The Social Business Initiative: Promoting Social Investment Funds. Response to consultation
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European Commission _ Staff working paper on "The Social Business Initiative: Promoting Social Investment Funds" _ Avanzi response to consultation

European Commission _ Staff working paper on "The Social Business Initiative: Promoting Social Investment Funds" _ Avanzi response to consultation

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The Social Business Initiative: Promoting Social Investment Funds. Response to consultation Document Transcript

  • 1. European Commission – Staffpaper on “T he Soci al BusinessIniti ati ve: Promoting Soci alInvestment Fund”Response to consul tati on thMilano, September 13 , 2011Davide Dal Maso (dalmaso@avanzi.org) and Davide Zanoni (zanoni@avanzi.org)+39 02 305160SummaryWho is Avanzi and why we are involved into the topic .....................................................................2 Support to social business...............................................................................................................2 Change the financial industry ..........................................................................................................3Comments on paper ............................................................................................................................4 Defining social business ..................................................................................................................4 The funding challenge .....................................................................................................................5 The role of investment fund .............................................................................................................6 The role of investors ........................................................................................................................7 Liquidity .............................................................................................................................................8 Risk diversification ...........................................................................................................................8 Types of asset and strategies .........................................................................................................8 Asset valuation .................................................................................................................................9 Financial assessment...................................................................................................................9 Social assessment and reporting ................................................................................................9 Investor participation..................................................................................................................... 10 Risk management ......................................................................................................................... 10 Depositary...................................................................................................................................... 10 Remuneration and cost structure................................................................................................. 10 Improving transparency and clarity .............................................................................................. 11 Improving transparency through common criteria ...................................................................... 11 A common EU label? .................................................................................................................... 12 Ensuring effective integration with social businesses and distributors ..................................... 12 Use of incentives, including tax.................................................................................................... 12
  • 2. Who is Avanzi and why we are involved into thetopicAvanzi. Sustainability In Action is a leading and independent Think-and-do tank forsustainable innovation. Since its founding in 1997, its mission has been to become anindependent and credible player in the field of sustainable development. Applied research and pilot projects carried out by Avanzi have shown an innovativeapproach in terms of both policy implications and actors involved. By collaborating with themost qualified universities and research centres in Europe, it has assured an independent andrigorous approach in both innovation drivers investigation and policies development. Avanzi has played a pioneering role in promoting and disseminating sustainabledevelopment and has contributed to a radical perspective change in many public and privateorganisations in Italy. Avanzi has conducted research and provided innovative services andbusiness activities, mainly in the field of Socially Responsible Investment (SRI) and Ethicalfinance, Corporate Social Responsibility (CSR) and Local Agenda 21. Bridging academia, business and the public sector, Avanzi represents a quite uniquecontext in Italy: the investigation on innovative approaches, policies and instruments isfollowed by their effective implementation and broad dissemination through pilot projects andstart-ups incubation with high social and environmental impact potential. By closely workingwith the public, private and no profit sectors, it engages with stakeholders and challengesreputational risks and business opportunities.Support to social businessAvanzi assists enterprises and other organisations in acknowledging their responsibilitiestowards stakeholders and in managing the change. The approach is modular and customisedand aims to integrate social, environmental and ethical concerns into all business activitiesand levels, from strategy to operational management. Avanzi is also a social businessincubator. We provide a full range of business support resources and