Procedures for prevention of conflicts of interest

This document provides an overview of the organisational procedures to prevent conflicts of interest at EnVent Italia SIM (hereinafter “EnVent”) concerning the production and publication of reports and recommendations (hereinafter “Research”).


General guidelines for Research activity
When producing Research, members of the Research Team must:
1. provide an impartial evaluation;
2. prepare documents in a manner that is clear and in no way misleading, in accordance with the following guidelines:
• facts must be kept clearly distinct from interpretations, evaluations, opinions, or from other types of non-factual information;
• all sources must be reliable. Any doubt as to their reliability must be clearly stated;
• all projections and all forecasts must be clearly indicated
3. use a sufficiently wide range of information on which investors may base their investment decisions;
4. refrain from receiving or requesting specific direct or indirect compensation from third parties in exchange for any opinions expressed.


Organisational procedures
In order to guarantee the independence and impartiality of judgement of financial analysts involved in the preparation of recommendations to be distributed to clients and/or investors, EnVent applies organisational and administrative procedures as well as a Conflict of Interest Policy. The measures adopted include the following:
1. The Research work is organized, carried out and published by team members who have no involvement nor any other kind of interest with respect to activities or projects for the  companies under coverage;
2. The Head of the Research Team reports directly and exclusively to the Chief Executive Officer and have the authority, resources and know-how required to perform his role;
3. Analysts work in separate offices from the rest of the company;
4. Computers and general information and data prepared/applied by the Research Team are kept separate from those of the other offices. Moreover, analysts only have access to the information and data required to perform their specific tasks, by means of authorisation procedures using passwords;
5. Requests or instructions to collaborate with other EnVent departments that may potentially give rise to conflicts of interest under current regulations must be given solely by the Board of Directors;
6. In dealings with EnVent’s other departments, the Head of Research and the financial analysts must refrain from seeking, receiving or supplying information that may impact independence and/or impartiality of judgment in the production of reports and/or investment recommendations, or encourage unbalanced distribution of information both inside and outside EnVent, generally observing the principles and rules of conduct established by the current Internal Procedures Manual;
8. Compliance with internal procedures and regulations is monitored by the internal control functions (Compliance).

Euronext Growth Advisor (EGA)
Analysts’ remuneration must not be related, either directly or indirectly, to specific  investment transactions or to market operations in which EnVent will or has played a role (i.e. Euronext Growth Advisor or Global Coordinator).

Supervision and control
Analysts who publish Research are under the supervision of and report solely to the Head of Research. Analysts do not report to and are not under the supervision of any member of the EGA   or the Sales teams. The Head of Research report directly to the Chief Executive Officer. 
Before publication, every research note is reviewed by the Head of Research. The purpose of this review is to check compliance with legal and regulatory requirements, as well as with in-house rules. Research is not subject to pre-publication review or approval by parties other than the Head of Research, with the exception of possible periodical and random checks on a sample basis by the Compliance function.

Chinese Walls
The company has installed information barriers (“Chinese walls”) to the exchange of information between the Research Team and the EGA Department. These barriers separate the two sectors in terms of logistics, information and organisation.
These barriers enable the Research Team to conduct research and formulate recommendations (“ordinary course of business”) involving issuers subject to coverage, regardless of the fact that the  EGA department has access to privileged information of  the same issuers.

Methods and timing of distribution
Decisions on the timing of Research publication are not taken, or influenced, by persons with interests conflicting with those of Research recipients;
The contents of the Research are circulated according to a previously established order, timing, and channels; more specifically, EnVent distributes Research primarily via e-mail (by means of a dedicated customer database system), with the aim of ensuring that the Research is made available simultaneously to similar categories of recipients.
EnVent’s procedures prevent Research from being made available to the staff of the company’s other departments, including EGA team people, before it has been sent to clients.

Personal investments of analysts
All analysts’ investments and securities transactions are subject to in-house rules contained in the “Internal Procedures Manual” and the “Internal Code of Conduct”.
Head of Research and financial analysts are prohibited from engaging in transactions involving the  financial instruments, or related products, of companies covered by the Equity Research service.

The Compliance Function may perform checks at any time to ensure compliance with these procedures.

EnVent Capital Markets Limited

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EnVent Italia SIM S.p.A.

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0039 02 22175979

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