Commitment policy information


This notice describes how Banca Finnat Euramerica S.p.A. (the "Bank") fulfils the obligations laid down under article 124d of the TUF (¹) as regards the encouragement of long-te

  1. monitor said companies, relating to relevant issues (including strategy, financial and non-financial performance and risk, capital structure, social and environmental impact and corporate governance);
  2. exercise voting rights, in cooperation with other shareholders and other stakeholders;
  3. manage actual and potential conflicts of interest in relation to the above, disclosing on an annual basis how their engagement policy has been implemented and how votes were cast in the general meetings of the aforesaid companies, with the exception of insignificant cases.

The Bank has verified that, on the date this notice was drawn up, it does not hold, as part of its portfolio management, company shares listed on a regulated market based in Italy or another Member State for values over 0.5% of the share capital of said companies. This circumstance, which is also typical of the Manager's operations, leads reasonably to the conclusion that the Bank's influence as a shareholder on the aforesaid companies is objectively negligible, in the face of certain administrative costs for the management of obligations and uncertain benefits, which are not in any case quantifiable. Furthermore, another element for which the engagement policy towards the companies in question does not apply is stipulated in the portfolio management contract signed by the clients for the activation of the service. The contract states that the voting right inherent in the financial instruments acquired by the Manager may be exercised by the Bank solely on the basis of a specific proxy and instructions given by the client to the Bank. None of the clients managed has ever issued such a proxy. Therefore, the Bank has chosen not to adopt an engagement policy. The Bank shall promptly inform the public of any changes relating to the engagement policy, in consideration of future operative developments. The above notice was approved by the Bank's board of directors on 10 February 2021.


[¹] As amended by Leg. Dec. 49/2019 in transposition of Directive (EU) 2017/828 of the European Parliament and of the Council of 17 May 2017.

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