Carlo Trabattoni
CEO Asset & Wealth Management Business Unit and Chairman of the Board of Generali Investments Partners
After graduating with a Bachelor's degree in Economics from Bocconi University, Carlo started his career in Financial Services joining Fideuram S.p.A. in Milan.
In 1991, he moved to Intereuropa Sim S.p.A. as Head of Sales and Marketing to create the sales division and to develop and manage the financial distribution network at national level. In 1996, he joined Schroders Italy Sim S.p.A in its startup phase, as Commercial Director, to create a third parties nationwide distribution.
In 2000, he was promoted to Country Head and Managing Director of the local entity, bearing responsibility for all the activities performed by Schroders Group in Italy. In addition, he was the Foreign Fund Managers’ representative in Assogestioni, Italian association of asset managers, as Board Member, and in IFI as Executive Board Member.
In 2006, he advanced to Head of Intermediary in Continental Europe & Middle East, whilst maintaining the responsibility as Country Head in Italy and becoming Member of Global Distribution Executive Committee and Member of Global Retail Distribution Committee in London.
In 2009, he was appointed as Country Head and President of Schroder Investment Management (SIM) in Tokyo, being also appointed President of the Board of SIM Japan.
In 2012, he returned to London as Head of the Pan European Distribution and Global Financial Institutions Group. Carlo was also member of the Board of Schroder International Sicav in Luxembourg.
Carlo Trabattoni joined Generali in September 2017, as Head of Generali Investments Partners and was appointed as Chief Executive Officer within the A&WM Business Unit in March 2021.
Vincent Chaigneau, who joined the group in August 2017, is Head of Research at Generali Asset Management S.p.A. SGR.
He contributes to Assicurazioni Generali’s Investment Strategy and is a member of the Group Tactical Asset Allocation Committee, as well as the Global Leadership Group.
Vincent runs a team of 30+ top-down, bottom-up and Quant analysts across markets and asset classes. He joined from Société Générale CIB, last serving as Head of Fixed Income Research.
Vincent holds a Master’s Degree and Postgraduate Degree in International Economics and Finance from the University of Bordeaux. He is a member of the CEPR Advisory Board member, and of the EU Economic Board.
Vincent Vinit is the Chief Risk Officer of Generali Insurance Asset Management S.p.A. Società di gestione del risparmio since July 2019 and Chief Risk Officer of Generali Real Estate S.p.A. since June 2016.
Prior to joining Generali, Vincent had been the Global Head of Risk Management & Compliance at AXA Real Estate since 2009. He previously worked for BNP Paribas, holding several functions, including for Group Risk Management.
Vincent, who started his career in 1998 as a consultant for Altran in Paris and Munich, holds an Executive MBA from HEC Paris and a Master Degree in Computer Science from Aix-Marseille University.
Antonio Cavarero was appointed Head of Investments at Generali Asset Management S.p.A. SGR in January 2024.
Prior to that, he was Head of Investments at Generali Insurance Asset Management S.p.A. SGR (GIAM) and at Generali Investments Partners S.p.A. SGR (GIP) between February 2020 and December 2023. A professional with almost 30 years of experience in financial markets, he held different investment roles since he joined the Generali Group in 2014. Before Generali, he had important international experiences with leading investment banks such as Deutsche Bank, Citi, Société Générale Corporate & Investment Banking, Banca IMI, Banca Euromobiliare.
Bruno Servant was the CEO of Generali Insurance Asset Management (GIAM) since March 2021, before becoming CEO of Generali Asset Management S.p.A. SGR.. Bruno joined Generali Group in September 2007 as Deputy Chief Executive Officer of Generali Investments France, was then nominated as Chief Investments Officer of Generali France in 2012 and since November 2017 he also held the position of Head of Group Investment Management Solutions.
Before working in Generali Group, Bruno Servant was Deputy Chief Executive Officer at UBS Global and prior to that Business Head for Asset Management for Deutsche Bank Paris.
Santo Borsellino is, as of January 1st, 2024, the Chairman of Generali Investments Holding S.p.A. and Vice-Chairman of Generali Asset Management S.p.A. SGR (GenAM).
From April 2019 to December 2023, Santo held the position of Head of Corporate Governance Implementation and Chairman of the Board of Generali Insurance Asset Management S.p.A. Società di gestione del risparmio (previously Generali Investments Europe S.p.A. Società di gestione del risparmio).
