Sustainability

Art. 3 – Transparency of sustainability risk policies

In accordance with article 3 of the Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability‐related disclosures in the financial services sector (the “Regulation (EU) 2019/2088”), currently, Namira SGR.p.A. (“Namira”) does not consider sustainability risks in its investment decision-making processes.
Namira, as part of its ESG integration pathway within the investment decision-making processes, has implemented an internal ESG Policy which define guidelines and principles related to Environmental, Social and Governance topics, approved by the Board of Directors in March 20233, and is finalizing the environmental risk model that will be used to include evaluations on the sustainability risks within the decision making processes.

Art. 5 – Transparency of remuneration policies in relation to the integration of sustainability risks

Currently the remuneration policy adopted by Namira does not include benchmarks or sustainability risk, in accordance with article 5 of the Regulation (EU) 2019/2088.

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 June 2023