ESG CHECKLIST

BACKGROUNDWhy? This checklist is to be used to screen for high-level ESG risks in order to scope the ESG Due Diligence When? Scree
" •" " Industry/sectors" " " " " " " " " "" " " " " " " "" • " " 231 Model;" " " " " " " " " " " " " " " " " " " "
- - - - - - - - - - - - - - - - - - - - - - - - - - -›
• ESGPolicy; i
• Type of operations • Sustainability/Non Financial Disclosures E
• Exclusion list check • Sustainability section on the website n
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Hazardous
substances

Packaging
 Compliance
environmental
regulation
Natural hazards
Green products

Biodiversity
Air emissions

Soil &
Groundwater
 Energy
&water

Waste/end of life
Climate change
H&S
Fair disclosure and
labelling

Innovation
ESG CHECKLIST - BUSINESS OVERVIEW
 Topic
Company name
Industry/ Business sector
Type of operations associated with the business e.g. office,
manufacturing/production, warehousing, logistics etc.
Exclusion list check - as per applicable Fund 3:
Rules & Regulations: Please confirm that the Company does not derive its revenues from pornography
and prostitution, production, sale or distribution of weapons of mass destruction, artillery and
antipersonnel landmines, illegal drugs, polychlorinated biphenyl and asbestos
Side Letters: Please confirm that the Company does not derive its revenues from
tobacco, palm oil, nuclear power, coal-fired power plants

231 Model
A. Has the company implemented an Organization Model 231?
B. Does the model cover environmental and social aspects?
Sustainability /Non Financial Disclosure Report
A. Does the Company prepare a Sustainability (or Non Financial Information) Report? Please note that
in such Reports it is possible to find some information that may be used in the compilation of tabs
"Environment", "Social" and "Governance".

B. Is the Company subject to the Legislative Decree no. 254 regarding non financial
disclosures (click here for more information on the scope of the Legislative Decree)?
ESG Policy, Environmental Policy, Health&Safety Policy, Social Policy
Does the Company have policies that cover ESG aspects (ESG Policy, Environmental
Policy, Health&Safety Policy, Social Policy)?
Sustainability section on the website
Does the Company publish sustainability information on its website?
Information
ESG CHECKLIST - ENVIRONMENT
 ASSESSMENT

ID Topic Relevance to the Target

E.1 Regulatory compliance

E.2 Natural hazards

E.3 Carbon emissions/ Climate change

E.4 Air emissions

E.5 Energy and water management

E.6 Chemicals/hazardous substances handling & supply

chain

E.7 Waste management/ end of life of products

E.8 Soil&groundwater

E.9 Biodiversity impact

E.10 Green products
E.11 Packaging
Level of Maturity of the target
Company
 GUIDANCE
Aspects that can be considered when assessing the relevance of the topic (reported on the left) to the target and t

ID

E.1

E.2

E.3

E.4

E.5

E.6

E.7

E.8

E.9
E.10
E.11
 GUIDANCE
Aspects that can be considered when assessing the relevance of the topic (reported on the left) to the target and the level o

Description/ questions for guidance

A. Serious incidents/regulatory breaches regarding environmental aspects. Nature of the incident, improvements
made/lessons learnt and regulatory action (enforcement/prosecution/fine).

Is the Company subject to flood, seismic or other natural hazards?

Carbon emissions
A. Does the Company operate in an energy intensive sector? Does the Company monitor GHG emissions (inclusive of non directly
generated e.g. outsourced logistics, use of final product etc)? Is the production (in particular the carbon intensive activities) mainly
outsourced? Is the company subject to a cap and trade scheme (EU ETS)?
B. Plans or actions to control and/or reduce emissions.
Exposure to climate changes
Could operations be at risk from current/evolving climate change regulation and/or physical changes associated with climate change
(including increased flooding, drought or other severe weather events), for example: business disruption or damage to assets and
production?

Can the Company operations originate significant emissions to air (e.g. oil&gas, energy, transportation, chemical)?

A. Are the Company operations energy or water intensive?

B. Are there any plans in place to reduce energy consumption, increase percentage of renewable energy in the Company's energy mix?
C. Do the products offered have energy labelling/certifications?