He had been Chief Executive Officer of Generali Insurance Asset Management S.p.A. Società di gestione del risparmio (previously Generali Investments Europe S.p.A. Società di gestione del risparmio) since June 2013. Before joining the company as Head of Equities in 2008, he gained extensive experience as an asset manager and equity analyst working for leading investment banks and asset management companies in London and Milan.
Santo graduated cum laude from the University of Economics in Bologna and holds an MBA from the Tuck School of Business, Dartmouth University, USA.
Tim Rainsford is appointed, effective January 1st, 2024, as Chief Product & Distribution Officer of Generali Investments Holding S.p.A. and Head of Product & Distribution of Generali Asset Management S.p.A. SGR (GenAM).
Tim joined Generali in September 2020 as Global Head of Sales of GIP, with the responsibility to define the commercial development plans and strategies aimed at consolidating the international footprint and he held the position of CEO of Generali Investments Partners (GIP) from April 15th, 2021 to December 2023.
Prior to that, Tim was Group Head of Distribution and Marketing at GAM Investments, with the responsibility for the company’s marketing and sales strategic direction. He previously spent thirteen years at Man Investments, covering positions of growing responsibility including Senior Managing Director - Head of European Sales, and Global Co-Head of Sales and Marketing.
Our ecosystem of asset management firms
Generali Investments* is an ecosystem of asset management firms, delivering a portfolio of specialist capabilities across various countries.
Years of experience
Assets under management
Asset managers and specialists
Countries worldwide for distribution
Asset management firms
Main distribution hub
Source: Generali Investments Holding S.p.A., data as at 30.06.2023. Generali Investments is part of the Generali Group, which was established in 1831 in Trieste as Assicurazioni Austro-Italiche. Generali Investments Partners S.p.A. Società di gestione del risparmio, Generali Insurance Asset Management S.p.A. Società di gestione del risparmio, Generali Real Estate S.p.A. Società di gestione del risparmio, Infranity, Sosteneo Infrastructure Partners Società di gestione del risparmio, Sycomore Asset Management, Aperture Investors LLC (including Aperture Investors UK Ltd), Lumyna Investments Limited, Plenisfer Investments SGR, are part of Generali Investments, as well as Generali Investments CEE. Please note that the number of countries refers to the number of countries where the different funds of the asset management companies part of Generali Investments are registered for distribution. Please note that not all funds are registered in all the countries and not all the asset management companies are licensed to operate in such countries.
The world of investment is more complex than ever.
That’s why we’ve created Generali Investments: an ecosystem of asset management firms, delivering a portfolio of specialist capabilities.
We take the time to understand what matters most to investors, so we can build solutions that best reflect their needs.
Every firm in our ecosystem is supported by Generali and able to innovate and grow with autonomy. For investors, this means access to highly entrepreneurial firms, with the security of our support.
Our solutions, built from a variety of specialist capabilities, aim to help investors unlock opportunities and generate long-term performance, while being mindful of our impact on the world around us.
In this way, we provide clients access to new investment possibilities that others might miss, and a partner that prioritises their long-term interests.
Generali Investments is part of the Generali Asset & Wealth Management Business Unit which gathers the Group’s main companies operating in asset management and wealth management.
Active fixed income, equity, multi-asset, fund of funds, and private markets
Generali Investments Partners* offer in-house fixed income, thematic equities and multi asset/balanced portfolios, as well as a range of private asset strategies. They are expert asset manager selectors and offer a wide fund of funds range across public and private markets. The firm is also the main distribution hub for Generali Investments ecosystem, acting as lead client relationship manager for all the asset management firms.
*The company full legal name is Generali Investments Partners S.p.A. Società di gestione del risparmio.
Head of Investments
Governance and Legal Policies
Complaints handling
The Company has adopted an appropriate procedure to ensure prompt handling of complaints from Clients/Investors (the “Complaints Management” Operating Procedure).
The procedure adopted provide for records to be kept of the essential elements of each complaint received and of the measures implemented to solve the issue.
The Compliance Function is the organisational structure responsible for handling complaints.
Complaints must contain:
i) the complainant’s details;
ii) the reasons for the complaint;
iii) the signature or similar reference allowing the Client to be identified with certainty.
