UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM N-CSR
CERTIFIED SHAREHOLDER REPORT OF REGISTERED MANAGEMENT
INVESTMENT COMPANIES
Investment Company Act file number 811-22026
The Gabelli SRI Fund, Inc.
(Exact name of registrant as specified in charter)
One Corporate Center
Rye, New York 10580-1422
(Address of principal executive offices) (Zip code)
Bruce N. Alpert
Gabelli Funds, LLC
One Corporate Center
Rye, New York 10580-1422
(Name and address of agent for service)
Registrants telephone number, including area code: 1-800-422-3554
Date of fiscal year end:March 31
Date of reporting period: March 31, 2015
Form N-CSR is to be used by management investment companies to file reports with the Commission not later than 10 days after the transmission to stockholders of any report that is required to be transmitted to stockholders under Rule 30e-1 under the Investment Company Act of 1940 (17 CFR 270.30e-1). The Commission may use the information provided on Form N-CSR in its regulatory, disclosure review, inspection, and policymaking roles.
A registrant is required to disclose the information specified by Form N-CSR, and the Commission will make this information public. A registrant is not required to respond to the collection of information contained in Form N-CSR unless the Form displays a currently valid Office of Management and Budget (OMB) control number. Please direct comments concerning the accuracy of the information collection burden estimate and any suggestions for reducing the burden to Secretary, Securities and Exchange Commission, 100 F Street, NE, Washington, DC 20549. The OMB has reviewed this collection of information under the clearance requirements of 44 U.S.C. § 3507.
Item 1. Reports to Stockholders.
The Report to Shareholders is attached herewith.
Gabelli SRI Fund, Inc.
Annual Report March 31, 2015
Portfolio Management Team
To Our Shareholders,
For the fiscal year ended March 31, 2015, the net asset value (NAV) per Class AAA Share of the Gabelli SRI Fund, Inc. rose 10.1%, compared with an increase of 5.4% for the Morgan Stanley Capital International (MSCI) AC World Index. See page 2 for additional performance information.
Enclosed are the financial statements, including the schedule of investments, as of March 31, 2015.
Performance Discussion (Unaudited)
The Funds investment objective is to seek capital appreciation. The Fund seeks to achieve its objective by investing substantially all, and in any case no less than 80%, of its assets in common and preferred stocks of companies that meet the Funds guidelines for social responsibility at the time of investment. The portfolio managers employ a social screening overlay process at the time of investment to identify companies that meet the Funds social guidelines.
As bottom up stock pickers, we are generally not making calls on the direction of rates or any other macro variable. Our process favors companies that can thrive in any climate, for example, those with pricing power, solid balance sheets, and adaptable managements.
Selected holdings that contributed positively to performance for the fiscal year were: OReilly Automotive Inc. (2.0% of net assets as of March, 31, 2015), a leading retailer in the automotive aftermarket industry; Coty Inc. (1.9%), together with its subsidiaries, manufactures, markets, and distributes womens and mens fragrances, color cosmetics, skin and body care products worldwide; Macquarie Infrastructure Co. LLC (1.8%) owns, operates, and invests in a portfolio of infrastructure businesses. Some of our weaker performing stocks were: Rogers Communications Inc. (0.8%), Canadas largest cable and wireless company; Boulder Brands Inc. (0.5%) provides health and wellness food solutions in the United States and Canada; and Blucora Inc. (0.4%) operates a portfolio of Internet businesses. It operates through three segments: Search and Content, Tax Preparation, and E-Commerce.
We appreciate your confidence and trust.
Sincerely yours, |
|
Bruce N. Alpert |
President |
May 12, 2015
Comparative Results
Average Annual Returns through March 31, 2015 (a)(b) (Unaudited) | ||||||||||||||||||||
1 Year | 3 Year | 5 Year | Since Inception (6/01/07) | |||||||||||||||||
Class AAA (SRIGX) |
10.08 | % | 11.27 | % | 9.10 | % | 6.41 | % | ||||||||||||
MSCI AC World Index |
5.42 | 10.75 | 8.99 | 2.82 | ||||||||||||||||
S&P 500 Index |
12.73 | 16.11 | 14.47 | 6.14 | ||||||||||||||||
Class A (SRIAX) |
10.09 | 11.28 | 9.13 | 6.42 | ||||||||||||||||
With sales charge (c) |
3.76 | 9.10 | 7.84 | 5.62 | ||||||||||||||||
Class C (SRICX) |
9.37 | 10.47 | 8.29 | 5.63 | ||||||||||||||||
With contingent deferred sales charge (d) |
8.37 | 10.47 | 8.29 | 5.63 | ||||||||||||||||
Class I (SRIDX) |
10.41 | 11.58 | 9.38 | 6.68 |
In the current prospectuses dated July 29, 2014, the expense ratios for Class AAA, A, C, and I Shares are 1.74%, 1.74%, 2.49%, and 1.49%, respectively. See page 9 for the expense ratios for the year ended March 31, 2015. Class AAA and I Shares do not have a sale charge. The maximum sales charge for Class A and C Shares is 5.75% and 1.00%, respectively. (a) Returns represent past performance and do not guarantee future results. Total returns and average annual returns reflect changes in share price, reinvestment of distributions, and are net of expenses. Investment returns and the principal value of an investment will fluctuate. When shares are redeemed, they may be worth more or less than their original cost. Current performance may be lower or higher than the performance data presented. Visit www.gabelli.com for performance information as of the most recent month end. Returns would have been lower had Gabelli Funds, LLC (the Adviser) not reimbursed certain expenses of the Fund for periods prior to March 31, 2011. The Fund imposes a 2% redemption fee on shares sold or exchanged within seven days after the date of purchase. Investors should carefully consider the investment objectives, risks, charges, and expenses of the Fund before investing. The prospectuses contain information about these and other matters and should be read carefully before investing. To obtain a prospectus, please visit our website at www.gabelli.com. The MSCI AC World Index is an unmanaged market capitalization weighted index representing both developed and emerging markets. The S&P 500 Index is a market capitalization weighted index of 500 large capitalization stocks commonly used to represent the U.S. equity market. Dividends are considered reinvested. You cannot invest directly in an index. (b) The Funds fiscal year ends March 31. (c) Performance results include the effect of the maximum 5.75% sales charge at the beginning of the period. (d) Assuming payment of the 1% maximum contingent deferred sales charge imposed on redemptions made within one year of purchase. |
COMPARISON OF CHANGE IN VALUE OF A $10,000 INVESTMENT IN
GABELLI SRI FUND, INC. (CLASS AAA SHARES) AND MSCI AC WORLD INDEX (Unaudited)
* | Past performance is not predictive of future results. The performance tables and graph do not reflect the deduction of taxes that a shareholder would pay on Fund distributions or the redemption of Fund shares. |
2
Gabelli SRI Fund, Inc. | ||||
Disclosure of Fund Expenses (Unaudited) | ||||
For the Six Month Period from October 1, 2014 through March 31, 2015 |
Expense Table |
3
Summary of Portfolio Holdings (Unaudited)
The following table presents portfolio holdings as a percent of net assets as of March 31, 2015:
Gabelli SRI Fund, Inc.
