Conflicts of Interest Policy

The Conflicts of Interest Policy sets out the principles and measures adopted by Finanziaria Internazionale Investments SGR S.p.A. (the “Company”) to identify, prevent, manage and, where necessary, disclose to clients any conflicts of interest that may arise in the course of its activities.

In accordance with applicable regulations, the Company has implemented organisational and administrative arrangements designed to ensure that the interests of clients and managed portfolios are safeguarded and take precedence over any interests of the Company, its Relevant Persons, or any persons directly or indirectly linked to it.

This document provides a summary of the policies adopted by the Company and is intended to offer the public a clear and transparent overview of its approach to managing conflicts of interest.

The Company has adopted a specific “Regulation on the Management of Conflicts of Interest for Managed Portfolios”, aimed at identifying actual or potential conflicts of interest that may arise in the context of collective portfolio management and ensuring their proper management through predefined measures.

In general terms, the Company considers as “conflicts of interest” all situations where, in the exercise of collective portfolio management and/or the provision of investment services and activities, including ancillary services, a conflict may arise between:

• the interests of one or more managed portfolios and the interests of the SGR, including its Relevant Persons or any person having a close link with the SGR;
• the interests of one or more investors and the interests of the SGR, including its Relevant Persons or any person having a close link with the SGR;
• the interests of one or more managed portfolios and/or their investors and the interests of other managed portfolios and/or their investors;
• the interests of collective investment undertakings (CIUs) or their investors and the interests of another client of the SGR;
• the interests of two or more clients of the SGR.

In order to facilitate the identification of situations that may give rise to conflicts of interest in the course of the Company’s activities, a mapping of the most common conflict scenarios has been developed. For each scenario, this mapping identifies the relevant control measures to be applied in managing the specific conflict.

Within the scope of collective portfolio management and investment services, the Company identifies potential conflicts of interest, in particular, in relation to:

• investment selection;
• selection of counterparties;
• exercise of voting rights.

Taking into account the nature, scale and complexity of its activities, the Company adopts appropriate organisational and procedural arrangements to prevent, identify and manage conflicts of interest, in line with its internal regulations as amended from time to time.

Potential conflict situations are assessed from the earliest stage of the investment decision-making process, through the collection of information and declarations from counterparties and through controls also carried out with the support of the Compliance Function. The results of such assessments are duly documented and submitted to the competent corporate bodies.

Transactions in which a conflict of interest has been identified are subject to a structured decision-making process. This may include the involvement of advisory committees (where applicable), the opinion of independent directors and the Compliance Function, as well as final approval by the Board of Directors. Where a conflict involves a director, such director abstains from participating in the relevant decision-making process.

For transactions involving specific types of assets, particularly real estate or illiquid assets, the Company also obtains independent valuations, appraisal reports or fairness opinions in order to verify that the transaction terms are consistent with market conditions.

Specific arrangements are also in place for investments in related CIUs within discretionary portfolio management mandates, as well as criteria for the allocation of investment opportunities among multiple managed portfolios and for co-investment transactions.

Finally, where the arrangements adopted are not sufficient to ensure, with reasonable confidence, that the risk of damage to investors’ interests will be prevented, the Company shall clearly disclose the nature and/or sources of the conflict to investors before undertaking business on their behalf, or escalate the matter to the Board of Directors to identify appropriate additional measures.