All complaints must be sent in writing to the Compliance Function:
in Italy to:
Generali Investments Partners S.p.A. Società di gestione del risparmio
Compliance Function,
Piazza Tre Torri, 1
20145, Milano
Italia
or to the following email address: InvestmentsCompliance@generali.com
in France to:
Generali Investments Partners S.p.A. Società di gestione del risparmio, French Branch
Rue Pillet Will, 2
75009, Paris
France
or to the following email address: InvestmentsCompliance@generali.com
in Germany to:
Generali Investments Partners S.p.A. Società di gestione del risparmio, German Branch
Tunisstraße 29
50667-Cologne,
Deutschland
or to the following email address: InvestmentsCompliance@generali.com
The final outcome of the complaint, containing the Company’s decisions, will, as a rule, be communicated in writing to the Client/Investor within 60 days from receipt.
Sustainability-related disclosures
The Company, having its registered office in
Italy: in Trieste, Via Machiavelli no. 4 and secondary offices in Milan 20145, Piazza Tre Torri 1,
in France - Rue Pillet-Will 75309 Paris Cedex 09
in Germany - 50667 Cologne, Tunisstraße 29 as well as Germany 60318 Frankfurt am Main, Oeder Weg 151
and with operational offices
in Italy: in Trieste 34132, Piazza Duca degli Abruzzi, no. 1 and in Rome 00187, Via Leonida Bissolati no. 23,
belonging to the Assicurazioni Generali Group, subject to the management and coordination of Generali Investments Holding SpA, Tax Code, VAT No. and registration into the Venezia Giulia Trade Register no. 01306320324 [tel. 040671111 - fax 040 671400] is an Asset Management Company authorised by a provision of the Bank of Italy on 24 July 2018 and entered in the Register of asset management companies in the UCITS Section under no. 55 and in the AIF Section under no. 165.
Communications of any kind between the Client and the Company concerning the provision of investment services, including the sending of any orders (special instructions) to the Company by the Client, must be in writing and must be sent:
- for correspondence to the Client:
To the address indicated by the Client/Investor to the Company in the portfolio management agreement, in the investment advisory agreement, in the agreement for the service of reception and transmission of orders for execution (hereinafter “the agreements for investment services”) or in the subscription form for the mutual funds promoted by the Company (the “Funds”), or to another address subsequently communicated in writing;
- for correspondence to the Company:
in Italy, to Generali Investments Partners S.p.A. Società di gestione del risparmio -, 34132, Piazza Duca degli Abruzzi, no. 1, Trieste, and 20145, Piazza Tre Torri 1, Milano or to any different address and with any different procedures that may be agreed upon with the Client and indicated in the relative agreement;
in France, to Generali Investments Partners S.p.A. Società di gestione del risparmio, French Branch - Rue Pillet - Will 2, 75309 Paris Cedex 09, or to any different address and with any different procedures that may be agreed upon with the Client and indicated in the relative agreement;
in Germany to Generali Investments Partners S.p.A. Società di gestione del risparmio, Zweigniederlassung Deutschland - 50667 Cologne, Tunisstraße 29
or to any different address and with any different procedures that may be agreed upon with the Client and indicated in the relative agreement.
Language used
The agreements for investment services, as well as all documents relating to the Funds, shall be drawn up in the Client’s/Investor’s reference language or the language of the place of domiciliation of the relevant Fund;
the same language must also be used in all subsequent verbal or written communications between the Client/Investor and the Company.
Investment services and activities that can be exercised
The Company is authorised by the Bank of Italy to carry out the following investment services and activities:
portfolio management;
collective portfolio management;
distribution of the units and shares of its own and third parties’ UCITSs and AIFs;
investment advice;
ancillary services.
Unconstrained investment strategies with a unique fee model
Aperture* offers unconstrained investment strategies and a unique fee model that aligns fund manager incentives with client performance. The firm charge low, ETF-like fees when performance is at or below stated benchmarks. A performance-linked fee is charged only when returns are generated in excess of a strategy’s benchmark. Their investment teams are therefore compensated primarily on outperformance. Aperture’s highly experienced credit and equity investment teams are based in New York and London.
*The company full legal name is Aperture Investors, LLC.
*Investments involve risks. Past performance is not a reliable indicator of future performance and can be misleading. There can be no assurance that an investment objective will be achieved or that there will be a return on capital. You may not get back the amount initially invested.
