ITAGO SGR S.p.A.
SFDR Regulation disclosure
ITAGO SGR (hereafter also “ITAGO” or the “SGR”), 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
ITAGO is committed to integrate ESG factors into the investment process with the long-term objective of generating value and positive impacts for investors and communities by identifying and cultivating opportunities for business growth and by monitoring and managing sustainability opportunities and risks.
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”. For this reason, the SGR has developed a responsible investment approach, which adopts tools and actions aimed at identifying and assessing sustainability risks and opportunities for each investment. In particular, before any investment decision is made, ITAGO adopts exclusion criteria and methodologies of analysis to identify the ESG risks associated with the potential investment on which, subsequently, in-depth analyses and evaluations are performed, also involving Due Diligence processes by external professionals.
These analyses offer a further dimension to the analysis of the investments’ risks and opportunities: the assessment of the real impacts of potential investments, alongside the analysis of the business, the market and the expected return, allows strengthening and improving target companies’ evaluation and selection processes.
No consideration of sustainability adverse impacts – art. 4
ITAGO does not currently consider the adverse impacts of its investment decisions on sustainability factors, as indicated by article 4 of the SFDR Regulation. ITAGO’s position can be explained due to the uncertainty about information to be disclosed, as the Regulatory Technical Standards (RTS), which contain details on how sustainability adverse impact should be reported, have not yet been approved by the European Commission at the time of this statement. Nevertheless, the SGR, as part of its strategy, recognizes the value of sustainability in the investment process and has defined an approach to integrate ESG factors into the investment selection and management process and to identify and assess the related potential negative effects on sustainability factors. In particular, during the initial screening phase, all potential investments are assessed using proprietary methodologies and, where necessary, due diligence activities are performed by external subject matter experts with the aim of identifying potential sustainability risks and understanding how these risks are managed and, if necessary, could be mitigated. In the management phase, the SGR actively engages with its investee companies, supporting them in defining common objectives and related action plans to improve their ESG performance and monitor their progress through the definition of specific KPIs. In addition, ITAGO intends in the next future to perform an analysis to assess the opportunities for integrating the data and information required by the RTS within the monitoring and reporting processes of the investee companies, with the aim of reporting information regarding the consideration of the negative effects of investment decisions on sustainability factors, as indicated by article 4 of the SFDR.
Venice, 31 March 2021