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ENPAP - Ente Naz. Prev. e Ass. Psicologi

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.

The Board of Directors of the Fund has approved the adoption starting from 2016 of the Management, Organization and Control Model of the Code of Ethics and the appointment of the Supervisory Body to implement a governance system inspired by Decree 231/2001.

In terms of investments and ESG, in its Code of Ethics, ENPAP states: "The Fund aspires to maintain and develop the relationship of trust  towards those who make investments related to the Fund's activities, by imprinting its relationships based on principles of impartiality, honesty, fairness and confidentiality, while protecting Members, Employees and the Community." (art.1) and "The Fund acts in line with the needs of the communities where it carries out its action, contributing to their economic, social and cultural development and placing the protection of the environment .." (art.6)

In terms of investments and ESG, in its General Criteria on investment of ENPAP, the Fund describes its investment strategy and states it "favors financial instruments with a low degree of risk".

The policy "Principles of sustainable investment and responsibility of ENPAP" is dedicated to the SRI strategy of the fund.

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]

ENPAP SRI Policy is based on the principle that ESG approach  allows to improve the risk / return profile of the investment in the medium and long term.
This document will be subject to revision, at least every three years, by the Board of Directors on the proposal of the Investment Commission.

Criteria of "exclusion":

- Exclusion of countries
a) which do not guarantee respect for civil rights (human rights and religious freedom); b) which do not guarantee respect for political freedoms (freedom of expression and association).
- Exclusions of Companies
a) that do not guarantee compliance with the principles contained in the ILO (International Labor Organization) convention regarding the protection of child labor;

b) that do not guarantee equality between men and women in work and in remuneration policies;

c) whose turnover derives from the following controversial activities: Weapons (nuclear, biological and chemical, mass destruction weapons or parts of them; chemical, biological and radioactive toxic agents; missiles capable of carrying weapons of mass destruction; fragmentation weapons and anti-personnel mines), Gambling  and Pornography;

d) who have been convicted of serious violations of the anti-money laundering and anti-terrorist financing legislation.

Criteria of "inclusions"
For investments represented by shares or shares in the share capital, debt securities or mutual funds / SICAV shares, only financial instruments that have an "ESG rating" deemed satisfactory, or at least equal to " BB "(according to the" MSCI ESG Ratings "valuation metric) or at least equal to" Limited "(according to the" VIGEO EIRIS "valuation metric) or equivalent.


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 why your organisation has not yet gone through a process to identify transition and physical climate-related risks and opportunities.

During 2019 ENPAP approached the climate risk of an invested portfolio with a Carbon Footprint and Energy Transition analysis, to addreass investment decisions that integrate the mitigation of the climate change risk and to identify investment opportunities aligned with the transition to a low carbon economy. 

These information have not yet been factored into the investment process, but from 2020 ENPAP could engage with companies that have a weak position in the energy transition.

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

Explain the rationale

The rationale is that ENPAP will decide to supports TCFD in the next futureThe Carbon Footpri

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


The Carbon Footprint & Energy Transition analysis carried out by the ESG advisors on a half-yearly basis is the monitoring tool tha enble ENPAP to identify, monito and manage the climate risks and opportunities

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.

ENPAP discloses on its website a Code for conflict of Interests. In the article 6, the Fund within its own asset management model, guarantees the full independence of the control functions with respect to the management functions. The Finance Department verifies that the investment process is consistent with the Fund objectives.

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

With the support of Vigeo Eiris, ENPAP identifies controversies faced by the companies in its portfolio.  A controversy is an information,a flow of information, or a contradictory opinion that is public, documented and traceable, allegation against an issuer on corporate responsibility issues. Vigeo Eiris - the rating agency that provides the analys to the Fund - provides an opinion on companies risk mitigation based on the analysis on three factors: severity (level of impact on stakeholders), responsiveness (ability demonstrated by an issuer to dialogue with its stakeholders and implement corrective measures) and frequency ( number of controversies faced).  

"ENPAP undertakes to carry out, where possible, a concrete activity of "engagement", that is, an active commitment in urging the companies in which it invests to the continuous improvement of its policies regarding "ESG", also through participation in associations and multilateral bodies with other institutional investors and qualified operators in the field of "sustainable" and "responsible" investments"(The principles of sustainable investment and responsibility of the ENPAP).

Companies with a weak risk mitigation index in terms of controversies ( 3 factors severity, responsiveness, frequency are considered to assess the index ) can be the basis of an engagement activity by ENPAP.