Policy

This Code expresses the principles of corporate ethics that must constantly guide all activities carried out by Etica Sgr employees on behalf of the Company.

Etica Sgr ensures the widest dissemination of the Code of Ethics by communicating its principles and values to all relevant parties, so that they may be applied in day-to-day decision-making. Etica Funds employees themselves were involved in the drafting of this Code.

The Code of Ethics applies to the conduct of all collaborators and corporate bodies of Etica Funds, regardless of their role or level of responsibility, both in internal and external operations. It reflects the belief that ethical behavior must be pursued with the same commitment and shared responsibility as the company’s economic success.

In particular, the Company’s directors are required to be guided by the principles of the Code when setting company objectives, proposing investments, and implementing projects.

Managers, in their operational and managerial activities, must be inspired by the principles contained in the Code, fostering a spirit of mutual cooperation across all hierarchical levels.

All Etica Funds employees are required to be familiar with the provisions of the Code of Ethics and the applicable rules governing their work within their specific functions. They must also refrain from any behavior that contradicts these rules.

Legislative Decree no. 231 of 8 June 2001 governs the administrative liability of legal entities, companies, and associations, including those without legal personality, pursuant to Article 11 of Law no. 300 of 29 September 2000.

The Sustainable and Responsible Investment Policy follows an approach based on five main pillars: ESG Selection, Engagement and Issuer Monitoring, ESG Risk Assessment, and Impact Measurement.

Etica Sgr has always taken into account the principal adverse impacts of its investment decisions on sustainability factors (“Principal Adverse Sustainability Impacts”). This document is prepared in accordance with the provisions of EU Regulation 2019/2088.

The Remuneration Policies and Practices document sets out Etica Fund’s rules on compensation and intends to guarantee the maximum transparency as regards the principles and mechanisms of remuneration within the company.

The document was approved by the shareholders’ meeting of April 29 2020 in Milan.

Employees, members of the corporate bodies, and, more generally, all individuals acting on behalf of the company must avoid any potential conflict of interest.

By way of example, though not limited to, the following situations may give rise to a conflict of interest:

• Taking part in decisions involving individuals or entities with whom the employee or a close family member has interests, or from whom they may derive a personal benefit;

• Acting in conflict with the company’s interests, thereby influencing the decision-making autonomy of another party responsible for managing business relationships with or on behalf of the company.

In line with its corporate governance principles based on trust, transparency, and integrity, Etica Funds encourages the cooperation of its employees and third parties in order to bring to light any unlawful, fraudulent, or suspicious activities, as well as any other irregularities or conduct that does not comply with the law, the regulations governing investment services, corporate administrative liability, anti-money laundering and counter-terrorism financing rules, and the provisions of the Code of Ethics.

The Stewardship Policy defines and regulates the stewardship strategies adopted by Etica Funds with respect to the financial instruments held by the collective investment schemes (OICRs) established and/or managed, including by delegation, by Etica Funds, in order to ensure that these activities are conducted solely in the best interest of the fund subscribers.

This document, prepared in accordance with current regulatory provisions that establish the obligation to protect Clients and ensure the utmost care in handling and analyzing complaints raised by them, collects the set of guidelines adopted by the Banca Etica Group to regulate the conduct of its employees in managing complaints submitted by current or potential Customers and, at the same time, serves as a useful information source for the latter, together with the individual Complaints Management Regulations, to inform them about the processes and timelines governing this matter.