Company name: 21 INVEST SGR S.P.A.
Business Entity: SOCIETÀ DI GESTIONE DEL RISPARMIO
Headquarters: Borgo Camillo Benso Conte di Cavour, 38, 31100 Treviso
Share Capital: Euro 1,090,236 wholly paid
Tax Number, VAT Number and Treviso Register of Companies no: 03553080965
Phone: +39 0422 31 66 11

21 INVEST SGR S.P.A. is a portfolio management company licensed to operate by the Bank of Italy and is registered under no. 63 of the official Roll – section of Alternative Investment Fund Management companies – held by the Bank of Italy under article 35 of the Consolidated Finance Act. Prior to any investment decision, we recommend investors to take note of the warnings and risk factors set forth in the regulations of the Fund. The Board of Directors of 21 Invest SGR S.p.A. is made up of Alessandro Benetton (Chairman), Dino Furlan (Chief Executive Officer) and Marco Monis (Vice Chairman),Andrea Mazzucato, Giuseppe Prestia e Francesco Scanagatta as well as independent external members – Simonetta Acri and Gianmarco Maffioli.

The 21 Invest code of ethics outlines ethical values, principles of conduct, and provides a guide to the implementation of internal controls, in line with the highest level of business ethics standards.

In order to encourage and facilitate the reporting of offences or breaches of laws and regulations governing its activities, 21 Invest SGR S.p.A. (the “Company”) has adopted an ad hoc system to manage such reports. The system uses appropriate technical and organisational measures to safeguard the confidentiality of the person making the report (the “whistleblower”), of the persons involved and of the persons in any case mentioned in the report, as well of the contents of the report and the related documentation; the system is entrusted to an autonomous and specifically trained person.
In accordance with applicable legislation, the Company has, therefore, established specific reporting channels while also laying down, in a specific procedure called the Whistleblowing Policy, the operating arrangements and responsibilities for receipt, evaluation, management and closure of such reports, as summarised in the attached document.

In reference to the implementation of EU Directive 2017/828 – also known as the Shareholder Rights Directive II (“SRD II”) – into Italian law, 21 Invest SGR S.p.A. has determined that as it currently stands the conditions for adopting a Policy of Engagement in accordance with article 124- quinquies of the TUF (Consolidate Law on Finance, Legislative Decree 58/98), Section I-ter (“Transparency of institutional investors, asset managers and consultants on voting rights”) have not been met. This is because the investment policy of the funds currently under management (the “Fund”) is not aimed at investing in companies with shares admitted to trading on regulated Italian or other EU member states’ markets. As foreseen by the management rules of the Funds, the investments admitted in said companies are conditional upon a series of limitations and well-defined cases (e.g. percentages of the fund’s assets, listing after the initial investment by the fund or companies acquired in delisting transactions). Furthermore, as of the publishing date of this notice, the Funds do not have portfolio companies with shares admitted to trading on regulated Italian or other EU member states’ markets. The Company shall proceed with drawing up and publishing a Policy of Engagement should the conditions foreseen by law be met in the future.

For any further information on the policies and procedures adopted by 21 Invest SGR S.p.A., please contact info@21invest.com.

Please note that separate policies are adopted by the individual management companies in order to respect local market legislation and requirements.