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, Rinascimento SCF S.r.l. integrates an assessment regarding environmental, social, and governance (ESG) sustainability factors. This ensures that various products and instruments can only be recommended to clients who express sustainability preferences compatible with the characteristics of those instruments.

Since the advisory service provided by Rinascimento SCF S.r.l. concerns the financial portfolio as a whole, the evaluation of sustainability factors is carried out at the portfolio level. This means that the portfolio, in its entirety, must align with the client’s sustainability preferences, although it is possible that, for risk management purposes or to achieve the client’s objectives, certain individual instruments used may not individually align with the client’s preferences.

The evaluation of the environmental, social, and governance sustainability characteristics is conducted based on the type of instrument/product, using information declared by the issuer in compliance with current regulations or by employing external evaluation models (ratings) and/or analyses conducted internally.

No Consideration of Negative Effects on Sustainability Factors

Currently, due to the partial availability of data from manufacturers necessary to evaluate the negative effects on sustainability, such effects cannot be considered in the provision of the advisory service. Rinascimento SCF will periodically review the availability of data from manufacturers and, when such data becomes widely and comprehensively available, will consider the opportunity to evaluate the negative effects on sustainability factors in relation to the advisory service provided.

Consistency of Remuneration Policies with the Integration of Sustainability Risks

Rinascimento SCF takes sustainability risks into account when complying with organizational requirements and remuneration practices. The remuneration and payments made by the company to third-party providers are determined in a manner that does not conflict with the policies for selecting instruments with regard to sustainability factors.