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Nummus.Info SpA

Service Providers Framework 2020

You are in Strategy and Governance » Policy on ESG beliefs

Policy on ESG beliefs

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.

The assessment and promotion of environmental, social and governance factors as well as NDGs are our core business.

We think that ESG analysis and ESG compliance is not only a responsible duty but also a driver to success. We promote our philosophy to our clients because ESG compliance means on one hand more value for society and environment and, on the other, better investment long term risk-return measures. 

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

01.5. Additional information [OPTIONAL]

SG 02. Norms used to develop policies (Not Applicable)

SG 03. Policy offerings to clients

03.1. 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
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

03.2. Provide a brief description of the key elements, any variations, or exceptions applying to these policies.

Clients define which services they are interested in and which policies they want to build. 

Clients can create custom filters in order to exclude (or include with a "best in class approach") controversial sector and sensible items (alcohol, gambling, tobacco...).

03.3. Additional information. [OPTIONAL]

SG 04. ESG/RI in business offerings

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

Business area


How you include ESG/RI factors

We provide to our clients a bottom up analysis of their portfolios, in order to hilight controversies or business involvements. 

We also provide a top level portfolio quality score and a top level portfolio ESG rating. 

Investment Consultancy

How you include ESG/RI factors

Each client creates his own filter, defining exclusions or best in class approach in different controversial sectors or defining a minimun ESG rating. 

This filter is then applied to the available investment universe, in order to exclude or create constraints to investments in controversial sectors and to improve portfolio sustainability. 

Research and Data Provision

How you include ESG/RI factors

ESG factors are integrated into our research and data. ESG risk factors are considered in the construction of investment universe.

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

Roles present in your organisation
Oversight/accountability for ESG/RI
Implementation of ESG/RI
Chief Executive Officer (CEO), Chief Financial Officer (CFO)
Chief Operating Officer (COO), Chief Information Officer (CIO)
Other chief-level staff
Other heads of department
Dedicated ESG/RI staff
Other role, specify (1)
Other role, specify (2)
Other role, specify (3)
None of the above

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

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

04.7. Additional information [OPTIONAL]

SG 05. Outsourcing of services (Private)

SG 06. Providing training/education

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

06.4. Additional information. [OPTIONAL]

SG 07. Applying, advancing and promoting the PRI principles

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

We explain the PRI principles to clients, as well as how to apply and implement them. 

We also refer to the PRI principles in public speaking engagements. 

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

SG 08. Actions taken to promote responsible investment

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

08.2. Additional information. [OPTIONAL]

SG 09. Long term trends

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

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

We refer to MSCI ESG Manager methodology.

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

We refer to MSCI ESG Manager methodology.

SG 10. Interaction with asset owners

10.1. Indicate whether you interact with asset owner clients.

10.2. Indicate the typical frequency and type of interactions with your asset owner clients.

Type of interaction



10.3. Additional information. [OPTIONAL]

SG 11. Aligning approach with investor goals

11.1. Describe how you typically align your organisation’s philosophy and approach to ESG/RI with your investor clients’ goals.

We promote ESG compliance to our clients, categorising ESG-related in order to identify opportunities for risk management and future value creation. Our goal is to promote responsible growth empowering responsible investments.

11.2. Additional information. [OPTIONAL]

SG 12. ESG recommendations not aligned with investor goals

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

12.2. Additional information. [OPTIONAL]

SG 13. Seeking feedback from clients

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

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

We have a close contact with our clients and we schedule periodically informal calls. Dialogue is the foundation of our client relationships. 

SG 14. Managing conflicts of interest

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

14.2. Describe how you manage potential conflicts of interest.

Although we are not directly involved in the determination of single firms ratings, we apply strict guidelines on work ethics and integrity. 

We base our research on MSCI ESG Manager platform and we elaborate third part's data. 

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

Nummus employees must respect the applicable insider trading regulations. 

14.4. Additional information. [OPTIONAL]