Policies on the integration of sustainability risks in the advisory service

Pursuant to Article 165 paragraph 1 letter h-bis of the Intermediaries Regulation, in the process of selecting financial instruments subject to the investment advisory service, Massimiliano Silla integrates an evaluation regarding environmental, social, and governance (ESG) sustainability factors, to ensure that various products and instruments can only be recommended to clients who express sustainability preferences compatible with the characteristics of these instruments. Since the advisory provided by Massimiliano Silla concerns the financial portfolio as a whole, the evaluation of sustainability factors is conducted at the portfolio level. This means that, overall, the portfolio must align with the client’s sustainability preferences; however, for reasons of risk management or achieving the client’s objectives, some individual instruments used may not align with said preferences.

The evaluation of environmental, social, and governance sustainability characteristics is carried out depending on the type of instrument/product according to the information declared by the issuer under the current regulations or using external evaluation models (ratings) and/or analyses conducted internally. At present, due to only partial availability of data from manufacturers necessary to assess the negative effects on sustainability, such effects cannot be considered in the provision of advisory service. Massimiliano Silla will periodically review the availability of data from manufacturers and, when these are widely and completely available, will consider the opportunity to assess the negative effects on sustainability factors in relation to the advisory service provided.