OLTRE II SICAF EUVECA S.p.A.

INFORMATION REGARDING THE POLICIES ON THE INTEGRATION OF SUSTAINABILITY RISKS IN THE INVESTMENT DECISION-MAKING PROCESSES

Art 3, paragraph 1 of Regulation (EU) 2019/2088
“Policies on the integration of sustainability risks in investment decision-making processes”
(Publication on the website)

By “sustainability risk” we mean an environmental, social or governance event or condition that, should it occur, could cause a significant negative impact to the value of the investment.

Oltre II Sicaf EuVeca SpA (“Oltre II” or the “SICAF”), an Impact Investing operator that promotes products with social impact objectives, investments that, in addition to respecting the principle of not causing harm (“do not harm”), generate a positive impact for all the company’s stakeholders. The SICAF invests in companies operating in the sectors of healthcare, agriculture, sport, tourism, education, always maintaining an important focus on the world of services to the individual. All the companies invested in Oltre II make the most of new technologies that are however placed to service its social objective.
The SICAF adopts its own social impact measurement methodology in its investment process, in order to establish and monitor the social impact objectives relating to the Target companies over time.

However, it should be noted that the SICAF has practically completed both the Investment Period (deadline 22 April 2021) and the Subscription Period and is starting to manage the portfolio companies, with a view to their planned exit in the coming years. Therefore, on the basis of these considerations, the SICAF will not proceed with the integration of ESG risks within the investment process with reference to the Regulation (EU) 2019/2088 relating to the disclosure on policies for integrating sustainability risks in the decision-making processes relating to investments.

Art. 4, paragraph 1 of Regulation (EU) 2019/2088
“Disclosure on the main negative effects (PAI) for sustainability”
(Publication on the website – ad hoc section “adverse sustainability impacts not considered”)

Oltre II, with reference to the provisions of Regulation (EU) 2019/2088 Art. 4 relating to disclosure on sustainability in the financial services sector, does not take into account the adverse impacts (PAI) of investment decisions on sustainability factors in the sense provided for by art. 4, paragraph 1. However, the SICAF adopts its own methodology for measuring social impact in its investment process, in order to establish and monitor over time the social impact objectives relative to the Target companies.

It should be noted that the SICAF has practically completed both the Investment Period (deadline 22 April 2021) and the Subscription Period and is starting to manage the portfolio companies with the view of their planned exit in the coming years. On the basis of these considerations, the SICAF will not proceed to consider the adverse impacts, in the sense provided for by the Regulation (EU) 2019/2088 and related document “Regulatory Technical Standard” (or also “RTS”), containing the technical regulatory standards, which are inter alia still awaiting final approval by the European Parliament.