A. Are chemicals/hazardous substances used in the production process?

B. Is management aware of any potential disruption to the supply of chemical/hazardous substances used in the production process
through regulatory phase-out (e.g. REACH regulation)?
C. Is the company considering the use of more environmental friendly and safer raw materials/chemicals in the
production process?

A. Does the production process originate relevant quantities of waste or hazardous waste?
B. Waste management initiatives to minimise or reuse/recycle waste.
C. Are products offered designed in order to reduce their end-of-life footprint?

A. Is there a risk of soil contamination resulting from the activities of the target company?
B. Is the company aware of any former or current soil/groundwater contamination issues at the site(s) and is there a need to conduct
investigation or remediation activities?
C. Has the company recognised any financial provision in the accounts to address any environmental liability such as
contaminated land/environmental restoration?

Has the production process an impact on biodiversity (including deforestation and land degradation)?
Does the Company offer "green" or "low impact "product lines?
A. Do the products offered by the Company require a relevant amount of packaging (eg. Fragile goods)?
B. Are sustainability criteria considered in the design of packaging?
get and the level of maturity.

Note
ESG CHECKLIST - SOCIAL
 ASSESSMENT

ID Topic Relevance to the Target

S.1 Human resources

Workers

S.2 Health and safety

Community

S.3 Community involvement

S.4 Consumer safety /product regulations

S.5 Customer privacy

Customers and products

S.6 Fair disclosure and labelling/Fair marketing

S.7 Innovation
Level of Maturity of the target
Company
 GUIDANCE
Aspects that can be considered when assessing the relevance of the topic (reported on the left) to the target and the

ID

S.1

S.2

S.3

S.4

S.5

S.6

S.7
 GUIDANCE
Aspects that can be considered when assessing the relevance of the topic (reported on the left) to the target and the level of m

Description/ questions for guidance

A. Workforce composition (employees, self-employed, trainee, seasonal workers)

B. Do all employees have a formal contract of employment?
C. Turnover rates and talent retention
D. Diversity issues (e.g. diversity on boards, pay gap)
E. Serious labour related complaints/claims/enforcement actions
F. Freedom of association and collective bargaining
G. Training
H. Benefits provided to employees

A. Is the Company operating in an industry that presents a high risk for health and safety? Are workers exposed to high incidence or high risk of diseases related to
their occupation?
B. Has the company been subject to enforcement actions by the regulators for breaches of relevant H&S legislation?
C. Is the Company classified as a major risk facility? (ie under Seveso Directive)

A. Community investments, sponsorships, product donations

B. Formal programmes in place to promote company involvement with the community (volunteering, stakeholder engagement, etc.).
C. Previous NGO/media negative campaigns, community/workforce unrest

A. Product or sector specific regulations (e.g. food safety, pharma GMP, other)
B. Actions taken to ensure the health and safety of consumers
A. Company's data security policy and IT security management system
B. Sensitivity of information in possess of the Company
C. Breaches in cyber security within the last years
D. Substantiated complaints regarding breaches of customer privacy and losses of customer data

A. Requirements for product and service information and labelling

B. Incidents of non-compliance concerning product and service information and labelling
C. Incidents of non-compliance concerning marketing communications

R&D investment plans, patents, innovative products and/or services

he level of maturity.

Note
ESG CHECKLIST - GOVERNANCE
 ASSESSMENT

ID Topic Relevance to the Target Level of Maturity of the target

G.1 ESG systems and processes

G.2 Corruption and business ethics

G.3 Supply chain

 GUIDANCE
Aspects that can be considered when assessing the relevance of the topic (reported on the left) to the target and the

ID

G.1

G.2

G.3
 GUIDANCE
Aspects that can be considered when assessing the relevance of the topic (reported on the left) to the target and the level of m

Description/ questions for guidance

Roles and responsibilities

A. Has an ESG committee/steering committee been established?
B. Commitment and responsibilities at a senior management level on sustainability.
C. Has a designated reference person for day-to-day ESG matters been assigned?

Policies & Procedures

A. Are ESG Values and principles clearly communicated (e.g.. on the website)?
B. Does the Company have Sustainability or Business Conduct policies? Do polices cover discrimination, and child, forced or compulsory labour, health and safety a
environmental issues?
C. Are there environmental/health and safety procedures or management systems in place?
D. What is the level of establishment and embedment of procedures?

