Sustainability

Disclosure Regulation (EU) 2019/2088

Reporting in Accordance with Regulation (EU) 2019/2088 or Sustainable Finance Disclosure Regulation (SFDR)

Since its establishment, Gardant Investor SGR has been committed to integrating ESG factors into its operations, beginning with its core business of managing alternative investment funds. Adopting a responsible approach to investment processes and managing ESG-related risks and opportunities is one of the keys to generating added value for all stakeholders in the relevant sector.

On March 10, 2021, Regulation EU 2019/2088, or the Sustainable Finance Disclosure Regulation (SFDR), came into force. This regulation requires financial market participants and financial advisors to disclose their approach to integrating sustainability factors and to enhance transparency regarding sustainable products, particularly in relation to:

  • How ESG risks are considered in decision-making and investment processes;
  • Evaluations of potential negative impacts of investment policies on environmental and social themes.

Gardant Investor SGR has implemented appropriate processes and activities to ensure proper application of the European regulation. This is achieved, in particular, through integrating ESG criteria into its processes and actions. In this respect, Gardant Investor SGR aims to monitor and manage the sustainability risks that investments may pose to investors and counterparties.

Gardant Investor SGR is also committed to transparent communication regarding its approach to integrating sustainability factors in investments, especially regarding ESG risk assessment and management, through channels required by current regulations, beginning with pre-contractual and periodic disclosures and the information on this website.

Article 3 – Transparency of Sustainability Risk Policies

Responsible investment is an essential part of Gardant Investor SGR’s positioning within the alternative investment fund management sector. As part of its commitment to sustainability, the SGR is developing dedicated internal policies to integrate ESG factors into both its investment processes and operations, consistent with the ambitions and vision defined by doValue.

Gardant Investor SGR has also implemented internal policies and procedures to accurately analyse and manage sustainability risks, aiming to incorporate the assessment and management of these risks into its investment process, covering both the identification and management phases of investments within its portfolio, as summarized below.

For each portfolio of non-performing loans, Gardant Investor SGR ensures that all companies entrusted with portfolio management adopt a Code of Conduct with the following commitments:

  • Align with the principles and best practices of the National Union of Credit Protection Companies (UNIREC);
  • Adopt and promote a management approach based on transparency and integrity in actions undertaken;
  • Prioritize out-of-court recovery over judicial recovery focused solely on enforcing guarantees, aiming to support debtor recovery under favourable conditions;
  • Promote the application of negotiation standards that consider responsible and reliable debtor behaviour, weighing it as an essential factor alongside economic and financial parameters when evaluating settlements.

 

Article 4 – Transparency of Adverse Sustainability Impacts at the Entity Level

Currently, Gardant Investor SGR is unable to comprehensively assess the adverse impacts of investment decisions on sustainability factors, as outlined in Article 4, Paragraph 1 (a) of Regulation (EU) 2019/2088, due to the following factors:

  • Lack or limited availability of necessary data for calculating the indicators required by the Regulation for currently managed assets; 
  • Difficulties in integrating this data into Gardant Investor SGR’s information systems for processing and reporting these indicators; 
  • Absence of reference leading practices.

Given the financial sector’s evolution toward integrating sustainability into business practices and the need for increased ESG transparency, Gardant Investor SGR has launched an internal sustainability project aimed at evaluating the feasibility of identifying and measuring adverse impacts on sustainability factors.

Article 5 – Transparency of Remuneration Policies Regarding Sustainability Risk Integration

Dedication, integrity, and professionalism of employees are essential for achieving corporate growth objectives. The Group provides professional growth opportunities for all employees, ensuring fair treatment based on competence and merit without discrimination.

Accordingly, Gardant Investor SGR’s remuneration policies are grounded in the principles of equity, integrity, professionalism, merit, and competence. These policies align with Gardant Investor SGR’s strategies, priorities, and vision, which regard sustainability as a core driver of its business model.

  • Publication date: Rome, June 21, 2022
  • Last updated: Rome, March 25, 2025