Disclosure on (EU) 2019/2088 Regulation

P101 SGR S.p.A Gestore EuVECA manager (also referred to as also “P101” or the “SGR”), as a financial market participant, provides the following disclosure as per articles 3 and 4 of the EU Regulation 2019/2088 on sustainability‐related disclosure in the financial services sector (also referred to as 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, 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.

Consideration of adverse sustainability impacts – art. 4

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 finalising a process of collection of specific Key Performance Indicators (KPIs) for all of its investee companies and monitoring of the ESG performance, actively supporting their improvement.

When the Regulatory Technical Standards (RTSs) come into effect (scheduled for January 1, 2023), P101 intends to fully consider  the adverse impacts of its investment decisions on sustainability factors, as established by article 4 of EU Regulation 2019/2088 and further detailed by the Final Report on the RTSs.

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.