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Incorporation of ESG criteria within Investment Policies The incorporation of ESG principles into the investment processes used by Poste Vita and BancoPosta Fondi SGR is of particular significance.

The increasing proliferation of sustainable finance and the expansion of responsible investments are testament to the fact that inclusion of ESG considerations has become a strategic pillar, consistent with the general recognition that a shared course of action is needed in order to make a substantial contribution to sustainable growth.
This conviction has, for some time now, determined the responsible Investment approach adopted by the Poste Italiane Group with regard to the investment activities of BancoPosta Fondi SGR and Poste Vita. Indeed, for some time now, this vision has been a part of the Group's strategy1, with the principles of sustainability applied in all areas in which it operates, including the financial sector, in the firm belief that, thanks to its efficient investment processes, the asset management and insurance sectors can help protect society, promote innovation and support economic growth. 

Poste Vita and BancoPosta Fondi SGR have signed up to the United Nations Principles for Responsible Investments (PRI), making a formal commitment to incorporate ESG criteria in their assessment and decision-making investment processes, and to apply such criteria in relations with counterparties.
This decision results from the strong belief that integrating environmental, social and governance factors within its investment processes is key to achieving sustainable performances over time, reducing the portfolio’s risk profile and acting in accordance with the principles of integrity and transparency. In this regard, as part of its Responsible Investment Policies, Poste Vita and BancoPosta Fondi SGR contemplate the monitoring, through periodic assessment, of risks related to environmental factors – such as climate change, social factors – such as human rights, and governance factors – such as governance diversity.

This decision results from the strong belief that integrating environmental, social and governance criteria within its investment processes is key to achieving sustainable performances over time, reducing the portfolio’s risk profile and acting in accordance with the principles of integrity and transparency.

During 2022, regulatory technical standards were defined. "RTS", Delegated Regulation (EU) (2022/1288) governing the presentation and content of the disclosures required under Regulation (EU) 2019/2008 ("Sustainable Finance Disclosure Regulation" or "SFDR") and Regulation (EU) 2020/852 ("Taxonomy Regulation").
In view of the entry into force of the RTS, BancoPosta Fondi SGR and Poste Vita have been called upon to adapt to the provisions, in particular by updating the disclosure in the precontractual documentation with the preparation of the annexes and the adaptation of the disclosure on the website for all Group products that promote environmental or social characteristics (as per Art. 8 SFDR). For these products, periodic reporting has been conducted from early 2023.

Poste Italiane considers it fundamental to participate in dialogue with institutions, trade associations and the financial sector in order to contribute to the dissemination of sustainable finance and the promotion of sustainable development in the belief that joint action can generate more concrete results towards sustainable development.

In this regard, the Poste Vita Group and BancoPosta Fondi SGR have adopted respectively the Guidelines on the exercise of voting rights and engagement activities, which outline the objectives, scope and methods of voting and engagement. Specifically, n line and in application with the provisions of the Guideline for Investment in Sensitive Sectors and the Responsible Investment Policy, Poste Italiane is committed to implementing of constructive engagement conducted with the issuers in its portfolios and to exercising its voting rights related to the shareholdings held2, in order to manage ESG issues and risks and support awareness regarding sustainability outcomes. In addition, in this regard, through specific guidelines, declines how to consider using engagement actions in case it invests in companies operating in sectors deemed sensitive to environmental issues – such as climate change, biodiversity, or social issues – such as human rights – or governance.

Specifically, the Group confirmed its adherence to social and environmental initiatives such as: Access to Medicine Index, aimed at raising awareness in the pharmaceutical sector and facilitating access to medicines for the world's poorest population groups in line with the UN Sustainable Development Goals; Land use and Climate Working Group of the international Ceres network, which since 1989 has aimed to improve the management of emissions and natural resources through targeted engagement activities; Access to Nutrition US Index, Workforce Disclosure Initiative (WDI), ClimateAction 100+.