services to selectedstart ups with high potential to impact social needs or challenge environmental issues. Avanziwelcomes innovative entrepreneurs with high potential for creating social and green value andprovides comprehensive business support services, including back-office, governanceexpertise, access to knowledge and financing. Avanzi applies a “stage-gate” roadmap forincubation. First ideas and ventures based on their overall quality, degree of eco and socialinnovation and consistency with market and environment conditions are selected. Then themotivation of future entrepreneurs, their capabilities and relationship network are assessed.Building or revising the business plan to assess financial and operational viability is the nextstep in the process. Finally, the Avanzi team works closely with the entrepreneur on the keychallenges to make the start up successful. Avanzi is based in Milan, into a place designed toinspire and realize new ideas. Located in a restored historical factory, it was once the home ofthe Italian-made cult design and technology brand Brionvega, It already hosts a community ofqualified professionals and innovative start ups. The incubator is an activity carried out incooperation with Make a Change, an association promoting a cultural change which putscapital and profit at the service of social good. MaC supports the development of new socialbusiness generating benefits for everyone within the traditional capitalist marketplace anddoes so using marketing levers in order to allow this new mentality to visibly spread andassert itself.Avanzi. Sostenibilità Per Azioni 2
  • 3. www.makeachange.itChange the financial industryAvanzi was the promoter, in 2001, of Forum per la Finanza Sostenibile, the Italian socialinvestment forum, member of Eurosif.www.finanzasostenibile.itAvanzi is developing a project in cooperation with a number of other organisations in Italyaiming at the launch of a Social Stock Exchange (in Italian, Borsa Sociale), that is a capitalmarket dedicated to business with a social mission. With this definition, Avanzi refers toorganisations that purposefully pursue a social value.Under Italian regulatory framework, there is a clear and rigid distinction between for profit andnon for profit entities: on the one side, companies (limited or unlimited liability) can runcommercial activities; on the other, associations or foundations (with members but withoutshareholders, i.e. without a capital that can be divided into share) can do any activity exceptcommercial. The idea behind this scheme is that the State has the quasi-monopoly in thedomain of social affairs, addressed through the redistribution of wealth collected via taxation.Private (non for profit) organisations can at most cooperate with the State, but act under itsvigilance or on its mandate. At the level of Constitution, the recent modification of article 118introduced the concept of “horizontal subsidiarity”, which encourages private entities(individuals and other organisations) to create public goods.In order to overwhelm this distinction, we launched the proposal of a hybrid subject, namedSocial Purposes Businesses (SPBs) (in Italian, Imprese a Finalità Sociale): legally speaking,they are companies, with capital and shareholders, but their mission is not profit maximisationbut rather creation of social added value. SPBs offer a blended dividend, made up of a[limited] economic return, plus a social-environmental return.In Italy as well as in all industrialised countries, there is a large and growing demand of goodsand services with a high social and environmental value. This broad area ranges from healthto assistance, from education to cultural activities, from local public services to responsiblefinancial services, from fair trade to eco-tourism, from organic food to eco-fashion, from greenconstruction to renewables, with technologies linking all of them.What distinguishes these activities is the fact that, besides the environmental and social care,they imply some kind of relational goods – and when relationship plays a role, the nature andthe credibility of the subjects are crucial. The traditional for profit companies, although“responsible”, suffer a lack of credibility, because people know or feel that their final goal isprofit and other conditions are constraints that they have to consider. The conflict between theinterests of shareholders and those of other stakeholders is immanent. Instead, for SPBs it’sthe other way round: stakeholders’ value is the goal, profit is the constraint that has to betaken into account in order to assure long term continuity.A detailed methodology to measure social value creation has been developed and will bevalidated with pilot projects. Social assessment will be run at initial listing and repeated over Avanzi. Sostenibilità Per Azioni 3
  • 4. time. A social nominated advisor or sponsor will be in charge to provide the assurance vis-à-vis the market and the investors.SSE is therefore an instrument to enhance these enterprises, by matching their demand ofcapital with the supply of patient, responsible investors. It does not compete with existingexchanges, because it is addressed to companies that will never list into traditional markets.The capital supply side is represented by both institutional and retail investors. The appetitefor responsible investment is growing across Europe: more and more people feel that theymight invest part of their assets into a new asset class that, although likely to provide asmaller financial return, can generates social benefits for the communities and, indirectly,themselves.SSE will be established as a multilateral trading facility (MTF), regulated by the MIFIDDirective and subject to the vigilance of the financial market Authority (Consob). Theinvestment company that will manage it will be backed up by a promotion company (Pro-Borsa Sociale), whose mission is to attract both emitters and investors towards the market.The shareholding structure and composition of Pro-Borsa