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Ambienta SGR SpA

PRI reporting framework 2019

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PE 16. Approach to disclosing ESG incidents

16.1. プライベートエクイティ投資におけるESGのインシデントを投資家である顧客(LP)に開示する際の組織のアプローチについて説明してください。

Our approach emphasise transparency. In light of our Responsible Investment policy, and the policies we require portfolio to adopt (particularly the Business Integrity policy), we consider that all possible incidents will be managed properly and will be reported at company's board, GP level (we always hold seats at company's board level) and LP level. Our reporting procedure, which works for both standard and incident related ESG issues, is clear and goes from top management teams (the ESG Manager) to the company's Board (where Ambienta representatives always sit; 100% of cases) and from the company's Board to Ambienta and from Ambienta to LPs. All people involved, management teams at portfolio level and Ambienta representatives, are formally accountable and responsible for process implementation. Their annual bonuses take into account ESG integration besides all other standard factors. Incident related reporting works on an urgency based reporting procedure.

Another measure that we recently implemented is that Ambienta's representative on a profolio company's board gets direct access to all press clips the management gets access to; simoultaneously. We implemented this in order to gain access to the same raw stream of information at local level and to avoid being filtered by management and management's judgement.

We also disclose the environmental impact of our companies through our Environmental Impact Analysis (containing all assumptions and detail calculations) and its 11 Environmental Metrics (5 for Resource Efficiency and 6 for Pollution Control).