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Assogestioni

Service Providers Framework 2018

You are in Strategy and Governance » Responsible investment policy

Responsible investment policy

SG 01. Responsible investment policy

01.1. Describe how your organisation’s philosophy incorporates environmental, social and governance factors, and the link to your business offerings.

In 2012 Assogestioni signed - together with the banking and the insurance associations – the Italian Charter for Sustainable and Responsible Finance  - committing the association to promote transparency, ESG and long term investing among its members and investors alike. Assogestioni is a founding member of the Italian SIF - the Forum for Sustainable Finance - and works for the advancement of sustainable and responsible approach to investment among its members by promoting awareness and debate on ESG issues and facilitating engagement on corporate governance amongst its members. ESG factors have been included in Principle 3 of the Italian Stewardship Principles, promoted by Assogestioni.

We have organized a series of public events to keep investor and asset managers abreast on issues related to sustainable investing: from the relationship between climate change and financial risk to tools to implement impact investing, from SRI fund rating to finance for the environment to the challenges of corporate governance and board engagement. Through its Corporate Governance Committee and through its support to the Investment Managers’ Committee, in fact, Assogestioni has been promoting the dissemination of corporate governance culture among market operators by monitoring investee listed issuers’ behaviours as well as providing technical support to investment management companies’ engagement with listed issuers, taking into account ESG factors.

Please note that since Assogestioni is a no-profit organization it does not carry out business activities.

01.2. Indicate whether you have internal policies that formalise the incorporation of your beliefs in your business offerings.

01.3. Indicate the components/types of your internal policy

Policy components/types

01.4. Indicate how these are put into practice internally across the organisation.

01.5. Additional information [OPTIONAL]

Please note that since Assogestioni is a no-profit organization it does not carry out business activities.

 

Regular RI/ESG policy awareness building for associate members.

 


SG 02. Publically available policies

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

Policy or document name

02.2. Additional information. [OPTIONAL]


SG 03. Norms used to develop policies

03.1. Indicate what standards you have used to develop your organisation’s policies. Tick all that apply.

          EFAMA Code for External Governance
        
          UK Stewardship Code
        
          Italian Corporate Governance Code
        

03.2. Additional information. [OPTIONAL]


SG 04. Policy offerings to clients

04.1. Indicate whether you offer standard, off the shelf, policies to clients as part of your product offerings, and/or whether you create tailored versions for individual clients.

Off the shelf Tailored
Asset class-specific RI guidelines
Sector-specific RI guidelines
Screening/exclusions policy
Engagement policy
(Proxy) voting policy
RI guidelines set out within the Investment Policy Statement (IPS)
RI guidelines set out in a freestanding RI policy
Multi-year RI implementation project plan
Conflict of interest management policy
Stockbroker allocation policy
Securities lending policy
Other, please specify (1)
Other, please specify (2)
Other, please specify (3)
None of the above

04.2. Briefly describe how you incorporate ESG factors and RI-consideration when advising clients on policies.

Please note that the above is not applicable to our organization since the legal status of Assogestioni is a no-profit association.

Assogestioni personnel provides the Investment Managers’ Committee secretary functions as well
as technical and legal advice on the matters discussed by the Committee, such as the presentation of minority slates of candidates for the election within the boards of Italian listed companies or engagement with Italian listed companies on ESG matters.

 

04.3. Additional information. [OPTIONAL]


SG 05. ESG/RI in business offerings

05.1. Briefly describe how you include ESG/RI factors as part of your business offerings.

Business area

Active Ownership Services

How you include ESG/RI factors

Please note that the above is not strictly applicable to our organization since the legal status of Assogestioni is a no-profit association.

Assogestioni regularly promotes awareness on ESG/RI issues to its members.

Assogestioni personnel provides the Investment Managers’ Committee secretary functions as well
as technical and legal advice on the matters discussed by the Committee, such as the presentation of minority slates of candidates for the election within the boards of Italian listed companies or engagement with Italian listed companies on ESG matters.

Other, specify (1)

          Null
        

How you include ESG/RI factors

Null

05.2. Indicate the roles in your organisation, and indicate for each whether they have oversight and/or implementation responsibilities for ESG/RI.

Roles present in your organisation Oversight/accountability for RI Implementation of RI
Board
Directors
Chief Executive Officer (CEO), Chief Financial Officer (CFO)
Other chief-level staff

Please specify

          
        

Please specify

          
        
Other heads of department

Please specify

          
        

Please specify

          
        
Dedicated ESG/RI staff
Other role, specify (1)

Please specify

          Corporate Governance Committee
        

Please specify

          Corporate Governance Committee
        
Other role, specify (2)

Please specify

          Director of Corporate Governance and Institutional Relations
        

Please specify

          
        
Other role, specify (3)

Please specify

          Director of Operations and Markets
        

Please specify

          
        
Other role, specify (4)

Please specify

          
        

Please specify

          
        
None of the above

05.3. Indicate how you ensure ESG/RI expertise for the roles where there are RI oversight/accountability or implementation responsibilities.

