Policies on integrating sustainability risks into the advisory service
Pursuant to Article 165(1)(h-bis) of the Intermediaries Regulation, in the process of selecting the financial instruments covered by the investment advisory service, Massimiliano Silla incorporates an assessment of environmental, social and governance sustainability factors, in order to ensure that the various products and instruments can be recommended only to clients whose sustainability preferences are compatible with the characteristics of those instruments. Since the advice provided by Massimiliano Silla concerns the financial portfolio as a whole, the assessment of sustainability factors is carried out at portfolio level. This means that, as a whole, the portfolio must be aligned with the client’s sustainability preferences; however, for reasons of risk management or of achieving the client’s objectives, some individual instruments used may not be aligned with those preferences.
The assessment of environmental, social and governance sustainability characteristics is carried out depending on the type of instrument/product, according to the information declared by the issuer under the regulations in force, or using external assessment models (ratings) and/or analyses conducted internally. At present, given the only partial availability of the data from manufacturers needed to assess the adverse impacts on sustainability, such impacts cannot be taken into account in providing the advisory service. Massimiliano Silla will periodically review the availability of data from manufacturers and, when it becomes broadly and fully available, will consider the opportunity to assess the adverse impacts on sustainability factors in relation to the advisory service provided.
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