currently collecting for Fund P102 specific ESG Key Performance Indicators (KPIs) for all of its investee companies that help in assessing the negative externalities of investments.
In any case, the SGR is aware that in its investment universe, ESG factors as well as social and environmental impacts are crucial for long-term financial targets, therefore applies specific exclusion criteria for controversial industries such as:
- 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.
- 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.
The Company reserves the right to change its position regarding the consideration of PAI and will update this information, accordingly, as provided for by the SFDR Regulation and the RTS.