INTERNAL CODE OF CONDUCT

In order to ensure proper conduct of its administrative and supervisory bodies, its employees and co-workers, Eurizon Capital SA has adopted the Internal Code of Conduct that these persons - in particular those who are involved in management decisions – must observe in dealing with personal transactions, receiving gifts, accept assignments or power of attorney on behalf of customers and for managing relationship with media and/or other external entities.

The provisions of the Code of Conduct are specifically intended to prevent situation of conflicts of interest, misuse of sensitive or inside information and improper conduct towards the Supervisory Authorities and Public Administration.

STRATEGY FOR THE TRANSMISSION AND EXECUTION OF ORDERS

This Policy establishes the methodology set up in accordance with the UCITS Directive (Directive 2009/65/EC, as amended), the AIFM Directive (Directive 2011/61/EU) and the MiFID II Directive (Directive 2014/65/EU) and the related implementing measures at European and National level, as applicable to the respective products and services rendered by Eurizon Capital S.A. (hereinafter “Management Company”) to its clients, in order to achieve the best possible result when executing or transmitting orders on financial instruments.
The UCITS Directive and the corresponding implementing measures set out that a management company shall, at all times, by virtue of rules of conduct, act honestly and fairly in conducting its business activities in the best interests of the UCITS it manages and the integrity of the market. In addition to that duty, management companies need to ensure that all reasonable steps are taken to obtain the best possible result for the UCITS, taking into account price, costs, speed, likelihood of execution and settlement, order size and nature, or any other consideration relevant to the execution of the order, taking into account the objectives, investment policy and risks specific to the UCITS, the characteristics of the order, of the financial instruments and the execution venues to which that order can be directed. Similar provisions are contained in the AIFMD and the corresponding implementing measures with regard to alternative investment funds.

STRATEGY FOR THE EXERCISE OF RIGHTS ATTACHED TO THE FINANCIAL INSTRUMENTS OF THE MANAGED UCITS

Eurizon Capital S.A. has adopted and applies the following strategy for the participation and voting rights attached to the financial instruments held in the managed UCITS in order to ensure that these rights are exercised to the exclusive benefit of the UCITS’s investors.
The Company normally participates, on behalf of the managed portfolios, in the shareholders’ meetings of selected companies with shares listed in Borsa Italiana, according to the advantage that this participation would bring to the managed portfolios, as well as for the opportunity to affect decisions regarding the shares with voting rights held by the Company.

As for the reasons that drive the decision to exercise participation and voting rights, ECSA has identified the following quantitative and qualitative criteria:

- participation in all shareholders’ meetings and interaction with the Board of Directors of those companies where the Company holds a significant share capital, as from time to time identified by internal procedure

- participation in the shareholders’ meeting that are deemed relevant to the company's benefit in order to identify situations of particular interest for the purpose of protecting and supporting the interests of minority shareholders

- contribution to the election of members of the boards of statutory auditors or board members through the voting mechanism, representing minority shareholders

- participation in those shareholders’ meeting where extraordinary operations are decided upon if, as regards the interests of the managed portfolios, such participation is needed to support or tackle the proposed operation.

MANAGEMENT OF CONFLICTS OF INTEREST

Eurizon Capital S.A. has adopted a specific policy for the management of conflicts of interest in accordance with the conflict of interest management provisions of the MiFID (Directive 2014/65/EC), UCITS (Directive 2009/65/EC, as amended and integrated from time to time) and AIFM (Directive 2011/61/EU) directives and the related EU and national implementing legislation.

The Company has also adopted the "Protocol of Autonomy for the Management of Conflicts of Interest" proposed by Assogestioni (Industry Italian Association) with the aim of safeguarding decision-making autonomy process with regards the provision of management services.

REMUNERATION AND INCENTIVE POLICIES

Eurizon Capital S.A. has prepared its Remuneration and Incentive Policies on the basis of the remuneration policies of the Intesa Sanpaolo Group and, although not in conflict, not regulated or more restrictive, in compliance with European and national provisions governing the asset management industry. As a "significant" asset manager, Eurizon Capital S.A. is required to apply all restrictive requirements set out in the relevant regulations.

DISCLOSURE EURIZON ALTERNATIVE SICAV.SIF

As required by Directive 2011/61/EU of the European Parliament and of the Council on Alternative Investment Fund Managers ("AIFMD") and the Luxembourg implementing measures, the Luxembourg Law of 12 July 2013 on Alternative Investment Fund Managers (the "Law of 2013"), Eurizon Capital S.A. and the Fund provide to investors as required by law and must not be used for any investment decision.

ENGAGEMENT POLICY

In accordance with the provisions of article Art.1er sexies of Law of 1 August 2019 amending the amended Law of 24 May 2011 concerning the exercise of certain rights of shareholders at general meetings of listed companies for the purpose of transposing of Directive (EU) 2017/828 of the European Parliament and of the Council of 17 May 2017 amending Directive 2007/36/EC Eurizon Capital SA adopted an "Engagement Policy" describing how monitors the investee companies on relevant issues, including strategy, financial and non-financial results as well as risks, capital structure, social and environmental impact and corporate governance, dialogues with the investee companies, exercises voting and other rights related to the shares, communicates with the relevant stakeholders of the investee companies and manages current and potential conflicts of interest in relation to its commitment.

SUSTAINABILITY POLICY

In accordance with the provisions of Regulation (EU) 2019/2088 of 27 November 2019 on Sustainability Disclosure in the Financial Services Sector (Sustainable Finance Disclosure Regulation) Eurizon Capital SA adopted the "Sustainability Policy", describing the financial instrument selection and monitoring methodologies implemented by the Company in order to include the sustainability risk analysis as part of its investment process.
These methodologies provide for the application of specific selection processes of the financial instruments, suitably tiered according to the characteristics and objectives of the managed products, taking into account environmental, social and governance factors (“ESG factors”) and principles of Sustainable and Responsible Investment (“SRI”).