Starting from 2022, Primo Capital has adopted an ESG Policy aimed at including the analysis and monitoring of social, environmental and governance risks and opportunities in the investment process, both at the firm and portfolio levels.
In 2024 Primo Capital became a signatory of the United Nations’ Principle for Responsible Investment, strengthening its commitment to sustainability practices.
The company publishes each year a ESG Report which includes its activities and results in terms of commitment towards social, environmental and governance objectives.

Governance
Primo Capital has identified an ESG Leader who verifies compliance with ESG principles on all levels, coordinates the investment team on the monitoring of the ESG performance of portfolio companies and reports directly to the firm’s Board of Directors. Portfolio companies are expected to appoint a manager, responsible for the implementation of ESG objectives.
Investment
The firm adopts an ESG approach in all steps of the investment process, from the screening to the exit processes. Starting from the analysis of investment opportunities, the investment team had adopted a customized due diligence to evaluate companies’ ESG risks and opportunities. When finalizing an investment, the investment team evaluates with the prospect portfolio company the possibility of activating initiatives to remove any negative factors identified in the due diligence process.
Monitoring
Portfolio companies’ ESG performance is monitored through the identification and periodic tracking of specific KPIs, defined by the investment team and designed for each company on the basis of their business profile and the applicability of related ESG risks and opportunities. The investment team's activities also include monitoring the resolution of any deficiencies that emerged in the due diligence phase and the assessment of the overall ESG performance of the targets in the exit phase.
The complete policy can be consulted upon request via the contacts page of our website or in the area reserved for subscribers.
Transparency of policies on sustainability risk
The firm, through the preliminary investigations and in accordance with its internal policies and the provisions of the management regulations of the managed AIF, selects the investments on the basis of the successful outcome of the due diligence activities which include rules for the exclusion of business sectors which, on the basis of best market practices, may present significant problems in relation to sustainability factors.
No consideration of adverse impacts on investment decisions on sustainability factors
As of today, the firm is unable to carry out an exhaustive assessment of all the negative impacts of investment decisions on sustainability factors, according to art. 4, paragraph 1, of the SFDR Regulation, in consideration of the following: (i) regulatory framework and best practices subject to further evolution and implementation; and (ii) incomplete availability of data, with regard to the specific topic of sustainability, relating to the assets in the portfolio of the AIFs currently managed, necessary for the assessments both during the investment phase and for the consequent reporting, also considering the characteristics of the underlying portfolio.