Statement on Transparency of Principal Adverse Impacts (PAI) of Investment Decisions on Sustainability Factors
Article 4 of the Regulation (EU) 2019/2088 (hereinafter "SFDR") requires fund managers to expressly disclose whether they consider "principal adverse impacts" of investment decisions on sustainability factors. While ESG topics and sustainability risks are crucial and systematically assessed, BlackSheep SGR S.p.A. (hereinafter also "the Asset Manager"), with reference to the provisions of the article 4 of the SFDR, does not currently take into consideration the negative effects (hereinafter "PAIs", or "Principal Adverse Impacts") of investment decisions on sustainability factors, defined by the SFDR as "environmental, social and employee concerns, respect for human rights, anti-corruption, and antibribery matters". This is due to the fact that BlackSheep SGR S.p.A. does not currently have sufficient data and information to allow an adequate evaluation of the potential PAIs of its investment decisions on sustainability factors. However, the Asset Manager is developing a methodology aimed at evaluating the materiality of potential PAIs, in line with the contents of the final version of the Regulatory Technical Standards (RTS) published by the European Commission on 6 April 2022, effective as of 1 January 2023. To this end, the Asset Manager, in line with its Responsible Investment Policy, identifies and analyses potential PAIs on sustainability factors in the pre-investment phase, also through the ESG Due Diligence, and has developed a proprietary tool aimed at collecting the sustainability adverse indicators required by the RTS to monitor the PAIs during the portfolio management phase. BlackSheep SGR S.p.A. reserves the right to update its position regarding the consideration of PAIs, and to update, if necessary, this statement.