Liquid alternative UCITS provider
Lumyna* is one of the oldest, largest and most successful Alternative UCITS providers in Europe. The firm brings best-of-breed hedge fund managers to the European market via regulated, liquid and transparent UCITS vehicles. Lumyna is consistently voted as best platform (by HFM in eight of the last nine years and by HFR for the last seven consecutive years**) and is recognised as a leader in the delivery of Alternative UCITS funds.
* The company full legal name is Lumyna Investments Limited
**Every year, the Hedge Funds Review European Performance Awards reward genuine performance, quality and skill within the European hedge fund industry.
Equity and debt real estate investments
Generali Real Estate* are the Generali Group experts in real estate investments, with a strong presence across Europe with about 370 professionals that operate in nine different countries. They invest in all of the steps across the real estate value chain: investment, asset and property management. Their Luxembourg funds range offers efficiency and diversification, and covers the full risk return spectrum from core to development in several sectors.
*The company full legal name is Generali Real Estate S.p.A.
High conviction ESG and SRI investors
Sycomore* offers industry-leading sustainable investments. They are pioneering ESG investors and have actively shaped its development in Europe. The firm focuses on human capital as the main lever to generate high conviction investment ideas, and their responsible investment approach is grounded in unique proprietary ESG research methodology. Sycomore’s fund range offers 16 Article 9 funds under SFDR regulation, and five Article 8 funds.
*The company full legal name is Sycomore Asset Management
Infranity is an asset management company specialising in infrastructure investments. The Company founded by three Managing Partners, Philippe Benaroya, Alban de La Selle and Gilles Lengaigne, as part of a strategic partnership with the Generali Group, is part of Generali Investments ecosystem of asset management firms and currently manages in excess of €7 billion of capital from institutional investors. Infranity's investment solutions leverage the resilience of the asset class and its long-term stable returns, as well as its ability to contribute to sustainable development. The investments address major societal challenges such as the energy transition, green mobility, digital transition and improvements to social infrastructure. This positioning, combined with a high degree of selectivity in the investment process, enables Infranity to generate sustainable value for its clients.
Infranity is part of Generali Investments.
Total return global multi-asset strategies
Plenisfer* are goal-based investors, offering unconstrained, total return, multi-asset strategies. Their ‘New Active’ investment philosophy allocates to strategies rather than asset classes. They focus on identifying idiosyncratic opportunities across a global opportunity set, and do not differentiate between traditional and alternative asset classes. This holistic approach allows the team to build outcome-oriented portfolios. The firm offers UCITS funds, bespoke mandates, and investment consulting.
* The company full legal name is Plenisfer Investments SGR
LDI solutions and multi-asset portfolio management
Generali Insurance Asset Management* partner with clients of all sizes to develop and manage customised LDI solutions to help them achieve their long-term investment goals. They offer Asset Liability Management (ALM), Strategic Asset Allocation (SAA) and Capital Management, and benefit from extensive proprietary research and ESG analysis resources. The firm has managed bespoke segregated LDI mandates for pension schemes and insurers since 2005 and have managed Generali Group insurance portfolios and pension mandates since 1998.
*The company full legal name is Generali Insurance Asset Management S.p.A. Società di gestione del risparmio.
Governance and Legal Policies
Complaints Handling
Complaints handling
The Company has adopted an appropriate procedure to ensure prompt handling of complaints from Clients/Investors (the “Complaints Management” Operating Procedure).
The procedure adopted provide for records to be kept of the essential elements of each complaint received and of the measures implemented to solve the issue.
The Compliance Function is the organisational structure responsible for handling complaints.
Complaints must contain:
i) the complainant’s details;
ii) the reasons for the complaint;
iii) the signature or similar reference allowing the Client to be identified with certainty.
All complaints must be sent in writing to the Compliance Function:
in Italy to:
Generali Insurance Asset Management S.p.A. Società di gestione del risparmio
Compliance Function,
Piazza Tre Torri, 1
20145, Milano
Italia
or to the following email address: InvestmentsCompliance@generali.com
in France to:
Generali Insurance Asset Management S.p.A. Società di gestione del risparmio, French Branch
Rue Pillet Will, 2
75009, Paris
France
or to the following email address: InvestmentsCompliance@generali.com
in Germany to:
Generali Insurance Asset Management S.p.A. Società di gestione del risparmio, German Branch
Tunisstraße 29
50667-Cologne,
Deutschland
or to the following email address: InvestmentsCompliance@generali.com
The final outcome of the complaint, containing the Company’s decisions, will, as a rule, be communicated in writing to the Client/Investor within 60 days from receipt.