Sociale will guarantee therepresentation of all interested groups and a balanced governance system will be designed inorder to preserve the social mission of the initiative. Rough estimations indicates some 60-80companies eligible for listing by the first 3-4 years.www.borsasociale.itComments on paperPlease find hereby our responses:Defining social businessDo you agree that the main features of social businesses are as outlined above?We agree with the proposed definition, but we think that the prohibition to distribute profit canbe a limit. As long as these entities are businesses, e.g. organisations that use capitals toproduce products and services, they should play with the same fundamental rules that“traditional” companies are subject to. We believe that social business should grow into themarket – not in a side playground. Therefore, risk capital should be rewarded. Otherwise, noinvestor will ever be willing to put its money into them. Social businesses typically don’tdistribute dividends in the early stage of their development, in order to reinforce their assetsby reinvesting the margins; but there is no reason why they should continue to do so overtime, once that the financial stability is reached.The Italian law-decree 155/2006 has created the “social enterprise”. It’s a new category thatcan be added to the typical legal structure of both non-profit and for-profit companies. Withoutgoing into the detail of this measure, it’s clear that its failure (few hundreds entities asked tobe registered as social enterprises) it’s also due to the fact that the prohibition of dividendsdistribution has been perceived as a barrier by investors.That’s the reason why we consider more appropriate a cap to ROI (return on investment)which includes dividends and capital gain limitation. This could prevent that assetsAvanzi. Sostenibilità Per Azioni 4
  • 5. accumulation due to profit limitations translates into a capital gain when stocks are sold to themarket.To what extent do you think this initiative should focus solely on those social businesses thatdo not distribute profits to their investors? Or shall it also focus on those which distributeprofits to their investors (e.g. at least to a limited extent)? If so, how might social businessesbe distinguished from other businesses?We think that the rationale of pure non-profit organisations is different from social business.Social businesses are less likely to generate massive capital gains because the logic behindtheir model prevents them to do so. Social business is low profit by definition, since theprocess of value creation implies equal treatment of all stakeholders: if workforce andsuppliers are managed fairly, clients pay an honest price, environment and communities arerespected, one can hardly produce huge margins. Typically, high profits appear when thereare strong economies of scale (which is seldom the case for social businesses) or one ormore of the stakeholders are exploited.But being low profitable does not necessarily mean that risk shouldn’t be rewarded. To acertain extent, dividend should be distributed. We are not, in principle, neither favourable norcontrary to a definite cap; we think that capping the distribution might be a good solution insome circumstances – but the decision should be left to the partners or the shareholders on acase by case approach.We think that a social business should be distinguished form other business on the ground ofits outputs. No doubt that it has to clearly state into the Statute that the mission of theorganisation is the creation of social and environmental value – but this can be not enough.The extent to which this goal is achieved has to be measured and communicated. We thinkthat accountability is key in this respect and we encourage the highest possible level oftransparency. In other words, the “sociality” has to be promised and, more importantly, to beproven.The funding challengeWhat are the main difficulties social businesses face, in your experience, in getting access tofinance?Social businesses operate in a typical area of market failure: they are not enough profitable toattract venture capitalists and private equity investors – but they are not eligible for grants.Social business need a specific type of capital providers, e.g. responsible investors that arehappy with a blended divided, made of a social as well as an economic return (the latter beinginevitably lower than a “normal” one).Traditional capital suppliers are not comfortable with most social business because (i) theyoperate in the area of innovation – and therefore are more risky by definition; (ii) they aremore often too small to cover the cost of assessment and due diligence; (iii) their governanceis often driven by values rather than economic interests.Do different kinds of social businesses face different barriers?The features that make a social business more attractive to investors are: • Size • Profitability • Maturity of the market • Credibility of the entrepreneursAvanzi. Sostenibilità Per Azioni 5
  • 6. To what extent do you think barriers to access to finance are limiting the growth of socialbusinesses across the EU?We feel that indeed finance is the most critical aspect for a social business.Do you agree that there is a need to tackle any such barriers at the EU level?Yes. In particular, we think that EU can intervene to regulate the fiscal system. The paradoxthat has to be handled is that social businesses are subject to the same tax regime of sociallyirresponsible industries. The taxation system is focused on the legal nature of a given entityrather than on its output. One can produce a huge amount of social benefit, but if it does sousing a limited liability company as a vehicle, it pays as it were a tobacco maker.Even more important to promote social investment funds could be a specific tax regime forinvestors and financial operators that support social ventures. If we accept the idea of taxexemption for grants, we can imagine different levels of exemption for