Pursuant to Art. 165 paragraph 1 letter h-bis of the Intermediaries Regulation, in the selection process of the financial instruments subject to the investment consultancy service, Federico Bellanti (hereinafter the "Consultant") integrates an assessment of environmental, social and governance sustainability factors, in order to ensure that the various products and instruments can be recommended only to customers who express preferences in terms of sustainability compatible with the characteristics of the instruments themselves.

Since the consultancy carried out by the Consultant concerns the financial portfolio as a whole, the assessment of sustainability factors is carried out at portfolio level. This means that, as a whole, the portfolio must be aligned with the client's sustainability preferences, although it is possible that, for reasons of risk management or achievement of the client's objectives, some individual instruments used are not individually aligned with the client's preferences.

The assessment of environmental, social and governance sustainability characteristics is carried out, depending on the type of instrument/product according to the information declared by the issuer pursuant to current regulations or using external assessment models (rating) and/or analyses carried out internally.