Furthermore, like before, dialogue activities on ESG issues with listed companies were carried out as part of the “Engagement” Working Group of the Forum for Sustainable Finance and Borsa Italiana's Digital Italian Sustainability Week. In this regard, the constructive investor-business dialogue on sustainability issues deemed relevant by the Working Group initiated by the Forum for Sustainable Finance itself continued in 2023.

In relation to the activity carried out by Poste Vita, during 2022 the Group implemented several engagement initiatives: the 2022 Global Investor Statement to Governments on the Climate Crisis, as part of the Investor Agenda, is a collaborative engagement initiative that includes all the major investor networks engaged on climate - AIGCC, CDP, Ceres, IGCC, IIGCC, PRI and UNEP FI, and which led to the drafting of a letter (in line with what was achieved in 2021), of which Poste Vita is a signatory, with the objective of managing ESG risks/opportunities and thus enabling an increase in the understanding of the issue by the world leaders to whom the letter was addressed. The REPower EU business letter, drafted by the University of Cambridge and for which the Poste Vita Group is a signatory, is a collaborative engagement initiative aimed at policy makers; this was conducted to delivering sustainable outcomes in the environmental sphere as it aims to request the European Commission to accelerate the energy independence plan and avoid new fossil fuel-based projects. The PRI-led collaborative stewardship initiative on social issues and human rights, is a collaborative engagement initiative coordinated by the PRI that provided for dialogue with international companies on social issues and respect for human rights; specifically, the topics covered referring to the aforementioned sustainability challenges, and aimed at ensuring a greater understanding of them, covered several macro-categories in the areas of full implementation of UNGPs, responsible political engagement, and additional company-specific expectations on human rights issues.

In addition, during 2022, Poste Vita did not exercise its voting rights – and therefore no ESG resolutions were made – because its portfolios, at present, do not characterized by direct equity3, although, as part of its voting activities, the Group nevertheless takes into consideration guidelines that contemplate environmental, social, and governance factors within the same voting activities. In any case, should particular cases arise such as to lead the Organization to submit possible resolutions, Poste Vita takes into consideration criteria useful for positively influencing the behavior of sustainability practices conducted by the companies in which the Group invests (ESG resolution), as well as considers adopting decision-making steps to support any shareholder resolutions with respect to, for example, additional issues; moreover, in this context, Poste Vita, despite not adopting voting recommendations provided by external service providers, evaluates the possibility of ensuring the alignment of these recommendations with its own internal guidelines, in the same way as BancoPosta Fondi SGR does in the context of its own activities.

In 2022, BancoPosta Fondi SGR published for the first time a report of engagement activity and voting rights exercised in the previous year in respect to the instruments held in the portfolio. During 2022, a process was also undertaken to update the system of policies that define the approach for integrating ESG criteria into the investment processes of Poste Italiane, with the aim of aligning the Responsible Investment strategy with changes in the external context, the regulatory framework and best practice and to incorporate internal developments.

Eventually, the placement of "Poste Gestione Patrimoniale", a portfolio management arrangement in collaboration with Moneyfarm, has been launched in 2022. It features 4 diversified ETF investment lines, calibrated according to customers' risk propensity and investment objectives, and characterised by an investment policy geared towards ESG factors.

As such, the Group the Group has established Responsible Investment Policies for both BancoPosta Fondi SGR and Poste Vita. the Responsible Investment Policy of Banco Posta Fondi SGR covers all the AuM. While, the Poste Vita Group's Responsible Investment Policy covers in terms of AuM 100% of active investments, 25% of passive investments, and 80% of externally managed assets.
2 The share of AuM in terms of active investments to which the Poste Vita Group's Guideline on Voting Exercise and Engagement Activities applies represents the totality of the same investments (100%); on the other hand, the share of AuM in terms of passive investments turns out to be 25%. With reference to BancoPosta Fondi SGR, the Guideline applies to the totality of AuM, with the exception of passive investments for which there is no exercise of voting rights.
3 During 2022, management mandates characterized by equities account for about 0.2% of total assets.

ESG criteria within Investment Policies