investments to non-profit and social business.The role of investment fundIf you operate a social investment fund, or are aware of the (national) legislative requirementsthat apply currently in practice, could you please provide broad detail on these requirements.No comment.How do you think funding through investment funds might effectively compliment othersources of funding, e.g. philanthropic funding? Are there any challenges here?We think that investment funds can play an important role because they can minimise theinformation asymmetry. The problem of social businesses is that they don’t speak the samelanguage of [traditional] investors; and these are not eager to invest time to know more andeventually understand a model that is miles away from their standard. The market would needspecialised players, who know their counterparts, the context in which they operate, their logicand their approach. In order to became a specialist, one need to reach the critical mass thatallows the investment needed for knowledge – which is in fact the case of a fund.On the other hand, we think that funds shouldn’t be the only or preferred instrument to supplycapital to social businesses. In fact, different instruments can solve specific financial needsalong with the development stage of the company. The problem is therefore broader: acomplete chain has to be designed and supported. In other words, the market needs a sort of“parallel” system, where specialised players do the same job of traditional investors, but with aspecific sensitivity and knowledge of a different object. Business idea Start up Early stage Development Scale up Seed capital Venture capital Private equity Public listingDo you think that the UCITS framework is sufficient for funding social business withoutchange?Yes, we think that UCITS framework does guarantee the basic rules to regulate also thissegment of the investment market.Do you think a bespoke fund framework tailored to the needs of social business might bebetter suited to channel funds toward social businesses?We think that, as long as it’s proven that social businesses do produce a measurable benefitfor the community, they should be favoured through a dedicated system, for instance on taxlevel. Nevertheless, specific measures might be introduced within the existing UCITSAvanzi. Sostenibilità Per Azioni 6
  • 7. framework, especially if accompanied with a dedicated discipline for other instruments thatcan complete the range of financial services needed by social businesses – without the needto create a bespoke one.Of course, the definition must be stated very clearly in order to prevent any abuse.The role of investorsDo you believe that social investment funds should be open to retail investors?We think that the role of retail investors is of the utmost importance. Social businesses are nota different way to get the same result; they represent an innovation of the economic pattern;they are, in fact, a cultural rather than an organisational change in the way capital can beused. In that respect, the participation of private investors means much more that a marketingopportunity; it’s a political act.Besides, institutional investors are often limited in their strategic allocation by limits in terms ofweight of each asset class and are very risk adverse.Moreover, in some European countries (for instance, Italy), where the institutional segment isunderdeveloped, the access of retail investors is in fact the only way to address significantflows of money towards social businesses. To limit the costs for retail protections, we canimagine different stages in the social business development and accordingly defineappropriate investment vehicles (or specific segments): at the preliminary stages, the risk istoo high for private investors, but as the business grow up, retailers may go into the market.This principle is related to the concepts of primary and secondary market. In our BorsaSociale project indeed, the primary market is reserved to institutional investors, but thesecondary one is open also to private investors.What features of a social investment fund do you think are most important forretail/professional investors?As stated before, the most important feature of a social investment fund, not only for privatebut also for professional investors, is the accountability and transparency related to social andenvironmental impacts. As the social business has to prove and measure its social output, thefund should measure its performance not only in terms of financial return and communicatesits overall social impact. For instance, the return on investment should be transformed insocial return on investment, and the price of shares of the fund defined according to differentmetrics.What specific pre-contractual information do you think would need to be provided to retailinvestors?Since the definition of social business is very broad – or it can be interpreted in many differentways, it is extremely important that the fund clearly states its value proposition, i.e. the type ofsocial value it is going to pursue. In order to avoid any ambiguity and risk ofmisunderstanding, social businesses (and in consequence the funds willing to invest intothem) should clearly state which social benefit they are going to deliver and how. Pre-contractual information should therefore be focused on indicators of social performance thatare set as objectives of the business.Should the framework encompass funds that explicitly forego greater financial returns for thebenefit of the social risks, or both?No commentAvanzi. Sostenibilità Per Azioni 7
