Disclosure on (EU) 2019/2088 Regulation

P101 SGR S.p.A Gestore EuVECA manager (hereafter also “P101” 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 disclosure in the financial services sector (hereafter also the “SFDR Regulation” or “SFDR”) and per Final Report on the Regulatory Technical Standards (“RTS”) published by the European Supervisory Authorities.

Sustainability risk policies – art. 3

P101 is aware that the integration of environmental, social and governance (“ESG”) factors into the investment process and the implementation of efficient procedures to identify and prevent ESG risks allow promoting innovation and supporting economic development, significantly contributing to the sustainable growth of the country. For this reason, the SGR is committed to include ESG considerations in the evaluation and selection of investment opportunities to create and manage alternative investment funds able to generate 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 sector 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 sectorial experts if needed.

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

Consideration of adverse sustainability impacts – art. 4

P101 focuses on early-stage investments in companies, mostly Italian, operating in the digital sector 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, during the ownership phase, the SGR collects specific Key Performance Indicators (KPIs) for most of its investee companies, tracking progresses and actively supporting their ESG performance improvement.

Currently, P101 does not completely consider the adverse impacts of its investment decisions on sustainability factors, as established by article 4 of Regulation (EU) 2019/2088 and further detailed by the Final Report on the Regulatory Technical Standards (RTS). The SGR current position is due to the delayed approval of RTS, which has not allowed aligning the monitoring and reporting processes of the investee companies with the information required by the RTS. However, the SGR is further developing its ESG assessment tools, aiming also at identifying and measuring potential adverse sustainability impacts related to target and investee companies’ activities. In the near future, 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.