In accordance with the European regulatory framework referring to the integration of ESG factors in the assessment of adequacy of transactions, the Bank's model for the provision of investment advisory services (covering, among other products, portfolio management on an individual basis) includes safeguards aimed at collecting and considering the sustainability preferences of clients, in compliance with the regulations in force from time to time.
The sources adopted for the retrieval of information regarding the financial instruments/products being advised on the relative consideration or otherwise of negative sustainability effects and, if applicable, related PAI indicators, are:
- specialized external info providers;
- information obtained directly from the companies/counterparties concerned;
- product governance information disclosed by individual third-party asset managers regarding the products created and managed by them (by means of the European MiFID Template "EMT" and, if available, "EET").
In addition, in order to be able to ensure the performance of a suitability assessment based on the client's overall portfolio, the Bank has planned to use, with reference to financial instruments that do not fall within the perimeter provided for by the relevant regulations (e.g., stocks, bonds, etc.) the indicator referring to the level of ESG Rating assigned to individual instruments.
Without prejudice to the obligation to collect sustainability preferences in accordance with applicable regulations, the consideration of such preferences in the context of the advisory service remains subordinate and will be activated only after the investment houses and info-providers used have made available to the Bank the data and information relating to the individual financial products/instruments necessary for carrying out the assessment of suitability with respect to clients' sustainability preferences.
This is without prejudice to Mediobanca's commitment to procuring the necessary data and information in order to be able to comply with the requirements of the regulations in force from time to time.
CONSIDERATION OF PRINCIPLE ADVERSE SUSTAINABILITY IMPACTS
The collection of client’s sustainability preferences also allows for the consideration of negative sustainability effects within the advisory service.
As stipulated in the relevant regulations, the collection of client’s sustainability preferences is also aimed at identifying, among others, whether clients are interested in investment products that take into account negative sustainability effects. This indication is taken into account when assessing the suitability of transactions with respect to client sustainability preferences in the provision of investment advisory services.
The suitability model defined by Mediobanca allows clients to be offered, where consistent with their sustainability preferences, financial instruments/products that consider negative sustainability impacts, with regard to environmental and/or social aspects, by leveraging information published by investment houses, in accordance with the SFDR Regulation and its implementing technical standards.