Monitoring & Reporting

A. What are the arrangements in place for monitoring and reporting ESG issues and performance to senior management/the Board?
B. Does the Company publish an ESG/CSR/Sustainability report or a designated section in the annual accounts?
C. Is there a Sustainability section on the website?

A. What does the organisation currently do to safeguard against illegal practices? Any corporate governance and/or ethical related employee claims/breaches/
enforcement/litigation action relating to issues such as anti-bribery and corruption, cases of unfair labour practices, human rights abuses, and other unethical busin
practices?
B. Does the Company make financial or in-kind political contributions?
C. Does the Company participate in public policy development or lobbying activities?
D. Are there any anti-trust issues?

A. Are key suppliers located in emerging markets with high social, human labour, environmental risks?
B. Is the supply chain part of an industry with high social, human labour, environmental risks?
C. Does the company have a responsible purchasing policy/Code of Conduct for suppliers? Are ESG criteria included in the selection and monitoring of key supplier
e level of maturity.

Note
ESG CHECKLIST - ENVIRONMENT
 ASSESSMENT

ID Topic Relevance to the Target

E.1 Regulatory compliance

E.2 Natural hazards

E.3 Carbon emissions/ Climate change

E.4 Air emissions

E.5 Energy and water management

E.6 Chemicals/hazardous substances handling & supply

chain

E.7 Waste management/ end of life of products

E.8 Soil&groundwater

E.9 Biodiversity impact

E.10 Green products
E.11 Packaging
Level of Maturity of the target
Company
 GUIDANCE
Aspects that can be considered when assessing the relevance of the topic (reported on the left) to the target and t

ID

E.1

E.2

E.3

E.4

E.5

E.6

E.7

E.8

E.9
E.10
E.11
 GUIDANCE
Aspects that can be considered when assessing the relevance of the topic (reported on the left) to the target and the level o

Description/ questions for guidance

A. Serious incidents/regulatory breaches regarding environmental aspects. Nature of the incident, improvements
made/lessons learnt and regulatory action (enforcement/prosecution/fine).

Is the Company subject to flood, seismic or other natural hazards?

Carbon emissions
A. Does the Company operate in an energy intensive sector? Does the Company monitor GHG emissions (inclusive of non directly
generated e.g. outsourced logistics, use of final product etc)? Is the production (in particular the carbon intensive activities) mainly
outsourced? Is the company subject to a cap and trade scheme (EU ETS)?
B. Plans or actions to control and/or reduce emissions.
Exposure to climate changes
Could operations be at risk from current/evolving climate change regulation and/or physical changes associated with climate change
(including increased flooding, drought or other severe weather events), for example: business disruption or damage to assets and
production?

Can the Company operations originate significant emissions to air (e.g. oil&gas, energy, transportation, chemical)?

A. Are the Company operations energy or water intensive?

B. Are there any plans in place to reduce energy consumption, increase percentage of renewable energy in the Company's energy mix?
C. Do the products offered have energy labelling/certifications?

A. Are chemicals/hazardous substances used in the production process?

B. Is management aware of any potential disruption to the supply of chemical/hazardous substances used in the production process
through regulatory phase-out (e.g. REACH regulation)?
C. Is the company considering the use of more environmental friendly and safer raw materials/chemicals in the
production process?

A. Does the production process originate relevant quantities of waste or hazardous waste?
B. Waste management initiatives to minimise or reuse/recycle waste.
C. Are products offered designed in order to reduce their end-of-life footprint?

A. Is there a risk of soil contamination resulting from the activities of the target company?
B. Is the company aware of any former or current soil/groundwater contamination issues at the site(s) and is there a need to conduct
investigation or remediation activities?
C. Has the company recognised any financial provision in the accounts to address any environmental liability such as
contaminated land/environmental restoration?

Has the production process an impact on biodiversity (including deforestation and land degradation)?
Does the Company offer "green" or "low impact "product lines?
A. Do the products offered by the Company require a relevant amount of packaging (eg. Fragile goods)?
B. Are sustainability criteria considered in the design of packaging?
get and the level of maturity.

