Companies / Global Selection SGR SpA /

Information pursuant to Articles 3, 4, 5 of Regulation (EU) 2019/2088 ("SFDR")

The nature of the environmental and social challenges to be faced at a global level has increased, in recent years, the attention towards sustainable finance, i.e. attentive to the consideration and enhancement of environmental, social and good governance issues (briefly issues indicated with the initials "ESG" - Environmental, Social and Governance). The creation of a financial system capable of promoting sustainable development that favors the needs of present and future generations led the European Commission to publish, in March 2018, the "Action Plan for sustainable finance" to guarantee, among other things, another, the transparency of the asset managers in favor of the final investors. In this context, the European legislator has adopted Regulation (EU) 2019/2088, relating to information on sustainability in the financial services sector ("Regulation 2088"). Regulation 2088 establishes specific disclosure obligations for financial market participants (including asset management companies) and, in particular, requires providing information on:

- how they integrate sustainability risks into their investment decision-making processes (see Article 3 of Regulation 2088);

- any assessment of the main negative effects of investment decisions on sustainability factors (see Article 4 of Regulation 2088); And

- the integration of sustainability risks within the remuneration policies (see Article 5 of Regulation 2088).


This document intends to clarify the choices made by Global Selection SGR S.p.A. ("SGR" or "Company") with respect to issues related to sustainability, taking into account the operations of the SGR as well as the characteristics of the financial products established and managed by the same.

With regard to sustainability risks, it is specified that the Company - although aware of the importance of including environmental and social objectives in financial decision-making processes - does not currently directly and independently integrate these risks within the selection process. of the investments of its own reserved alternative investment funds "Global Managers Selection Fund" and "China Managers Selection Fund" ("Funds" or "AIF").

This circumstance is motivated, in particular, by the characteristics and investment policy of the Funds, which qualify as feeder funds, mainly investing their respective assets in the "Selection Holdings - Atlantic Selection", Share Class F, and "Selection Holdings" sub-funds. - China Selection ", Share class F, of the Luxembourg-based investment company with variable capital reserved for professional investors called" Selection Holdings SA, SICAV-FIAR "(" Master Fund ").

The master-feeder structure of the AIFs and, in particular, the investment policy pursued by the Master Fund with which the AIFs are required to comply - which in turn does not value the sustainability risks in the selection of UCIs in which to invest - do not allow current status, the SGR to take these risks directly into consideration as part of its management activity. In addition, it is specified that the investments underlying the AIFs do not take into account the EU criteria for eco-sustainable economic activities as defined by Regulation (EU) 2020/852. The SGR also intends to specify that, in compliance with Article 4, paragraph 1, point b) of Regulation 2088, it does not currently take into consideration the negative effects of its investment decisions on sustainability factors (so-called Principal adverse impact - "PAI "). Also in this case this choice is a consequence, as highlighted above, of the nature of the financial products managed as well as of the investment policy of the Master Fund.

In any case, the Company is aware of the importance that sustainability issues play in the management of investments and has launched internal evaluations to identify the most correct and adequate methods in order to enhance, by the end of 2022, these aspects in the context of of their management activities. The remuneration and incentive mechanisms adopted by the Company and formalized in the “Remuneration and incentive policies” are aimed at the good governance of the Company, however, at present, they do not take into consideration the sustainability risks as stated above. In this context, however, internal analyzes will be conducted with the aim of integrating sustainability risks into the SGR's remuneration policies. In this regard, the SGR will be responsible for providing updates on the activities carried out to integrate sustainability risks into investment processes as well as to consider the negative effects of the investment decisions taken on sustainability factors.