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Cometa Pension Fund

PRI reporting framework 2020

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Outputs and outcomes

LEA 09. Number of companies engaged with, intensity of engagement and effort

Indicate the proportion of companies in your listed equities portfolio with which your organisation engaged during the reporting year. We did not complete any engagements in the reporting year.
We did not complete any engagements in the reporting year.

Number of companies engaged

(avoid double counting, see explanatory notes)

Proportion of companies engaged with, out of total listed equities portfolio

Individual / Internal staff engagements

Collaborative engagements


09.2. Indicate the breakdown of engagements conducted within the reporting year by the number of interactions (including interactions made on your behalf).

No. of interactions with a company
% of engagements
One interaction
2 to 3 interactions
More than 3 interactions

09.3. Indicate the percentage of your collaborative engagements in which you were the leading organisation during the reporting year.

Type of engagement

% leading role
  Collaborative engagements

09.5. Additional information. [Optional]

Most engagement activities occur over several years.  After the initial contact (letter or meeting) the dialogue continues with interaction, but objective need time to come. 

LEA 10. Engagement methods

10.1. Indicate which of the following your engagement involved.

10.2. Additional information. [Optional]

LEA 11. Examples of ESG engagements

11.1. Provide examples of the engagements that your organisation or your service provider carried out during the reporting year.

ESG Topic
Climate Change
Conducted by

Investors are concerned that the financial implications of climate change are not adequately disclosed by companies to the market. Insufficient disclosure hinders the capital markets from making well-informed asset allocation and risk pricing decisions, and could pose a financial stability problem.  Scope of the engagement is to promote and encourage the company transparency on climate-related issues. 




Scope and Process

The pool of italian investors engaged - through letters -with 20 international companies to request for information about recommendations issued by the Task Force on Climate related Disclosure (TCFD). Two questions were addressed:

1. Is the company a signatory of the statement to support the TCFD? 
2. Is the company’s reporting in compliance with the TCFD recommendations?

The assessment of the responses is still on going.

ESG Topic
Aggressive tax planning
Conducted by

The impact of tax-related risks can be severe and cover a large number of portfolio companies. Multinational enterprises have become much more vulnerable to unexpected tax assessments and increases in tax liability as strengthened enforcement has spread around the world. 

These concerns and political pressures led to a more concerted response from an international regulatory perspective through the OECD Base Erosion and Profit Shifting (BEPS) project. This project attempted the first comprehensive reform of international tax rules for over 80 years, on the basis of a consensus among nearly 50 states. 

Investors are largely unable to assess a multinational’s tax risks due to a lack of transparency around the strategies a company might be using and the policy and governance practices that guide those strategies. For this reason, the engagement was addressed to request information about Tax fairness principles.


Scope and Process

The pool of italian investors engaged - through letters - with 20 international companies asking about Tax fairness principles with two questions:

1. Tax policy signed by a board-level representative outlining the company's approach to taxation and how this approach is aligned with its business and sustainability strategy;
2. Tax governance as part of the risk oversight mandate of the board and management of the tax policy and related risks.

The assessment of the responses is still on going.


11.2. Additional information. [Optional]

The engagement initiatives launched in 2018 are still on going.