Disclosures under Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability-related disclosures in the financial services sector

Art. 3 – Transparency of sustainability risk policies

Wise Equity SGR S.p.A. (the “Company” or “Wise Equity”) is aware of the importance that the responsible management of its business has in creating sustainable value in the short- and medium-long-term. The company integrates sustainability risk evaluations, as defined under Regulation (EU) 2019/2088, in undertaking its investment decision-making process.

The Company, among the first Italian corporate signatories to the PRI (Principles for Responsible Investments), excludes investments in sectors considered controversial. Wise Equity has implemented specific processes and procedures aimed at analyzing and managing specific categories of sustainability risks, both in the preliminary investment evaluation phase and after undertaking an investment. Significant sustainability risks are identified on the basis of the specific characteristics of the target company and the economic sector in which the target company operates. In the pre-investment phase, this process includes a pre-assessment activity conducted with the assistance of specialized third parties with the requisite expertise to evaluate the relevant risks and opportunities, including those regarding sustainability risks. The results of this analysis are included in the management team’s documentation, are discussed with the Fund’s Investment Committee and the Company’s Board of Directors and constitute, together with other valuation considerations, the basis for a decision on the merits of continuing the investment process.

The Company also takes care that sustainability risks are adequately identified, evaluated and monitored in the post-acquisition phase and makes every effort to assure that each portfolio company fully investigates the sustainability risks pertinent to its principal operating activities, analyzing the processes and procedures in place as well as any mitigation measures adopted. The risks and areas for improvement are detailed in a multi-year action plan extending over the investment period and its implementation is periodically monitored by the Company.

The Company’s Partners with responsibility for an individual investment assure oversight of progress on the forementioned action plan and indicate, where necessary, corrective measures and actions. The Investment Managers offer operational support to the Partners, while the Chief Financial Officer has a coordinating and supervisory role. Risk monitoring may also be undertaken with the assistance of specialized third-party consultants.

Art. 4 – Transparency of adverse sustainability impacts at entity level

The Company does not currently take into consideration, as defined under Art. 4, paragraph 1 of Regulation (EU) 2019/2088, the negative effects of investment decisions on sustainability factors. Following the adoption and entry into force of the Regulation’s technical rules establishing the detailed requirements under the Regulation, its methodologies and the presentation of information regarding the sustainability indicators identified by the Regulation, and following explanations regarding questions subject to interpretation, the Company will reevaluate its position as regards the definition of its due diligence policies to include the negative effects of investment decisions on sustainability factors and will update its website accordingly.

Art. 5 – Transparency of remuneration policies and their integration with sustainability risks

The Company is required to adopt sound and prudent remuneration and incentivization policies reflecting and fostering conservative and effective risk management, in accordance with the risk profiles and governing rules of the funds it manages. In applying this principal, the Company’s remuneration policy does not, currently, address sustainability risks.

Specifically, results evaluated by the Company when determining the variable portion of remuneration is undertaken without considering any negative impact that may derive, ex ante or ex post, from sustainability risks assumed.