Sustainable Finance Disclosure Regulation (SFDR) related disclosures
Sustainability risk policies
At Ambienta, the integration of sustainability risks in the investment process informs investment decisions and contributes to the generation of attractive risk-adjusted returns over the medium to long-term. Sustainability risks are rooted in Ambienta’s firm-wide Risk Policy which outlines our risk management framework across asset classes, including the procedures to ensure the effectiveness and adequacy of sustainability risk integration.
Principal adverse impacts of investment decisions on sustainability factors
Ambienta’s Responsible Investment Policy is the cornerstone of all firm-wide and asset-class specific ESG policies, procedures and actions. The policy, latest version approved by the Board of Directors in 2023, defines the roles and responsibilities for the integration of sustainability factors in Ambienta’s operations and investments, starting with the Sustainability & Strategy (S&S) team, which is responsible for the application of the proprietary Environmental Impact Analysis methodology and of the ESG in Action programme up to the investment teams which are fully accountable for integration of ESG and execution of the programme along all phases of the investment process.
Ambienta, in implementing its approach to sustainable investments and in pursuing the Principles for Responsible Investment defined by the United Nations, of which it is a signatory, ensures alignment with the internationally recognized fundamental principles regarding business conduct and respect for human rights.
ESG analysis is an integral part of the investment process and contributes to the identification and control of the principal adverse impacts (PAIs) associated with investments. Ambienta considers the main negative impacts of investment decisions on sustainability factors deemed relevant for the companies in which we invest through a combination of proprietary and external market research analysis. PAIs will be analysed through a qualitative and quantitative approach that may consider, where relevant and depending on asset class, third party providers sector data.
The above takes place through Ambienta’s ESG in Action programme (a proprietary approach to the integration of non-financial factors into portfolio management) that is structured in two main phases:
- prior to investment, due diligence to analyse the main impacts on environmental and social objectives to ensure comprehension of potential negative impacts, their probability of occurrence and compliance with minimum safeguard principles. Based on results, an exclusionary approach or an engagement approach may be adopted.
- during the holding period Ambienta will continue monitoring negative impacts through a combination of proprietary tools and external market research analysis, which are subsequently factored into investment decisions and in implementing our annual engagement and active ownership practices.
The ESG analysis undertaken in the due diligence and monitoring phase will consider internationally recognized principles including the OECD Guidelines for Multinational Enterprises, the UN Guiding Principles of Business and Human Rights, including the principles and rights set out in the eight fundamental conventions identified in the Declaration of the International Labour Organisation on Fundamental Principles and Rights at Work and the International Bill of Human Rights.
Integration of sustainability risks in remuneration policies
Ambienta’s approach to remuneration is designed in such a way to be consistent with the integration of material sustainability risks in investment decisions. Together with the centralized S&S function, as per our ESG in Action programme, the investment team is fully accountable for the integration of ESG and is instrumental in driving execution, across all phases of the investment process. This is part of the annual performance analysis and drives remuneration both for the S&S team and for the investment teams, of which the ESG drive is a component.
Details of how each product considers sustainability risk in their investment decision making processes can be found below:
Principal Adverse Impact Statement
Ambienta SGR considers the principal adverse impact (PAI) of its investments on various sustainability factors as expressed through the relevant mandatory and additional PAI indicators outlined in the SFDR RTS Level 2 measures, including for example environmental, social and employment, human rights and anti‐corruption topics.
Ambienta has therefore actively incorporated within its assessments, pre-investment and during the holding period, the analysis of potential adverse impacts for each of its investments. The PAI indicators of the single investments are aggregated for the entity level reporting that Ambienta undertakes on a voluntary basis and that will be annually updated.