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Cometa Pension Fund

PRI reporting framework 2020

You are in Strategy and Governance » Investment policy

Investment policy

SG 01. RI policy and coverage

New selection options have been added to this indicator. Please review your prefilled responses carefully.

01.1. Indicate if you have an investment policy that covers your responsible investment approach.

01.2. Indicate the components/types and coverage of your policy.

Select all that apply

Policy components/types

Coverage by AUM

01.3. Indicate if the investment policy covers any of the following

01.4. Describe your organisation’s investment principles and overall investment strategy, interpretation of fiduciary (or equivalent) duties,and how they consider ESG factors and real economy impact.

Investment Principles

The commitment stems from the importance of integrating social and environmental considerations and governance, which go beyond the sole target to any financial return of the investment, to embrace broader issues , in accordance with nature of the pension fund and with the awareness of acting as a long-term investor (fiduciary duty).

Cometa objective is to address the invested companies to more sustainable management styles, in order to take into consideration the expectations of present and future stakeholders involved , mitigating the negative externalities deriving from their activities .

Investment Strategy

In accordance with the investment strategy Cometa will engage with investred companies which are involved (also through the supply chain) in serious social or environmental controversies, such as:

1. violation of human rights,

2. violation of workers' rights,

3. occurence of significant environmental accidents,

4. violation of business ethics (corruption, conflicts of interest, ...)

5. violation of consumer rights (lack of transparency in communication on products and services, insufficient product safety, ...)

01.5. Provide a brief description of the key elements, any variations or exceptions to your investment policy that covers your responsible investment approach. [Optional]

01.6. Additional information [Optional].


SG 01 CC. Climate risk

01.6 CC. Indicate whether your organisation has identified transition and physical climate-related risks and opportunities and factored this into the investment strategies and products, within the organisation’s investment time horizon.

Describe the identified transition and physical climate-related risks and opportunities and how they have been factored into the investment strategies/products.

During 2019 Cometa - thanks to the support of an ESG rating agency - adopted an integrated approach for aligning with the Paris Agreement and the TCFD recommendations, considering the growing awarness of the risk posed by the climate change, the growing regulatory pressure and the fiduciary duty of asset owners and asset managers. The climate risk assessment framework is shaped by international and national authoritative norms, regulations, standards and initiatives, which define the principles of action upon which companies are assessed.

Transition Risks who have been identifired are: policy & legal, technology, market, regulation. All these risks are assessed through any potential fossil fuel involvement. Transition opportunities are: resource efficiency, energy source, sustainable products and services.All these opportunities are assessed  in terms of contribute toward the transition to a low carbon economy and climate related SDGs.

Physical risks management is assessed on how companies anticipate, prevent and manage the risk associated with the physical impacts of climate change (temperature increase, sea level rise, change in precipitations patterns, hurricanes). 

01.7 CC. Indicate whether the organisation has assessed the likelihood and impact of these climate risks?

Describe why your organisation has not yet assessed the likelihood and impact of climate risks

Cometa assesses the companies climate risks/opportunities management, not the impact likelihood. 

01.8 CC. Indicate whether the organisation publicly supports the TCFD?

01.9 CC. Indicate whether there is an organisation-wide strategy in place to identify and manage material climate-related risks and opportunities.


Cometa set up a methodological framework to identify all climate related risks and expects to implement an investment strategy of climate related issues in time for its 2020/2021 Annual Report, due out in early 2021.

1.10 CC. Indicate the documents and/or communications the organisation uses to publish TCFD disclosures.

SG 02. Publicly available RI policy or guidance documents


02.1. Indicate which of your investment policy documents (if any) are publicly available. Provide a URL and an attachment of the document.



02.2. Indicate if any of your investment policy components are publicly available. Provide URL and an attachment of the document.



02.3. Additional information [Optional].

SG 03. Conflicts of interest

03.1. Indicate if your organisation has a policy on managing potential conflicts of interest in the investment process.

03.2. Describe your policy on managing potential conflicts of interest in the investment process.

Interest conflict are regulated by the italian law n.703/1996. Internal code of ethics and compliance policies are designed to address and prevent any potential conflicts of interests. key points:

  • Cometa can invest in the corporates it belongs according to specific limit set up by italian law. In case Cometa has to communicate it to the italian pensione funds Authority.
  • Cometa's employees are required to review and certify compliance with our policies on an annual basis. 

03.3. Additional information. [Optional]

SG 04. Identifying incidents occurring within portfolios

04.1. Indicate if your organisation has a process for identifying and managing incidents that occur within investee entities.

04.2. Describe your process on managing incidents

It is possible to identify an incident that could occur within invested portfolio, through the ESG portfolio analysis periodically carried out by the ESG advisor.

Cometa defines an ESG incident as a tangible fact  based on information public, documented and traceable, incriminating a company on corporate responsibility issues and incorporating a potential investment risk.

When incidents' severity is critical, Cometa starts an Engagement activity. Immediately the dialogue is addressed to the asset manager to verity his awarness and level of information. Secondly the engagement is activated with the company involved in the allegation, to assess its reactivity and responsivness. Both engagements are conducted with the support of the ESG advisor. Until the dialogue is in progress, the company is included in a watch list, waiting for all relevant information to decide about the stock in portfolio.