Sustainability
Art. 3 – Transparency of sustainability risk policies
In accordance with Article 3 of Regulation (EU) 2019/2088 of the European Parliament and of the Council of November 27, 2019 on sustainability reporting in the financial services sector (the “Regulation (EU) 2019/2088”), Namira SGR.p.A. (“Namira”) adopts internal policies and procedures aimed at analyzing and managing sustainability risks, with the objective of integrating the assessment and management of these risks into its investment process, both at the stage of identifying investments and in the management of them in the portfolio.
Namira, as part of its plan to integrate ESG principles in the conduct of its business, has adopted an internal ESG policy, which defines the Principles and Guidelines related to the company’s environmental, social and governance topics, approved by the board of directors in March 2023
Art. 5 – Transparency of remuneration policies in relation to the integration of sustainability risks
In the remuneration policy adopted by Namira the objectives related to ESG topics are integrated, they are considered in the evaluation of performance within the incentive schemes; in addition, sustainability risks are considered in the correction for risk of performance objectives related to FIAs.
The principles and measures adopted by the SGR to ensure gender neutrality also have been integrated into the framework of the company’s remuneration policies.
No consideration of adverse impacts of investment decisions on sustainability factors
Art. 4 – Transparency of adverse sustainability impacts at entity level
In accordance with article 4 of the Regulation (EU) 2019/2088, currently Namira does not consider the adverse impacts of investment decisions on sustainability factors since the process aimed at a more correct assessment and monitoring of these impacts has not yet been defined; therefore Namira is not able to ensure complete compliance of internal processes with the relevanti legislation.
February 2022
Last updated July 2024