Sustainability-related disclosure
The Company, having its registered office
in Italy, in Trieste, Via Machiavelli no. 4 [tel. 040671111 - fax 040 671400] and secondary offices in Milan 20145, Piazza Tre Torri 1,
in France - Paris Cedex 09, Rue Pillet-Will 75309 and
in Germany 50667 Cologne, Tunisstraße 29
and with operational offices in Italy located in
Trieste 34132, Piazza Duca degli Abruzzi, no. 1 and in
Rome 00187, Via Leonida Bissolati no. 23,
belonging to the Assicurazioni Generali Group, subject to the management and coordination of Generali Investments Holding S.p.A., Tax Code and entry in the Venezia Giulia Trade Register no. 05641591002, VAT number 01004480321 is an Asset Management Company authorised by a provision of the Bank of Italy on 8 May 1999 and entered in the Register of Italian asset management companies in the UCITS Section under no. 18 and in the AIF Section under no. 22.
Communications of any kind between the Client/Investor and the Company concerning the provision of the services, including the sending of any orders (special instructions) to the Company by the Client, must be in writing and must be sent:
in Italy, to
Generali Insurance Asset Management S.p.A. Società di gestione del risparmio
34132, Piazza Duca degli Abruzzi, no. 1, Trieste
and / or
Generali Insurance Asset Management S.p.A. Società di gestione del risparmio
20145, Piazza Tre Torri 1, Milano
or to any different address and with any different procedures that may be agreed upon with the Client/Investor and indicated in the relative agreements for the Services;
in France, to
Generali Insurance Asset Management S.p.A. Società di gestione del risparmio, French Branch - Rue Pillet - Will 2, 75309 Paris Cedex 09,
or to any different address and with any different procedures that may be agreed upon with the Client/Investor and indicated in the relative agreements for the Services;
in Germany to
Generali Insurance Asset Management S.p.A. Società di gestione del risparmio, Zweigniederlassung Deutschland - 50667 Cologne, Tunisstraße 29
or to any different address and with any different procedures that may be agreed upon with the Client and indicated in the relative agreements for the Services.
The Company is authorized by the Bank of Italy to carry out the following investment services and activities:
Individual portfolio management service[1];
investment advice[4];
marketing of the units and shares of its own and third parties’ UCITSs and AIFs (the “Funds”)
collective investment portfolio management;
(the “Services”).
[1] Mandate given by clients for the management, on a discretionary and individualized basis, of investment portfolios that include one or more financial instruments (Italian Legislative Decree No. 58 of 24 February 1998 (“TUF”), according to article 1, clause 5-quinquies)
[2] Concluding agreements to buy or sell one or more financial instruments on behalf of clients, including concluding agreements to subscribe to or buy or sell financial instruments issued by an investment firm or a bank at the time of their issue (Italian Legislative Decree No. 58 of 24 February 1998 (“TUF”), according to article 1, clause 5-septies.1)
[3] Currently GIAM provides the RTO service only for the benefit of Generali Investment Partners SPA Società di Gestione del Risparmio.
[4] the provision of personalised recommendations to a client, at its request or at the initiative of the service provider of the service, in respect of one or more transactions relating to financial instruments (Italian Legislative Decree No. 58 of 24 February 1998 (“TUF”), according to article 1, clause 5-septies)
Retail real estate investment and asset managers
Axis Retail Partners is a team of specialist retail real estate investment and asset managers. The firm has an analytical approach to investing with strong focus on data as the key driver behind underwriting and decision-making. The firm is a fully integrated real estate player, with the capabilities to cover all the steps of the asset life-cycle: investment, asset and portfolio management and disposals ranging from core to opportunistic investments.
