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.
Intesa Sanpaolo Group Internal Code of Conduct
Internal Code of Conduct
ORDER TRANSMISSION AND EXECUTION STRATEGY
As provided for by the best execution criteria for 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 ("Regolamento Intermediari", introduced by CONSOB with Resolution 20307 of 15 February 2018), Eurizon Capital Real Asset SGR S.p.A. (hereunder also “the SGR”) takes all sufficient steps, and puts in place effective mechanisms, to obtain the best possible results when executing trading decisions for the UCITS managed or for the portfolios of professional and retail clients in the selected "Execution Venues", with specific reference to the purchase or sale of financial instruments or other assets to which such modalities apply. The "Execution Venues" are regulated markets, multilateral trading facilities (MTFs), organised trading facilities (OTFs) and "Investment Firms" operating as systematic internalisers, market makers, traders on their own account, or other liquidity providers or entities that perform a similar function in a third country to the functions performed by any of the foregoing. For the same end, when making purchases or sales of financial instruments or other assets to which these rules apply, the SGR adopts sufficient steps, and implements effective mechanisms, to obtain the best possible result even when it transmits orders to third parties (hereunder "Investment Firms") for execution.
In accordance with the “Regolamento Intermediari”, the SGR has therefore defined an order transmission and execution strategy, in order to obtain the best result possible (best execution) for the clients to which it provides portfolio management services, and for the UCITS managed. The document describes the most important aspects of the strategies pursued by the SGR, including the execution factors deemed relevant and the selection process for Execution Venues and Investment Firms.
In any case, the document was drafter taking into account the core activity of the products managed by the SGR, focused on strategies aimed at the selecting (i) AIFs of other asset management companies (multi-manager) specialised in private equity, private debt, infrastructure and real estate, as well as (ii) co-investments and (iii) direct investment in unlisted stocks.
Order Transmission and Execution Strategy
List of Investment Firms selected for the transmission/execution of orders
STRATEGY FOR THE EXERCISE OF RIGHTS TIED TO THE FINANCIAL INSTRUMENTS HELD BY THE UCITS MANAGED
The SGR 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.
Strategy for the exercise of speaking and voting rights pertaining to the financial instruments held by the UCITS managed
ORGANISATION, MANAGEMENT AND CONTROL MODEL – LEGISLATIVE DECREE 231/2001
The SGR, 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, and taking into account the guidelines laid out by the fiancila 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 SGR 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 (“Legislative Decree No. 58 of 24 February 1998 and subsequent changes - TUF” and "Regolamento Intermediari", introduced by CONSOB with Resolution 20307 of 15 February 2018).
Summary of the regulation for the management of conflicts of interest
The SGR 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 SGRs in making choices concerning the provision of asset management services.
REMUNERATION AND INCENTIVE POLICIES
The SGR’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.
Summary of the remuneration and incentive policies of Eurizon Capital Real Asset SGR S.p.A.
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 Real Asset 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”).
The policies reported in this section are a translation of the official policies in Italian language, available here