INTERNAL CODE OF CONDUCT

In order to ensure proper conduct of its administrative and supervisory bodies, its employees and co-workers, Eurizon Capital SGR has adopted the Internal Code of Conduct that these persons - in particular those who are involved in management decisions – must observe in dealing with personal transactions, receiving gifts, accept assignments or power of attorney on behalf of customers and for managing relationship with media and/or other external entities.

The provisions of the Code of Conduct are specifically intended to prevent situation of conflicts of interest, misuse of sensitive or inside information and improper conduct towards the Supervisory Authorities and Public Administration.

 

ORDER TRANSMISSION AND EXECUTION STRATEGY

As required by the best execution rules of the MiFID (Directive 2014/65/EC), UCITS (Directive 2009/65/EC, as amended and supplemented from time to time) and AIFM (Directive 2011/61/EU) and related EU regulations (second-level directives and regulations) and national implementing regulations (‘Regolamento Intermediari’ issued by CONSOB with resolution 20307 of 15 February 2018), the Company adopts all sufficient measures and implements effective mechanisms to obtain the best possible result for the UCITS managed and for the portfolios of professional and retail clients when executing orders on behalf of the assets managed in the selected ‘Execution Venues’. ‘Execution Venues’ means regulated markets, multilateral trading facilities (MTFs), organised trading facilities (OTFs) and ‘Intermediaries’ operating as systematic internalisers, market makers, proprietary traders or other liquidity providers, or entities performing in a third country a function similar to those performed by any of the aforementioned entities). For the same purpose, the Company adopts sufficient measures and implements effective mechanisms to obtain the best possible result even when it transmits orders to third parties (hereinafter ‘Intermediaries’) for their execution.

In accordance with the ‘Regolamento Intermediari’, the Companyhas therefore defined a strategy for transmitting and executing orders, with the aim of obtaining the best possible result (known as ‘best execution’) for the clients to whom it provides portfolio management services and for the UCITS it manages. The document describes the most significant elements of the strategies applied by the Company, including the execution factors considered relevant and the methods for selecting the Execution Venues and Intermediaries.

Further information on the order transmission and execution strategy

 

STRATEGY FOR THE EXERCISE OF RIGHTS TIED TO THE FINANCIAL INSTRUMENTS HELD BY THE UCITS MANAGED

The Company has adopted a specific strategy for the management of the exercise of speaking and voting rights pertaining to the UCITS managed, in accordance with the rules and self-regulation measures in force in the asset management industry.

 

ORGANISATION, MANAGEMENT AND CONTROL MODEL – LEGISLATIVE DECREE 231/2001

The Company, in accordance with Legislative Decree No. 231 of 8 June 2001 on the responsibilities of corporate bodies, has adopted an “Organisation, management and Control Model”, drafted as required by the Law, taking into account the guidelines laid out by the financial sector associations (ABI and Assogestioni) and the criteria and guidelines used by the Parent Company, Intesa Sanpaolo S.p.A.

MANAGEMENT OF CONFLICTS OF INTEREST

The Company has adopted a specific policy for the management of conflicts of interest, in respect of the provisions on the management of conflicts of interest contained in the directives on MiFID (Directive 2014/65/CE), UCITS (Directive 2009/65/EC, as changed and integrated over time) and AIFM (Directive 2011/61/EU), and the related EU regulations (second-level directives and rules), and national implementation legislation.

The Company has also adopted the “Independence Protocol for the Management of Conflicts of Interest” proposed by Assogestioni, with the aim of safeguarding the decisional independence of the asset management companies in making choices concerning the provision of asset management services.

 

REMUNERATION AND INCENTIVE POLICIES

The Company’s remuneration and incentive policies are based on those adopted by the Intesa Sanpaolo Group and, although not in contrast, not regulated, or more restrictive, in respect of the provisions of the European and National regulations governing the asset management industry. In its role as a “significant” asset manager, the SGR is held to respect all the strictest requirements of the regulations governing the industry.

 

ENGAGEMENT POLICY

The Company has adopted a specific “Engagement Policy”:

- in respect of Article 124-quinquies of Legislative Decree No. 58 of 24 February 1998 (so-called “Testo Unico della Finanza” - TUF), that governs how asset managers monitor and interact with participated companies, as well as

- to the ends of the adoption of the Italian Stewardship Principles for the exercise of administrative and voting rights in listed companies, describe the behaviours adopted by the Company adopts to stimulate engagement with the issuers in which it invests, integrating its commitment as a shareholder in the investment strategy.

 

SUSTAINABILITY POLICY

In accordance with the provisions of Regulation (EU) 2019/2088 of 27 November 2019 on Sustainability Disclosure in the Financial Services Sector (Sustainable Finance Disclosure Regulation) Eurizon Capital SGR has adopted the "Sustainability Policy", describing the financial instrument selection and monitoring methodologies implemented by the Company in order to include the sustainability risk analysis as part of its investment process.

These methodologies provide for the application of specific selection processes of the financial instruments, suitably tiered according to the characteristics and objectives of the managed products, taking into account environmental, social and governance factors (“ESG factors”) and principles of Sustainable and Responsible Investment (“SRI”).