THE ROADMAP FOR ITAGO

ITAGO SGR has launched a project to integrate ESG (Environmental, Social, Governance) factors into the investment strategies and management processes of the portfolio companies

ITAGO SGR bases its investment strategy on the opportunities for development, efficiency and innovation offered by the world of Italian SMEs.

As part of its strategy and approach, the SGR recognizes the value of sustainability in the investment process: the integration of ESG factors is in fact a central need to identify and cultivate the growth and development opportunities of companies, monitor and manage risks and opportunities and generate value and positive impacts for investors and communities.

For this reason, the SGR is committed to integrating ESG factors within the investment selection and management process, adopting targeted tools and actions for each phase of their life cycle.

Policy ESG Report 2022 Report 2023 Report 2024

Statement on principal adverse impacts of investment decisions on sustainability factors

PAI Disclosure 2022 PAI Disclosure 2024 PAI Disclosure 2025 PAI Disclosure 2026

ITAGO SGR is a signatory to the Principles for Investors in Inclusive Finance (PIIF) – a responsible investment framework housed within the PRI initiative for investors focused on expanding access to affordable and responsible financial products and services to those traditionally excluded.

ITAGO SGR S.p.A.

SFDR Regulation disclosure

ITAGO SGR (hereinafter also “ITAGO” or the “SGR”), as a participant in the financial markets, provides the following disclosure in accordance with Articles 3 and 4 of Regulation (EU) 2019/2088 on sustainability reporting in the financial services industry (hereinafter also “SFDR Regulation”) as supplemented by Commission Delegated Regulation (EU) 2022/1288 of April 6, 2022.

Transparency of sustainability risk policies – Article 3 SFDR Regulation.

ITAGO is committed to integrating ESG factors within the investment process by monitoring and overseeing sustainability risks.

Sustainability risk is defined as “an environmental, social or governance event or condition that, if it occurs, could cause a significant actual or potential negative impact on the value of the investment.” Therefore, SGR has developed an approach to responsible investment that adopts targeted tools and actions aimed at identifying and assessing sustainability risks for each investment. Specifically, before making any investment decision, ITAGO uses exclusion criteria and analytical methodologies aimed at identifying potential sustainability risks associated with the potential investment on which, subsequently, in-depth analyses and assessments are carried out, including by resorting to Due Diligence processes by external professionals.

These analyses offer an additional dimension for the analysis of investment risks and opportunities: the assessment of the sustainability risks of potential investments, alongside the analysis of the business, market, and expected return, makes it possible to strengthen and improve the process of evaluating and selecting target companies.

Transparency of adverse sustainability effects at the subject level – Art. 4 SFDR Regulations

ITAGO considers the Principal Adverse Impacts (or “PAIs”) of its investment decisions on sustainability factors in line with Article 4 of the SFDR Regulation.
To this end, ITAGO has developed a proprietary tool for the collection and periodic reporting of a set of sustainability indicators, integrating the sustainability adverse indicators for monitoring the PAIs starting from 2022.
Please refer to the following document for further details on the monitoring result, the planned actions in order to reduce the PAIs and the methodology used for reporting.

Venice, 30 June 2023

NEIP III SICAF S.p.A.

SFDR Regulation disclosure

NEIP III SICAF S.p.A. (hereafter also “NEIP III” or the “SICAF”) is an investment company, advised by ITAGO SRL, dedicated to small and medium-sized Italian companies, which has invested in a portfolio of nine companies, of which five have already been divested. The remaining four holdings are in the divestment process.
The SICAF, as a financial market participant, provides the following disclosure as per article 3 and 4 of the Regulation (EU) 2019/2088 on sustainability‐related disclosures in the financial services sector (hereafter also the “SFDR Regulation”) and per the Final Report on the Regulatory Technical Standards (“RTS”) published by the European Supervisory Authorities.

Sustainability risks policy – art. 3

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”.
NEIP III has not developed a structured approach for the integration of sustainability risks within the analysis of investments’ risks and opportunities in the evaluation and selection process of target companies. However, before any investment decision is taken, specific exclusion criteria and analyses are applied for each potential investment in line with the SICAF’s regulations and the applicable legislation.
Given the imminent closure of the company and the fact that all holdings are in the divestment process, it was not deemed necessary to provide the SICAF with additional measures for the integration of environmental and social risks.

No consideration of sustainability adverse impacts – art. 4

Given the imminent closure of the company and the fact that all holdings will be divested by next years, NEIP III is not considering publishing a Statement on Sustainability Adverse Impacts as indicated in the Report on the RTS.

Venice, 28 September 2022