Disclosure

Company Policies

POLICY FOR THE MANAGEMENT OF CONFLICTS OF INTEREST

Banor SIM has taken all reasonable steps to identify conflicts of interest that may arise in the performance of its services. Under the current regulations, Banor SIM is required to identify any circumstances which constitute or could give rise to a conflict of interest that could seriously harm the interests of one or more investors. It is required to adopt an effective policy for managing conflicts of interest, appropriate to the size and the organisation of Banor SIM itself, as well as to the nature, scale and complexity of its business.
Banor SIM has therefore identified those conflicts of interest that could arise when providing investment services or activities and has drawn up procedures to be followed and measures to be adopted to manage and eliminate such conflicts.
Should further conflicts of interests arise, and the measures put into place prove not to be sufficient to avoid (with reasonable confidence) any damage to the interest of managed assets, Banor SIM will inform its investors in a clear and detailed manner.
Download the pdf file (in Italian).

POLICY FOR THE TRANSMISSION AND EXECUTION OF ORDERS

Banor SIM, in providing the portfolio management service, undertakes to take all reasonable steps to obtain the best possible results, to be considered as the best “expected” possible outcome and not the best “actual” outcome.
Banor SIM has therefore drawn up a strategy for the transmission and execution of orders with the aim of obtaining the best possible results for the clients to whom it provides the portfolio management service.
In implementing investment decisions, the company executes or transmits orders using intermediaries of high standing who meet the criteria of confidentiality, reliability and financial soundness required to ensure the smooth running of operations and minimise any risk. To this end, for each type of financial instrument/market Banor SIM employs more than one intermediary in order to avoid an excessive concentration with respect to any single counterparty and reduce the possibility of the market recognising the investment strategies adopted.
Download the pdf file (in Italian).

ORGANISATION, MANAGEMENT AND CONTROL MODEL IN ACCORDANCE WITH LEGISLATIVE DECREE NO. 231/2001

The Organisation, Management and Control model adopted by Banor SIM in accordance with legislative decree no. 231/2001 is designed to reflect the rules of operation and conduct governing the activities of the company, as well as additional checks and controls it has adopted to prevent the commission of the types of offence covered by the Decree.
Banor SIM operates in strict compliance with the laws and regulations currently in force. With this model, the company intends to pursue the goal of disseminating a culture of legality among its employees and among all those interacting with its business organisation.
The Code of Ethics forms an integral part of the Organisation, Management and Control Model adopted by the Company, and the ethical principles contained therein are relevant for the purpose of preventing the crimes referred to in the aforementioned Decree; they also constitute an essential element of the Internal Control System.
Download the Organisation, Management and Control Model in pdf file (in Italian).
Download the Code of Ethics in pdf file (in Italian).

INVESTMENT SERVICES DISCLOSURE DOCUMENT

The pre-contractual disclosure document is intended to provide clients or potential clients of Banor SIM S.p.A. with the appropriate information to enable them to reasonably understanding the nature of the investment and supplementary services and the financial instruments offered by the investment firm, as well as the related risks. The aim, therefore, is to enable clients to make informed investment decisions.

Download the pdf file (in Italian).

ANNUAL DISCLOSURE ON THE IDENTITY OF EXECUTION VENUES (RTS 28)

Each year, and for each category of financial instrument, Banor SIM publishes information on the first five intermediaries by trading volume to which it has sent or with which it has placed clients’ orders for execution purposes, along with information on the quality of execution. This is in compliance with the obligations envisaged under Article 27(6) of Directive 2014/65/EU (MiFID II) and Article 65(6) of Commission Delegated Regulation (EU) 2017/565 and with the provisions of Commission Delegated Regulation (EU) 2017/576 (known as Regulated Technical Standard (RTS) 28).

Download the pdf file (in Italian) year 2023.
Download the pdf file (in Italian) year 2024.

INFORMATION ABOUT PROCESSING COMPLAINTS AND THE PROCEDURES FOR SETTLING DISPUTES OUT OF COURT

SIM has adopted procedures to ensure that complaints filed by retail customers or potential retail customers are diligently processed.
The document specifies the methods envisaged and includes a guide for investors on using the procedure to bring an appeal before the Arbitro per le Controversie Finanziarie (Italian Financial Disputes Arbitrator).
Download the pdf file (in Italian).

THE COMMITMENT POLICY IN THE PORTFOLIO MANAGEMENT

Adopted pursuant to art. 124-quinquies of the TUF, the commitment policy describes the methods used by Banor SIM in the context of portfolio management to monitor the investee companies on relevant issues. These issues include: strategy; financial and non-financial results; risk; capital structure; social and environmental impact, and corporate governance. The policy also covers how the company interacts with the investee companies, exercises voting rights and other rights related to shares, collaborates with other shareholders, communicates with the major stakeholders of the investee companies and manages current and potential conflicts of interest in relation to this commitment.

Download the commitment policy in pdf file (in Italian).
Download the 2022 implementation guidelines for the Commitment Policy in pdf file (in Italian).
Download the 2023 implementation guidelines for the Commitment Policy in pdf file (in Italian).
Download the 2024 implementation guidelines for the Commitment Policy in pdf file (in Italian).

REPORTING FOR PRODUCTS QUALIFIED AS “ETHICAL” OR “SOCIALLY RESPONSIBLE

We provide the information required by Article 137 of the Intermediaries Regulations adopted by Consob via resolution No. 20307 dated 15 February 2018 on products qualified as “ethical” or “socially responsible”.

Download the pdf file (in Italian) year 2023.