Investing in the new essential infrastructure that accelerates the transition to net zero
Sosteneo Infrastructure Partners is an investment manager that specialises in greenfield infrastructure equity related to the energy transition, with a focus on clean energy production and enablement. They are trusted by clients to manage capital in a way that contributes to the decarbonisation of the energy system whilst providing an attractive long-term commercial return, with a strong emphasis on delivering value enhancements through the asset lifecycle. Based in Milan and Sydney, the team brings together a wealth of infrastructure equity investment expertise complemented by an industrial background in the energy sector.
*The company full legal name is Sosteneo Infrastructure Partners, Società di gestione del risparmio
Generali Investments Luxembourg* (“GIL”), part of the Generali group, is a Luxembourg based management company authorized under Chapter 15 of the Law of 17 December 2010 relating to Undertakings for Collective Investments in Transferable Securities (UCITS) as well as an Alternative investment fund manager authorized under the Law of 12 July 2013 on alternative investment fund managers. As such, it offers the overall mandatory management company services for both UCITS and AIF products.
As Management Company, GIL manages investments on an international scale leveraging on the experience and professionalism of a team of world-class investment firms, including Generali Group asset management companies and boutiques as well as other major players whose capabilities are available through its fund offerings. GIL’s activities focus on the set-up of investment funds, designing structures and strategies adapted to different situations and investors. GIL’s risk management services are adjusted to the changing market environment while financial professionals supervise the day-to-day activities of the investment vehicle. As a result the investment managers can focus on their priorities while generating growth.
Based in Luxembourg, the largest fund center in Europe and the largest international hub for fund distribution, GIL benefits from an efficient and reliable fund infrastructure. The Management Company offers a wide range of fund structures such as UCITS, real estate funds, SIFs, AIFs and non-UCITS vehicles. In addition, being based in Luxembourg, GIL is regulated by a sophisticated but pragmatic legal and regulatory framework.
*The company full legal name is Generali Investments Luxembourg S.A.
Chairman of the Board
Chief Executive Officer
GIL Head of Oversight of Delegates – Conducting Officer
GIL Chief Risk Officer – Conducting Officer
GIL Chief Compliance Officer – Conducting Officer
Generali Investments Holding* guarantees a solid framework of services designed to support various asset management activities. Key elements include back office activities, organized to provide maximum efficiency; advanced reporting systems and sophisticated technological infrastructures. The company also acts as a holding company, retaining share capital in the asset management firms of Generali Investments’ ecosystem.
*The company full legal name is Generali Investments Holding S.p.A.
● Gain access to niche investment skills
● Rely on experts selected by Generali Group based on knowledge and talent
● Benefit from long-term attractive opportunities through distinctive investment strategies
● Broadens and diversifies investment solution offer
● Invests in results-centred companies with a strong entrepreneurial drive
● Selects quality partners to maximise returns on investment
● Keep their investment autonomy
● Leverage Generali Group’s strength, capital, customer focus, global reach and brand
● Engage in an ecosystem ensuring consistency in the areas of risk control, audit and compliance
MILLION CUSTOMERS
THOUSAND EMPLOYEES
COUNTRIES
GROSS WRITTEN PREMIUMS
ASSETS UNDER MANAGEMENT
AMONG THE TOP 100 LARGEST COMPANIES IN THE WORLD ****
*** Source: Generali Group, data as at 31 December 2022.
**** Source: Fortune Global 500 2022.
© Generali Investments, all rights reserved. This website is provided by Generali Investments Holding S.p.A. as the holding company of the main asset management companies of the Generali Group having, directly or indirectly, the majority shareholding in the companies listed below (hereinafter jointly, “Generali Investments”). This website may contain information related to the activity of the following companies: Generali Asset Management S.p.A. Società di gestione del risparmio, Infranity, Sycomore Asset Management, Aperture Investors LLC (including Aperture Investors UK Ltd), Plenisfer Investments S.p.A. Società di gestione del risparmio, Lumyna Investments Limited, Sosteneo S.p.A. Società di gestione del risparmio, Generali Real Estate S.p.A. Società di gestione del risparmio, Conning* and among its subsidiaries Global Evolution Asset Management A/S - including Global Evolution USA, LLC and Global Evolution Fund Management Singapore Pte. Ltd - Octagon Credit Investors, LLC, Pearlmark Real Estate, LLC as well as Generali Investments CEE. *Includes Conning, Inc., Conning Asset Management Limited, Conning Asia Pacific Limited, Conning Investment Products, Inc., Goodwin Capital Advisers, Inc. (collectively, “Conning”).