05.4. Indicate whether your organisation has any ESG/RI linked incentives for its employees.

05.6. Additional information [OPTIONAL]


SG 06. Outsourcing of services (Private)


SG 07. Providing training/education

07.1. Indicate whether you provide training/educational services on ESG/RI. Tick all that apply.

          Directors and statutory auditors of listed companies
        

07.2. Describe the main components of your training/educational services on ESG/RI and any variations depending on the group you provide training/education to.

Education courses directed to directors and statutory auditors of listed companies are called "Induction Sessions". Induction Sessions consist in training programmes on the topics of duties and responsibilities inherent to the offices of member of the boards of Italian listed companies. In line with the Italian Corporate Governance Code recommendations (cf. art. 2.C.2), the course offers best-in-class education regarding theoretical and practical corporate governance matters, along with a specific focus on: the Corporate Governance Code, duties and responsibilities of directors and statutory auditors, risk management, relationships with shareholders, corporate information (financial and non financial) as well as sustainability. Speakers comprehend eminent academics from Italian Universities, experienced board members serving in Italian and foreign listed companies, senior officers from supervisory authorities as well as from the Italian Stock Exchange. Course participants range predominantly from current and prospective directors and statutory auditors of listed companies to company secretaries and corporate affairs officers.

07.3. Describe whether these training/educational services include any commercial elements.

          Participants have to pay tuition fees in order to enroll to the program.
        

07.4. Additional information. [OPTIONAL]


SG 08. Applying, advancing and promoting the PRI principles

08.1. Describe how your organisation applies, advances and promotes the PRI Principles.

Assogestioni, as representative trade body of the Italian investment management industry, promotes continously and on a day by day basis the culture of good governance and sustainability (ESG), whithin all of its activities.

08.2. Highlight whether there are any ways that your organisation would like to engage further with the PRI. [OPTIONAL]

The Association would like to foster the usage of the PRI Collaboration Platform in order to raise awareness on the multiple occasions of engagement with Italian listed companies offered by the slate voting mechanism at the AGMs.


SG 09. Actions taken to promote responsible investment

9.1. Indicate which of the following actions your organisation has taken to promote responsible investments during the reporting year, independently of collaborative initiatives.

          Through providing administrative and legal support to the engagement activities of the Investment Managers' Committee
        

9.2. Additional information. [OPTIONAL]


SG 10. Long term trends

10.1. Indicate which of the following long-term trends are addressed in your product outputs.

10.2. Explain how this long-term trend affects your product outputs.

...

10.4. Additional information. [OPTIONAL]

All these topics are integrated within our action plan and culture, as well as integrated within our activities as trade association (climate change can be considered as an example).


SG 11. Interaction with asset owners (Not Applicable)


SG 12. Aligning approach with investor goals

12.1. Describe how you align your organisation’s philosophy on and approach to ESG/RI with investor goals.

12.2. Additional information. [OPTIONAL]

Please note that this is not applicable to our Association since it is a no-profit organization. All of our activities are aligned to the goals relevant for the Italian investment management industry.


SG 13. ESG recommendations not aligned with investor goals

13.1. Describe what steps you take, if any, when your ESG recommendations are not in line with investor goals.

13.2. Additional information. [OPTIONAL]


SG 14. Seeking feedback from clients

14.1. Indicate whether you seek feedback from clients on your RI/ESG services and product offerings

14.2. Describe how you use this feedback in your RI/ESG services and product offerings.

Feedback from Associate members is continuous and ongoing.

14.4. Additional information. [OPTIONAL]

This is not applicable to our organization since its statuts of no-profit organization


SG 15. Managing conflicts of interest

15.1. Indicate whether your organisation has a policy for managing potential conflicts of interest.

15.2. Describe how you manage potential conflicts of interest.

This is not applicable to Assogestioni itself, however the Association has developed  the "Independence Protocol for the Management of Conflicts of Interests", which consist in a self-regulation protocol that each Associate is free to join it or not. Each Associate, however, is required to provide the Association with proper information, in a special report on the adoption of the Protocol, specifying the decision to join, the extent and modalities of the membership and the reasons which may have induced it not to follow some or all of the recommendations contained in the Protocol or, if not adopted, the reasons why. Each management company is therefore subject only to an obligation to comply or explain.

 

The Protocol can be found here:

http://www.assogestioni.it/index.cfm/3,792,10782/protocollo-autonomia_2014.pdf

 

15.3. Describe how you ensure that company employees do not derive any personal gain from the use of information collected during your work process.

This is not applicable to Assogestioni.

15.4. Additional information. [OPTIONAL]


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