Company name: 21 INVESTIMENTI SGR S.P.A.
Business Entity: SOCIETÀ DI GESTIONE DEL RISPARMIO
Headquarters: Viale G. Felissent 90, 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
Fax: +39 0422 31 67 77
21 INVESTIMENTI 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 Investimenti SGR S.p.A. is made up of Alessandro Benetton (Chairman), Dino Furlan (Chief Executive Officer) and Marco Monis (Vice Chairman), as well as independent external members – Graziano Visentin, Francesco Scanagatta and Gianmarco Maffioli.
The 21 Investimenti 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.
21 Investimenti voluntarily adopted an ‘organizational management and control model’ in accordance with Italian Legislative Decree no. 231 (i.e. “Modello 231”), referring to measures to prevent potential crimes, corruption and bribery. This procedure involves the presence of a dedicated supervisory committee, made up of three independent external members, who regularly check that all procedures to prevent crimes, corruption and bribery are correctly implemented by 21 Investimenti.
21 Investimenti SGR SpA has joined the Arbitrator for Financial Disputes (Arbitro per le Controversie Finanziarie – “ACF”) established by Consob with resolution no. 19602 dated May 4, 2016, which regulates its operations, structure and procedures. The ACF settles disputes between retail investors and intermediaries (including, in such case, 21 Investimenti SGR SpA). In the below document (ACF guidelines) there is an overview of how the ACF works.
For further details, please refer to the ACF website: https://www.acf.consob.it
In reference to the implementation of EU Directive 2017/828 – also known as the Shareholder Rights Directive II (“SRD II”) – into Italian law, 21 Investimenti 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 Investimenti SGR S.p.A., please contact email@example.com.
Please note that separate policies are adopted by the individual management companies in order to respect local market legislation and requirements.