Nummus.Info was founded in 2013 and its promoting partners include the Italian Episcopal Conference, the Diocese of Milan and ISA S.p.A., a financial company owned by the Diocese of Trento and other Italian dioceses.

Nummus.Info was created to provide efficient and timely support to the monitoring function of investment portfolios, both securities and real estate, by providing objective analyses of both the exposure to the various financial risks assumed by the portfolio and the performance achieved in absolute and relative terms with respect to the performance of the various markets and investment instruments.

Since 2016, Nummus.Info has also been monitoring portfolios from an ethical and sustainable point of view, analysing the criticalities or merits of the securities in the portfolio.

In 2021 Nummus.Info developed a proprietary model for the analysis of Private Markets investments, capable of expressing an ESG assessment on Private Equity/Debt, Venture Capital, Infrastructure and Real Estate products. This is the first ESG assessment model for Private Markets products. In 2022 the Nummus.Info team will expand.

Our History


  • Incorporation of the company


  • Start of ESG activities


  • Nummus.Info becomes a member of the Sustainable Finance forum


  • Membership of the United Nations-supported PRI


  • Publication of the CEI guidelines document

  • Nummus Ethics Certification is born


  • ESG private market assessment model


  • Introduction of engagement

The organisation, management and control model 231

Legislative Decree No. 231 of 8 June 2001: Organisation, Management and Control Model, Charter of Principles, Disciplinary System, Whistleblowing

As is well known, Legislative Decree 231/01 introduced and regulates the liability of ‘entities’ (a concept that includes entities with legal personality, companies and associations, including those without legal personality) for administrative offences dependent on crime.

It provides for the direct liability of the body for the commission of certain offences by persons functionally linked to it and establishes the applicability to the latter of administrative sanctions (pecuniary, prohibitory, confiscation and publication of the sentence), which may have serious repercussions on the performance of the company’s business.

The provisions of Legislative Decree 231/01 exclude the liability of the Company in the event that it – before the offence is committed – has adopted, and effectively implemented, an Organisational, Management and Control Model and a Code of Ethics suitable for preventing the commission of offences of the kind committed. Compliance with these company regulations must be ensured by a Supervisory Board.

To this end, the Board of Directors of Nummus.Info has adopted – after analysing the relevant corporate risks pursuant to Legislative Decree 231/01 – its own Organisational, Management and Control Model (MOG) – including a Charter of Principles and Rules of Conduct with the relevant Disciplinary System – which complies, for employees, with the provisions of the CCNL – designed to prevent the relevant predicate offences in relation to the business activity carried out and to sanction any ascertained violations of the Organisational Model: company regulations and procedures binding for all persons, in various capacities, in professional relations with the Company, corporate bodies, managers, employees, external collaborators, suppliers and consultants.

Lastly, a specific procedure has also been introduced for the confidential reporting of unlawful conduct that is relevant and based on precise and concordant facts – or violations of the Organisation, Management and Control Model – of which the reporter has become aware by reason of the functions performed (so-called whistleblowing).

Finally, as provided for in Legislative Decree 231/01, Nummus.Info has set up a Supervisory Board with the functions of monitoring compliance with the aforementioned regulations and procedures.

The Supervisory Board can, and must, be addressed, in confidential form, exclusively:

  • reports of any violations of the provisions, rules, principles and prohibitions of the Organisation, Management and Control Model, as well as of the related Charter of Principles;
  • well-founded suspicions of commission of offences referred to in Legislative Decree 231/ 2001 – in the interest of the Company – by apical subjects and employees, as well as by any other subject, for various reasons, in business or professional relations with the Company;
  • any proposals to adjust the Organisation, Management and Control Model where it no longer corresponds to the actual company reality;

“The adoption of the Organisation, Management and Control Model and the establishment of the Supervisory Board are part of the process of constant strengthening and attention reserved by Nummus.Info to internal controls aimed at achieving the highest standards of legal compliance in compliance with the regulations in force and industry best practices.”

Erica Cis
Operations Director

Code of Ethics

Download our company’s Code of Ethics.

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