Santiago Principles Self-Assessment

CDP Equity SpA

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  • Pillar 1: Legal
  • Pillar 2: Institutional
  • Pillar 3: Investment
Principle 1

1. The legal framework for the SWF should be sound and support its effective operation and the achievement of its stated objective(s).

1.1. The legal framework for the SWF should ensure legal soundness of the SWF and its transactions.

1.2. The key features of the SWF’s legal basis and structure, as well as the legal relationship between the SWF and other state bodies, should be publicly disclosed.

CDP Equity SpA (“CDPE”) is a joint-stock company with a sole shareholder Cassa depositi e prestiti SpA (“CDP”), that has a major public shareholder, the Italian Ministry for the Economy and Finance (“MEF”), but also private shareholders.

The legal framework of CDPE is mainly represented by:

Art. 5 paragraph 8-bis of Law Decree September 30, 2003, n. 269 (introduced by Art. 7 paragraph 1 of Law Decree March 31, 2011, n. 34);

Ministerial Decree July 2, 2014;

CDPE Articles of Association, available on CDPE website (Statuto_CDP_Equity_04-2022_ENG.pdf). 

The above regulation provides for the corporate purpose and the investment criteria of CDPE. In particular, the Ministerial Decrees dated May 3, 2011 and July 2, 2014 define the companies of “significant national interest” in which CDPE can invest.

Since 2019, CDPE has invested, as a cornerstone investor, in direct funds and funds of funds managed by Asset Management Companies in which CDPE is a shareholder, according to its strategy. 

The above legal relationships are publicly disclosed on

CDPE website ( 

Principle 6

6. The governance framework for the SWF should be sound and establish a clear and effective division of roles and responsibilities in order to facilitate accountability and operational independence in the management of the SWF to pursue its objectives.

CDPE is a joint stock company, thus its corporate rules are regulated by the Italian Civil Code.

CDPE corporate governance framework is also defined by its Articles of Association, that set a clear and effective separation of roles and responsibilities.

Furthermore, CDPE has structured a series of procedures representing its corporate regulatory system, in line with the best market practice for companies operating in the investment sector.

The different functions of each governing body are publicly disclosed on CDPE website: (

Principle 18

18. The SWF’s investment policy should be clear and consistent with its defined objectives, risk tolerance, and investment strategy, as set by the owner or the governing body(ies), and be based on sound portfolio management principles.

18.1. The investment policy should guide the SWF’s financial risk exposures and the possible use of leverage.

18.2. The investment policy should address the extent to which internal and/or external investment managers are used, the range of their activities and authority, and the process by which they are selected and their performance monitored.

18.3. A description of the investment policy of the SWF should be publicly disclosed.

CDPE’s mission, investment policy and the selection process for the investments are clearly defined and publicly disclosed in its Articles of Association. 

The purpose of the company is the direct or indirect acquisition of equity investments, intended as the activity of acquiring, holding and managing rights, whether or not represented by securities, in the capital of joint-stock companies with significant development prospects that:

are active in the sectors of defence, security, infrastructure, transport, communications, energy, insurance and financial intermediation, high-tech research and innovation, and public services, tourism-hotel, agribusiness and distribution, and management of cultural and artistic heritage; or 

although not engaged in the sectors referred to in (i) above, meet the following cumulative requirements: a) annual net turnover of no less than 300 million euro; and b) average number of employees in the last financial year of no less than 250; 

although not engaged in the sectors referred to in (i) above and although they have a turnover or a number of employees lower than those indicated in (ii) above, but in any case not lower than 20% of the aforesaid figures, carry out a significant activity in terms of generating related economic activities and benefits for Italy’s economic and production system, also in terms of production plants on the Italian territory.

Companies that, although not incorporated in Italy, are active in the sectors referred to in (i) and have subsidiaries or permanent establishments in Italy that meet the following cumulative requirements are also of significant national interest: a) annual net turnover of no less than 50 million euro; b) average number of

employees in the last financial year of no less than 250.

The above requirements must be met and documented at the time the transaction is approved by the company's Board of Directors.

( ).