Disclosure Pursuant to Article 4 of Regulation (EU) 2019/2088 on Sustainability Risk

Policies on Integrating Sustainability Risks in the Advisory Service

Pursuant to Article 165(1)(h-bis) of the Intermediaries Regulation, in the process of selecting financial instruments for investment advisory services, AVERAU CAPITAL PARTNERS SCF SRL SEMPLIFICATA UNIPERSONALE incorporates an assessment of environmental, social, and governance (ESG) sustainability factors. This ensures that the various products and instruments are recommended only to clients whose sustainability preferences are compatible with the characteristics of the instruments.

Since the advisory service provided by AVERAU CAPITAL PARTNERS SCF SRL SEMPLIFICATA UNIPERSONALE concerns the financial portfolio as a whole, the evaluation 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, for risk management reasons or to achieve the client’s objectives, some individual instruments may not be individually aligned with those preferences.

The assessment of environmental, social, and governance characteristics is conducted depending on the type of instrument/product, based either on information disclosed by the issuer under applicable regulations, external evaluation models (ratings), and/or internal analyses.

No Consideration of Actual Negative Impacts on Sustainability Factors

At present, given the partial availability of data from manufacturers necessary to assess negative impacts on sustainability, such effects cannot be taken into account in the provision of advisory services. AVERAU CAPITAL PARTNERS SCF SRL SEMPLIFICATA UNIPERSONALE will periodically review data availability from manufacturers and, once comprehensive data are available, will consider assessing negative impacts on sustainability factors in relation to the advisory service provided.

Consistency of Remuneration Policies with the Integration of Sustainability Risks

AVERAU CAPITAL PARTNERS SCF SRL SEMPLIFICATA UNIPERSONALE takes sustainability risks into account in complying with organizational requirements and remuneration practices. Remuneration and fees paid to third-party providers are determined in a manner that does not conflict with policies for selecting instruments with regard to sustainability factors.