  • 8. LiquidityWhat do you think would be the appropriate time frame for redemption of units in a socialinvestment fund, e.g. monthly?Liquidity is a critical issue. It is difficult to balance the conflicting interests of investors andcompanies. The appropriate time frame largely depends on the nature of the business and thestage of maturity. For investment in early stage, the period should be longer and the companyshould be sheltered with lock in obligations. For more consolidated business, a monthlyredemption could be acceptable.Do you think there are other options for balancing the liquidity that small retail clients might beseeking with a focus on a long-term time horizon?No commentRisk diversificationDo you think that social investment funds should be subject to diversification rules?We think that a social investment fund should invest exclusively or predominantly in socialbusinesses. A mixture of different asset classes would eventually jeopardise the credibility ofthe value proposition. Diversification could be achieved by investing in different types of socialbusinesses. At most, a portion of the asset could be invested in risk-free securities (monetaryor AAA government bonds), just to cover the liquidity risk.To what extent do you think investors might expect a fund focused on social businesses toonly invest in social businesses?See above.Should social investment funds be required to invest into different types or numbers of socialbusiness? (How many separate businesses might be required?).No, as long as the risk profile of the product is clear to the investor.Should there also be diversification across asset classes different from social business?See above.Types of asset and strategiesWhat types of assets should a social investment fund be able to invest in? Please giveexamples.We think that the primary need for social businesses is long term risk capital, e.g. equity.Subordinately, debt (bonds) or quasi-equity securities.Should the funds be limited to certain kinds of strategies (for instance, aimed at maximisingtheir attractiveness for retail investors)? If so, which?No. We think that in an ideal situation, there should be as many social investment funds aspossible, competing with each other on the ground of the attractiveness of their offer – e.g.risk profile, value proposition, cost …Avanzi. Sostenibilità Per Azioni 8
  • 9. What rules or limits might be necessary to prevent firms using a new framework to circumventrestrictions in other frameworks (e.g. UCITS)?We think that the only way to prevent abuses is the robustness of the definition of socialbusiness and, even more important, the disclosure standard for continual reporting of thesocial results – along with the financial result.Asset valuationFinancial assessmentDo you agree that it would be impractical for social investment funds to have frequentvaluations of assets? Please give reasons for your answer.The delivery of economic value is not the primary objective of social businesses; inconsequence, social investment funds (and their clients) shouldn’t be obsessed by financialreturn. In other words, financial performance and other financial indicators shouldn’t beconsidered the most important pieces of information addressed to the clients. At the sametime, social investors have a long-term perspective and they are probably not so interested ina daily or weekly valuation of their assets.If so, for the purposes of investor protection what frequency might be appropriate?We believe that a monthly or quarterly evaluation of asset could be acceptable to a sociallyresponsible investor.Do you think that any non-social business assets that might be permitted should be subject todifferent valuation requirements? Might different kinds of assets require different approaches?As stated above, we dislike the mixture of different assets in a social investment fund portfolio– with the exception of “socially neutral” securities, whose evaluation should follow traditionalrequirements.Social assessment and reportingHow do you think social returns might be best addressed and measured?Avanzi, within the Borsa Social feasibility project, has developed its own methodology for themeasurement of social return. This is a very complex issue, that can hardly be simplified.However, key points are: • Outputs are more important than statement of principles • The crucial aspect is the consistency between mission and results • [social and environmental] indicators are sector-relatedHow might this build on other existing work, for instance on non-financial company reporting,social accounting, socially responsible investing, etc.?There might be some similarities and ESG accounting systems do contain elements of valuebut social businesses are different in essence from for profit, although “responsible”businesses. Therefore, the assessment methodologies should be tailored on their owncharacteristics.What information do you think needs to be disclosed to investors, and how might this best bepresented?Avanzi. Sostenibilità Per Azioni 9
  • 10. There might be different sets of indicators to be disclosed and the frequency of theirpublication might differ according to their relevance. We think that some key figures should bedisclosed almost on real time; other could be communicated on a half-yearly or yearly basis.Investor participationDo you agree that investor participation will contribute to the success of these funds?The evaluation of a social business, from both a social and economic point of view, is anextremely difficult job. We think that the added value of a vehicle such as a fund is theprofessional contribute that a competent fund manager can provide. Direct participation of theinvestors might be justified only in case it is a specialised one (for instance, a foundation).Otherwise, we see the risk that a non professional investor might be influenced by externalfactors and creates expectancies doomed to be frustrated.A specific exception should be regarded for investment in “local” social business, where thelink between the activity of the business and the community in which it operates represent avalue for the investor who live in that territory.If so, please outline how this might work in practice, and whether this can or should berequired as part of the social investment fund framework itself.Risk managementWhich particular features of social investments might require specific risk managementrequirements?Whereas