Last Updated: Feb 2023
Last Updated: Feb 2023
The Mediolanum Group considers sustainability as an integral part of its culture and one of the fundamental elements of its business model. As part of the Mediolanum group, MIL believes that incorporating sustainability into its business will result in long-term added value and contribute to the realisation of our Vision and Values.
Our Vision is in line with the Action Plan defined by the European Commission to strengthen the role of finance in the creation of an efficient economy that also achieves environmental and social objectives.
Sustainability represents a strategic choice for which the companies of the Mediolanum Group share the fundamental guidelines and have developed an approach to responsible investments that combines economic and profitability objectives with ESG (Environmental, Social, Governance) factors in the analysis and in the management of investment solutions.
Mediolanum International Life DAC (“MIL”) is authorised to issue life insurance products and is responsible for the general management and the administration of these products. MIL has appointed as its investment manager Mediolanum International Funds Limited (MIFL), a group company.
MIFL defines “responsible investment” as the integration of sustainability considerations, including environmental, social and governance (ESG) factors, sustainability risk and active ownership, i.e. seeking to drive change through engagement and proxy voting in investee companies, into the investment decision-making process.
This approach applies to all its clients including, funds managed by MIFL and those non-fund clients who have engaged MIFL as a discretionary portfolio manager (i.e. MIL).
Environmental, Social and Governance (ESG) issues are integral to the values and culture of the Mediolanum Group. These values are also embedded in MIFL’s Investment Process. Central to MIFL’s investment process is the analysis of an investment’s ability to create, sustain and protect value to ensure that it can deliver returns. In addition to this, MIFL also adopts a Responsible Investment Policy, the primary focus of which is ESG integration and active ownership including engaging and voting with the objective of improving performance in these areas.
MIFL is committed to and supports the objectives of all 17 United Nations Sustainable Development Goals (SDGs). In 2020, MIFL decided to prioritise three climate-oriented SDGs (7, 12 and 13) to assess assets under management, with an aim to seek improvement in the long term, as climate change is a clear and pressing issue which needs to be addressed. Through engagement with managers, MIFL seeks to drive improvement across these 3 specific SDGs.
To measure and monitor MIFL’s impact on these three SDGs at an entity level, MIFL has selected five Principal Adverse Impact (PAI) indicators aligned to these SDGs. They are:
MIFL has also chosen a sixth PAI indicator, Board Gender Diversity, which, although not linked to the three selected SDGs, is an important area where it aims to deliver change.
Through regular and active monitoring of these six indicators, MIFL will look to engage indirectly through the managers of its mandates or directly through engagement via its Single Securities Teams, to affect improvement over time.
MIFL also aims to mitigate the negative impacts of its investment decisions on sustainability factors by considering PAIs as part of the investment process. These impacts can occur in different areas, such as environmental, social and employee matters, human rights, corruption and bribery matters.
The Mediolanum group has implemented an exclusion policy applicable to all group entities and all group assets. This exclusion policy aligns with new legislation -LEGGE 9 Dicembre 2021 -n. 220- passed by the Italian parliament and which became effective as of 1 January 2023. The aim of the exclusion policy is to prohibit investments in companies involved in the financing, production, use, sale, distribution, import, export or transfer of anti-personnel mines, cluster munitions and submunitions. Implementing this policy represents the group’s ongoing commitment to invest responsibly, to align with evolving regulatory and legislative obligations and to focus on sustainability at all levels across the Mediolanum group.
In accordance with new legislation and group policy, MIFL has implemented an exclusion policy which covers direct investments as well as delegates.
MIL meets the definition of a Financial Market Participant (“FMP”) under the Sustainable Finance Disclosure Regulation (the “SFDR”). Under the SFDR, MIL is required to publish a number of disclosures on its website. The attached statement has been prepared to address the SFDR requirements.