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INFORMATION PURSUANT TO ART. 4 OF REGULATION (EU) 2019/2088 ON SUSTAINABILITY RISK
Pursuant to Art.165 paragraph 1 letter h-bis of the Intermediaries Regulation, in the process of selecting financial instruments subject to the investment advisory service, the ADVISOR integrates an assessment regarding environmental, social, and governance sustainability factors, in order to ensure that the various products and instruments can only be recommended to clients who express sustainability preferences compatible with the characteristics of the instruments.
Since the advice provided by the ADVISOR concerns the financial portfolio as a whole, the assessment of sustainability factors is carried out at the portfolio level. This means that, overall, the portfolio must be aligned with the client's sustainability preferences, even though it is possible that, for risk management reasons or to achieve the client's objectives, some individual instruments used may not be individually aligned with the client's 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 pursuant to current regulations or by using external evaluation models (ratings) and/or analyses carried out internally.
© Marco Galli 2019
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