social business might run additional risk of failure due to the type of activity, on theother hand the non-speculative approach should limit the exposure to default risk. We don’tknow to what extent these two features compensate each other, but we feel that socialinvestment fund should adopt a risk mitigation strategy based on the specific nature of thebusiness they invest in.DepositaryWhat should be the duties of a depositary (e.g. tracking the funds assets, reconciling units orshares issued with subscription proceeds received)? Please give reasons for your answer.We don’t think that the depositary should be charged of any additional duty.Remuneration and cost structureHow might the sustainability and profitability of a social investment fund regime be ensured?The profitability of a fund is based on a vast range of factors and it’s the ability of the fundmanager to find the right balance between the different interests. In principle, we think that thesize of the fund is important in order to dilute the fixed costs, that might be higher than thoseof a traditional fund.Are there any particular factors in your experience that might determine the commercialsuccess of the fund?Avanzi. Sostenibilità Per Azioni 10
  • 11. We don’t have a practical experience, but we think that the clarity of the value propositionstatement is key to intercept investors’ objectives and assure the alignment between theirexpectancies and results.In your view, what kinds of incentive structures might be appropriate or inappropriate for themanagers of the funds (e.g. performance fees versus flat management fees)?Price is a competitive factor. We would leave this to the market competition and we wouldrecommend not to intervene with any regulation.Improving transparency and clarityWhat steps do you think should be taken to improve transparency for investors in relation tofunds targeting social businesses?We suggest the issue of guidelines setting standards for disclosure. They might be proposedon voluntary basis in a first phase and become mandatory once “digested” by the marked andamended by the practice.What steps do you think should be taken to improve transparency for fund managers aboutthe social businesses which they target?We don’t see the need to oblige social business to disclose a given set of information. It’s intheir interest to guarantee the highest possible level of transparency towards investors. Themost transparent will be considered more attractive (other things being equal). Having saidthat, we believe that in the mid term businesses will naturally converge to a commonstandard.Improving transparency through common criteriaHow do you think common criteria for defining, labelling and rating social funds and socialbusinesses might be most effectively established?We believe that a bottom-up, multi-stakeholder approach might guarantee the highest level ofinvolvement, variety of sensitiveness and ideas. We recommend to consider the specificity ofeach national market and not to exclude the possibility of different systems in differentcountries – within a common framework.Who should establish them and develop them over time?We see room for a regulatory intervention only to set the basic, fundamental norms of thegame. Other, more detailed, rules can be decided by the professionals and the practitionerson a self-regulatory basis. The decision making process of formal legal norms can be too rigidand complicated for a sector that evolves very rapidly.How might they be verified, to ensure they are appropriately used in practice?We think that, as long as transparency is real, market forces will naturally be able to rewardthe honest players and punish the free riders. Traditional system of verification (third partyassurance) can work properly for this purpose.Avanzi. Sostenibilità Per Azioni 11
  • 12. A common EU label?Do you think a strong new EU label (e.g. supported by a common logo) would help socialinvestment funds succeed?We believe that a complicated EU regulated system would eventually weight down theindustry, that is small and fragile. We think that the best contribution EU can provide is astrong investment in a communication campaign to make the concept of social businessbetter known.How might the appropriate use of such a brand be ensured in practice, and potential forconfusion with other brands or labels diminished?There are too many labels in the market and the risk of confusion is virtually inevitable. Westrongly doubt of their effectiveness.Ensuring effective integration with social businessesand distributorsWhat steps do you think might be taken at the European level to facilitate betterintermediation between funds and social businesses? Are there particular responsibilities thatyou think fund managers should take on?We think that social investment should be encouraged and supported with frameworkmeasures, but market forces should be left free to find the best possible integration.Do you think there are any possible actions at the European level that might ensure effectivedistribution of social investment funds?Nothing besides transparency.Use of incentives, including taxHow might tax incentives be made useful? Please provide data on any existing suchincentives you are aware of.We think that tax [dis]incentives can be powerful measure to encourage [or discourage] someactivities. Although widely used, they are in fact mechanism that can distort the free marketcompetition. As we believe that social businesses should compete fairly with other models inthe market and not in a separate ground. Therefore, tax incentives should be granted only fora limited period of time, say 3 up to 5 years, with the objective to allow the growth of a newpractice. After that, a phasing out period should lead to a complete alignment.Are there any other measures you think might be possible to maximise investors access tosocial investment funds, or the attractiveness of these for investors?Avanzi. Sostenibilità Per Azioni 12
  • 13. Avanzi. Sostenibilità Per Azioni 13