Statement on the sustainability of Asset Management operations

Cassa Centrale Banca, in accordance with the new regulatory framework on sustainability (Regulation (EU) 2019/2088), has adopted new investment selection approaches as part of its decision-making processes, so as to give clients the opportunity to select asset management lines that are environmentally friendly, uphold human and gender rights, and are in line with good corporate governance practices.

In its investment decisions, Cassa Centrale Banca uses the following measures to integrate and consider the risks and main adverse impacts on sustainability factors:

• negative screening – this process consists in conducting an analysis of direct investments in order to implement a policy to exclude/limit financial instruments:
  • o related to issuers associated with controversial industries (e.g., arms);
  • o related to government issuers that are not members of international organisations promoting sustainable development policies and/or policies to combat crimes such as corruption and bribery;
  • o related to UCIs with severe sustainability risk;
  • o used to speculate on food commodities (e.g., coffee, cocoa, grains).

For specific issuers/financial instruments, these exclusions or limitations may be waived through specific approval processes.

• positive screening – this process consists in selecting investments based on the assessments offered by info-providers (ESG rating), the issuers or the producers of such instruments, to verify their environmental and/or social or sustainability characteristics.
• alignment with SFDR  – the definition of strategic thresholds for investments with environmental and/or social characteristics allows classifying asset management lines as follows:
  • o financial product as per art.8 SFDR (“light green”): at least 70% of overall assets invested in financial instruments or products of issuers selected according to the above screening criteria;
  • o financial product as per art.9 SFDR (“dark green”): at least 90% of overall assets invested in financial instruments or products of issuers selected according to the above screening criteria;
  • o other products that do not fall within the above categories and integrate sustainability risks in investment decisions.

The integration of such measures in the investment process has allowed Cassa Centrale Banca to classify the following asset management lines as financial products promoting, among other things, environmental or social characteristics or a combination of those characteristics (so-called “light green” financial products).

The high level of personalisation that characterises Private AM lines affects their classification under the SFDR based on the allocation of the percentage weights assigned to each fund, and, specifically, those that meet the requirements for “light green” and/or “dark green” products.