BUSINESS PRINCIPLES & ESG

Business Principles (officially adopted by PEP from 2002)

Our participated companies’ interest always comes first. Our experience shows that if we serve our participated companies well, helping them in maximising their corporate value, our own success will follow and our investors’ interest is protected and maximised.

Our key assets are our people and reputation. We are dedicated to fully complying with the laws, rules and ethical principles that govern us. Our continued success depends upon unswerving adherence to this standard.

We take great pride in the professional quality of our work. We have an uncompromising determination to achieve excellence in everything we undertake. Though we may be involved in a wide variety of activities within the private equity business, we would, if it came to a choice, rather be best than bigger.

We stress creativity and imagination in everything we do. While recognising that the old way may still be the best way, we constantly strive to find a better solution to problems.

We make an unusual effort to identify and recruit the very best person to work for us and we carefully select our people one by one. In our business we know that without the best people we cannot be the best firm.

We offer our people the opportunity to put to fruitful use their expertise and skills more rapidly than is possible at most other places. We have yet to find the limits to the responsibility that our best people are able to assume. Their own success depends solely on ability, performance and contribution to the firm’s success, without regard to race, colour, religion, sex, age, national origin, disability, sexual orientation, or any other impermissible criterion or circumstance.

We stress teamwork in everything we do. While individual creativity is always encouraged, we have found that team effort often produces the best results. We have no room for those who put their personal interest ahead of the interest of the firm, our participated companies and our investors.

The dedication of our people to the firm and the intense effort they give to their jobs are greater than one finds in most other organisations. We think that this is an important part of our success.

Returns and profitability are key to our success and crucial to our future. It is our practice to share our profits generously with all who helped create them.

We consider the relationship with our investors a key element for our success and future. We strongly want to assure them the best possible service we can, protecting their resources, maximising their interest and returns, and allowing them to be informed and updated on everything we do in their interest.

We constantly strive to anticipate the rapidly changing needs of the environment. We know that the world of finance and private equity will not stand still and that complacency can lead to extinction.

We regularly receive confidential information as part of our normal business relationships. To breach a confidence or to use confidential information improperly or carelessly would be unthinkable.

Our business is highly competitive and we aggressively seek to expand our business relationships. However, we must always be fair competitors and must never denigrate other firms.

Integrity and honesty are at the heart of our business. We expect our people to maintain high ethical standards in everything they do, both in their work for the firm and in their personal lives.

Regulation (EU) 2019/2088 on sustainability‐related disclosures in the financial services sector

The following disclosure is issued by Private Equity Partners SGR S.p.A. according to Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability‐related disclosures in the financial services sector (“the Regulation”), in accordance with Articles 3.1 and 4.1.b of The Regulation. The disclosure aims to illustrate its policies on the integration of sustainability risks in its investment decision‐making process.

Information on policies on the integration of sustainability risks in accordance with Articles 3.1 of the Regulation

Sustainability risk means "an environmental, social or governance event or condition that, if it occurs, could cause an actual or a potential material negative impact on the value of the investment". Sustainability risks, in case they occur, may have a negative impact on the value of the portfolios managed by Private Equity Partners SGR S.p.A.

Private Equity Partners SGR S.p.A. has not integrated sustainability risks in its investment decision‐making process yet, since the sole private equity closed-end Fund currently managed is under liquidation.

Financial market participant’s decision not to consider principal adverse impacts of investment decisions on sustainability factors in accordance with Article 4.1.b of the Regulation

Principal adverse impacts mean "negative impacts of investment decisions on sustainability factors. Private Equity Partners SGR S.p.A., for the same reasons stated above, does not consider the main negative impacts of investment decisions on sustainability factors, as defined in the Regulatory Technical Standards (Annex 1, Table 1 and following) issued by ESMA ON February, 2nd 2021 (“RTS”).

However, Private Equity Partners SGR S.p.A. is sensitive to all the main adverse impacts of investment decisions on sustainability factors. In relation to the possible launch of new alternative investment funds, the Board of Directors will approve a specific ESG policy, so that the application of ESG (Environmental, Social, Governance) and sustainability factors become an integral part of the investment activities.

Moreover, procedures regarding decision-making process, including product governance and risk management policy, will be integrated and modified, to make them compliant with the Regulation.