Note
ESG CHECKLIST - SOCIAL
 ASSESSMENT

ID Topic Relevance to the Target

S.1 Human resources

Workers

S.2 Health and safety

Community

S.3 Community involvement

S.4 Consumer safety /product regulations

S.5 Customer privacy

Customers and products

S.6 Fair disclosure and labelling/Fair marketing

S.7 Innovation
Level of Maturity of the target
Company
 GUIDANCE
Aspects that can be considered when assessing the relevance of the topic (reported on the left) to the target and the

ID

S.1

S.2

S.3

S.4

S.5

S.6

S.7
 GUIDANCE
Aspects that can be considered when assessing the relevance of the topic (reported on the left) to the target and the level of m

Description/ questions for guidance

A. Workforce composition (employees, self-employed, trainee, seasonal workers)

B. Do all employees have a formal contract of employment?
C. Turnover rates and talent retention
D. Diversity issues (e.g. diversity on boards, pay gap)
E. Serious labour related complaints/claims/enforcement actions
F. Freedom of association and collective bargaining
G. Training
H. Benefits provided to employees

A. Is the Company operating in an industry that presents a high risk for health and safety? Are workers exposed to high incidence or high risk of diseases related to
their occupation?
B. Has the company been subject to enforcement actions by the regulators for breaches of relevant H&S legislation?
C. Is the Company classified as a major risk facility? (ie under Seveso Directive)

A. Community investments, sponsorships, product donations

B. Formal programmes in place to promote company involvement with the community (volunteering, stakeholder engagement, etc.).
C. Previous NGO/media negative campaigns, community/workforce unrest

A. Product or sector specific regulations (e.g. food safety, pharma GMP, other)
B. Actions taken to ensure the health and safety of consumers
A. Company's data security policy and IT security management system
B. Sensitivity of information in possess of the Company
C. Breaches in cyber security within the last years
D. Substantiated complaints regarding breaches of customer privacy and losses of customer data

A. Requirements for product and service information and labelling

B. Incidents of non-compliance concerning product and service information and labelling
C. Incidents of non-compliance concerning marketing communications

R&D investment plans, patents, innovative products and/or services

he level of maturity.

Note
ESG CHECKLIST - GOVERNANCE
 ASSESSMENT

ID Topic Relevance to the Target Level of Maturity of the target

G.1 ESG systems and processes

G.2 Corruption and business ethics

G.3 Supply chain

 GUIDANCE
Aspects that can be considered when assessing the relevance of the topic (reported on the left) to the target and the

ID

G.1

G.2

G.3
 GUIDANCE
Aspects that can be considered when assessing the relevance of the topic (reported on the left) to the target and the level of m

Description/ questions for guidance

Roles and responsibilities

A. Has an ESG committee/steering committee been established?
B. Commitment and responsibilities at a senior management level on sustainability.
C. Has a designated reference person for day-to-day ESG matters been assigned?

Policies & Procedures

A. Are ESG Values and principles clearly communicated (e.g.. on the website)?
B. Does the Company have Sustainability or Business Conduct policies? Do polices cover discrimination, and child, forced or compulsory labour, health and safety a
environmental issues?
C. Are there environmental/health and safety procedures or management systems in place?
D. What is the level of establishment and embedment of procedures?

Monitoring & Reporting

A. What are the arrangements in place for monitoring and reporting ESG issues and performance to senior management/the Board?
B. Does the Company publish an ESG/CSR/Sustainability report or a designated section in the annual accounts?
C. Is there a Sustainability section on the website?

A. What does the organisation currently do to safeguard against illegal practices? Any corporate governance and/or ethical related employee claims/breaches/
enforcement/litigation action relating to issues such as anti-bribery and corruption, cases of unfair labour practices, human rights abuses, and other unethical busin
practices?
B. Does the Company make financial or in-kind political contributions?
C. Does the Company participate in public policy development or lobbying activities?
D. Are there any anti-trust issues?

A. Are key suppliers located in emerging markets with high social, human labour, environmental risks?
B. Is the supply chain part of an industry with high social, human labour, environmental risks?
C. Does the company have a responsible purchasing policy/Code of Conduct for suppliers? Are ESG criteria included in the selection and monitoring of key supplier
e level of maturity.

Note