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Disclosure pursuant to articles 3.1, 4.1 and 5.1 of Regulations (EU) 2019/2088

DISCLOSURE PURSUANT TO ARTICLES 3.1, 4.1 AND 5.1 OF REGULATION (EU) 2019/2088


For CDP Venture Capital SGR S.p.A., which operates with the aim of simplifying and strengthening the venture capital sector and the economic-productive foundations of the country, environmental, social and governance (ESG) matters are extremely important within the scope of said mission. Indeed, the essential aspects of its business are based on the principles of ESG responsibility.

Since its inception, the Company has paid close attention to its ESG goals, establishing, as early as 2020, a Board Committee on sustainability.

Given the chrematistics of the funds managed by the SGR, which are strongly focused on innovation and digitalisation, and the highly diversified portfolio, the sustainability risk is reasonably expected to be small.

During 2021, the Company adopted its own internal ESG Policy, which describes the SGR’s approach to ESG principles to prevent any related risks and ensure safeguards in line with the specific business operations.

With the adoption of the afore-mentioned Policy, approved by the Company’s Board of Directors, further specifying the internal procedures for the investment decision-making process, investment monitoring and risk management, the SGR has undertaken to include and incorporate ESG implications and risks into its day-to-day operations.

The Company has defined the principles behind the integration of ESG aspects in the management of its operations, with the aim of contributing to the generation of positive impacts for the community. More specifically, the Company has committed itself to:

  • promoting the integration of ESG factors within the activities of the investee companies of the Funds managed so as to encourage greater awareness of sustainability and the generation of positive impacts on the community;
  • enhancing the relations with all the stakeholders that revolve around the SGR through engagement activities and shared improvement plans;
  • identifying the methods of engagement in and management of an active dialogue with the investee companies, in order to allow the monitoring of the risk profiles of the companies held in the portfolio, the achievement of the set ESG goals and the collection of continuous feedback for the evolution of the ESG strategy adopted by the SGR.

In order to pursue the aforementioned goals and with a view to identifying its ESG strategy, CDP Venture Capital has adopted an approach aimed at integrating into its investment policies the main issues falling within the “Impact Innovation” and
“Energy Transition” areas that the SGR intends to pursue.

With regard to the principal adverse impacts (or PAI), taking account of the SGR’s operations and the nature of the Funds as well as the target companies subject to investment, CDP Venture Capital has not yet systematically incorporated the adverse effects of investment decisions on sustainability factors, as defined in Article 4 of Regulation (EU) No. 2088/2019. Concurrently, the SGR has internally launched the analyses deemed to be appropriate in order to consider the negative effects on sustainability factors of the investment process, which will take into account - inter alia - the evolution of the applicable regulatory framework.
In this context, the SGR has launched a due diligence process aimed at identifying which among the principal adverse impacts caused by the investment decisions identified by ESG regulations are applicable to the Funds taking account of their operations as well as the nature of the target investment companies.

In particular, the environmental and social impact of the operations of the investee companies of the Funds of CDP Venture Capital will be assessed on an ongoing basis through integration of PAIs identified as relevant in the due diligence process. The SGR will report annually on the PAIs, based on a preliminary survey for each Fund of the indicators whose measurement is possible and consistent with the types of the investee companies of the Funds.

Finally, it is noted that CDP Venture Capital SGR S.p.A. promotes the consistency of its operations with sustainability matters. To this end, CDP Venture Capital SGR S.p.A. takes into consideration ESG goals in its remuneration policies so as to make them permanent and long-lasting goals within its policies and consistent with the integration of sustainability risks.
CDP Venture Capital SGR S.p.A. is aware that these goals can positively affect the pursue of its strategic targets. Therefore, it encourages their achievement.

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