Individual portfolio management

As part of the provision of the portfolio management service on an individual basis, Mediobanca, through the managing director, takes the negative effects for sustainability at the Company level into account in making investment decisions.

In line with the approach established at Group level, Mediobanca has defined the principles on the basis of which the PAIs and related indicators are taken into consideration, ensuring compliance with the principles of management responsibility towards its stakeholders.

These effects and calculation of the related indicators are taken into consideration the Bank in order to:

  • Adopt a responsible investment approach, in accordance with international principles and standards on climate and the environment, as well as labour rights, human rights and anti-corruption;
  • Define the objectives to be pursued in order to reduce the negative impacts on sustainability deriving from the Bank's investment decisions, and any actions to be taken if the objectives are not achieved;
  • Ensure growing and continuous active engagement on the part of its stakeholders in issues related to sustainability.




In order to take account of the PAIs, the Bank has implemented, consistent with regulatory requirements, an activity of monitoring the PAIs in order to carry out the analyses and assessments regarding the positioning of the indicators and the sensitivity of the portfolio to them. This activity is aimed at the progressive definition of target objectives and their prioritization for achievement to reduce the negative sustainability impacts resulting from investment decisions.

In particoular, beyond the mandatory PAIs, the procedures adopted by the Bank identify the optional indicators to be considered based on the following variables:

  • Consistency between the selected PAIs and the environmental, social and good governance objectives defined at Group level;
  • Availability of data relating to each indicator from external sources and not estimates;
  • Coverage of the data available for each indicator with respect to the weight of the issuers/financial instruments in the portfolios managed.

In order to comply with the requirements of time-to-time regulations on an increasing percentage of managed portfolios, the Bank is constantly committed to obtaining updated and reliable data on ESG issues through the sources indicated above. However, it should be noted that in some cases the availability of data referring to individual PAIs and the level of coverage of issuers may not be guaranteed.

Precise definition of the (1) reduction targets of the PAI indicators and (2) the actions to be taken to avoid or reduce the negative effects on sustainability will take place progressively, based on the monitoring activities and availability of the related information, in order to publish the information referred to in points (1) and (2) by the deadline set by the reference regulation.




In order to take PAIs into consideration and calculate the related indicators and targets, plus any actions required in order to manage exposure to them (including in view of possible changes in the regulations), the Bank, inter alia through the delegated manager, has set the following plan for completing the consideration:

Completion of the model for considering the PAIs, including further indicators and related definition of calculation methods;

  • Analysis of the performance of the PAIs on managed portfolios, and definition of targets for reducing PAIs;
  • Adaptation of investment and engagement policies in order to ensure the targets are met;
  • Implementation of the calculation and monitoring process.




The Mediobanca Group believes that compliance with ESG criteria can generate improved long-term performance for investors.  This is why, at every meeting and/or useful contact opportunity, it is committed to encouraging the companies in which it has invested (and in which it intends to invest) to engage in open dialogue regarding their responsible approach and how ESG factors affect their businesses.

Engagement activity is also carried out with a view to achieving the objectives in terms of reducing the negative effects on sustainability.




The Bank, in line with the Group, recognizes the value of involving its shareholders and stakeholders, in general, by adhering to international principles and standards in line with its own approach as a sustainable and responsible investor.

The Group is a signatory to the UN Global Compact, requiring it to share, support and apply a set of universally agreed principles in its sphere of influence as derived from the Universal Declaration of Human Rights, the ILO Declaration, Rio Declaration and the United Nations Convention against Corruption.

The Mediobanca Group has become a signatory to the Principles for Responsible Banking, in addition Mediobanca SGR is a signatory to the Principles for Responsible Investment (PRI) [4].

In order to guarantee the relationship of trust with the shareholder, the Group has adopted, in compliance with national legislation, an organization, management and control model pursuant to Legislative Decree 231/2001, and the Bank, like all Group companies, has adopted:

  • Its own Code of Ethics, which applies to directors, auditors, employees, consultants, interns, external collaborators and suppliers;
  • Its own Code of Conduct, which defines the fundamental principles underlying the bank's reputation and contains the values based on which its daily operations are performed.investment advisory