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(pursuant to articles 3 and 4, paragraph 1, letter (b) and 5 SFDR)



In order to comply with the principles of responsible investment, Gradiente has adopted a code for a structured approach to the management of environmental, social and corporate governance issues (ESG) for itself as well as for the selection and management of portfolio companies.

One reason is because we believe that by adopting an ESG approach it is possible to achieve better growth, cost savings and better profitability as to long-term returns compared to a traditional approach. At the same time we increase our reputation and strengthen relationships with stakeholders. Therefore, Gradiente SGR  aims to associate the adoption of responsible finance principles with the maximization of returns through the management of investment funds and target companies. All of this is possible thanks to the integration of traditional financial analysis tools with environmental, social and good governance tools both during the investment evaluation process and during the holding period of the investee companies, in order to consider the risks of sustainability in investment decisions.

In particular, sustainability risks are meant as an environmental, social or governance event or condition which, if it occurs, could cause a significant negative or potential impact on the value of the investment, as defined by art. 2, point 22 of EU Regulation 2019/2088. Particularly:

  • sustainability risk related to environmental issues includes climate risk, both physical and transitional. Physical risk derives from the physical effects of climate change, acute or chronic: for example, frequent and severe climatic events can have an impact on products, services and supply chains. Transition risk, on the other hand, is linked to companies’ ability to mitigate and adapt to climate change and their adaptation to a low-carbon economy;
  • sustainability risk related to social issues may include labor rights and community relations, issues such as inequality and inclusiveness, investment in human capital and accident prevention;
  • sustainability risk related to governance issues may include, among others, the composition and effectiveness of the Board of Directors, management incentives, shareholder engagement, corruption. This type of sustainability risk includes risks that may impact an issuer’s operational effectiveness and resilience, as well as its public perception and reputation, impacting its profitability and, in turn, its capital growth.

The investment process adopted by the SGR is integrated by the screening, assessment and due diligence procedure to be conducted on the companies/entities subject to investment (also) in the ESG area.

Below is a summary of the main phases when the aforementioned ESG procedure will be articulated:

  • preventive exclusion of investments in expressly prohibited sectors;
  • due diligence, also with regard to ESG factors, according to the following three main guidelines:
  • preparation and use of specific information questionnaires referring to ESG factors, aimed at a preliminary assessment of good governance, environmental and social factors;
  • the assistance of (and cooperation with) a consultant (specially designated) with specific skills in assessing ESG factors with respect to individual investment transactions, in order to identify both the risk profiles and the opportunities connected to the reference investment;
  • the implementation of specific environmental due diligence, where the environmental risk factor is potentially significant with reference to the sector of activity in which the company/entity subject to investment operates.

On the basis of the results of the due diligence, also carried out through the consideration of specific ESG indicators, the asset management company evaluates the investment (for example if it is such as to allow the promotion of environmental and social characteristics as well as compliance with good governance practices in line with the investment policy) and the related risks, including those of sustainability.

Date of publication 10.03.2021

1st update 27.12.2022

2nd update 13.02.2023


The SGR does not consider the negative effects of the investment decisions made on behalf of the AIFs managed on sustainability factors (“Principal Adverse Impacts” – PAI) in the light of the provisions of art. 4 of EU Regulation 2019/2088.

Date of publication 10.03.2021

1st update 27.12.2022

2nd update 13.02.2023



Among the specific qualitative assessment indicators relating to portfolio management activity, the current remuneration policies envisage the implementation of policies, at investee company level, for the management of sustainability risks as defined by art. 2, point 22 of EU Regulation 2019/2088 (including, inter alia, implementation of gender diversity practices, provision of policies aimed at reducing paper production, development of specific policies concerning the regulation of remote working practices where applicable).
Furthermore, in order to ensure that for the same activity performed, the personnel have an equal level of remuneration – also in terms of conditions (merit-based criteria and assessment of professional skills) for their recognition and payment – the SGR (i) ensures the neutrality of remuneration treatments (fixed and variable) with respect to elements of diversity and (ii) guarantees fairness and equal opportunities for each employee in terms of career advancement and salary increases.

Date of publication 10.03.2021

1st update 04.04.2023

Attached the Disclosure on the promotion of environmental and/or social characteristics pursuant to art.10 SFDR of Fund Gradiente III.