The Fund files a complete schedule of portfolio holdings with the Securities and Exchange Commission (the SEC) for the first and third quarters of each fiscal year on Form N-Q. Shareholders may obtain this information at www.gabelli.com or by calling the Fund at 800-GABELLI (800-422-3554). The Funds Form N-Q is available on the SECs website at www.sec.gov and may also be reviewed and copied at the SECs Public Reference Room in Washington, DC. Information on the operation of the Public Reference Room may be obtained by calling 800-SEC-0330.
Proxy Voting
The Fund files Form N-PX with its complete proxy voting record for the twelve months ended June 30, no later than August 31 of each year. A description of the Funds proxy voting policies, procedures, and how the Fund voted proxies relating to portfolio securities is available without charge, upon request, by (i) calling 800-GABELLI (800-422-3554); (ii) writing to The Gabelli Funds at One Corporate Center, Rye, NY 10580-1422; or (iii) visiting the SECs website at www.sec.gov.
4
Gabelli SRI Fund, Inc.
Schedule of Investments March 31, 2015
See accompanying notes to financial statements.
5
Gabelli SRI Fund, Inc.
Schedule of Investments (Continued) March 31, 2015
See accompanying notes to financial statements.
6
Gabelli SRI Fund, Inc.
See accompanying notes to financial statements.
7
Gabelli SRI Fund, Inc.
Statement of Changes in Net Assets
Year Ended March 31, 2015 |
Year Ended March 31, 2014 | |||||||||
Operations: |
||||||||||
Net investment loss |
$ | (212,637 | ) | $ | (71,986 | ) | ||||
Net realized gain on investments and foreign currency transactions |
5,037,178 | 5,689,600 | ||||||||
Net change in unrealized appreciation on investments and foreign currency translations |
2,389,452 | 2,073,403 | ||||||||
|
|
|
|
|||||||
Net Increase in Net Assets Resulting from Operations |
7,213,993 | 7,691,017 | ||||||||
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|
|
|
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Capital Share Transactions: |
||||||||||
Class AAA |
(4,231,430 | ) | (1,732,609 | ) | ||||||
Class A |
(7,131,801 | ) | (776,941 | ) | ||||||
Class C |
(261,100 | ) | 990,099 | |||||||
Class I |
10,393,104 | 2,157,610 | ||||||||
|
|
|
|
|||||||
Net Increase/(Decrease) in Net Assets from Capital Share Transactions |
(1,231,227 | ) | 638,159 | |||||||
|
|
|
|
|||||||
Redemption Fees |
| 1,114 | ||||||||
|
|
|
|
|||||||
Net Increase in Net Assets |
5,982,766 | 8,330,290 | ||||||||
Net Assets: |
||||||||||
Beginning of year |
70,046,163 | 61,715,873 | ||||||||
|
|
|
|
|||||||
End of year (including undistributed net investment income of $0 and $0, respectively) |
$ | 76,028,929 | $ | 70,046,163 | ||||||
|
|
|
|
See accompanying notes to financial statements.
8
Gabelli SRI Fund, Inc.
Financial Highlights
Selected data for a share of capital stock outstanding throughout each year:
Income (Loss) from Investment Operations |
Distributions | Ratios to Average Net Assets/Supplemental Data | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
Year |
Net Asset Value, Beginning of Year |
Net Investment Income (Loss)(a) |
Net Realized and Unrealized Gain (Loss) on Investments |
Total from Investment Operations |
Net Investment Income |
Net Realized Gain on Investments |
Return of Capital(b) |
Total Distributions |
Redemption Fees(a) |
Net Asset Value, End of Year |
Total Return |
Net Assets End of Year (in 000s) |
Net Investment Income (Loss) |
Expenses Net of Waivers/ Reimburse- ments |
Expenses Before Waivers/ Reim- bursements |
Portfolio Turnover Rate |
||||||||||||||||||||||||||||||||||||||||||||||||
Class AAA |
|
|||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
2015 |
$ | 13.49 | $ | (0.03 | ) | $ | 1.39 | $ | 1.36 | | | | | | $ | 14.85 | 10.08 | % | $ | 20,886 | (0.22 | )% | 1.64 | % | 1.64 | % | 28 | % | ||||||||||||||||||||||||||||||||||||
2014 |
12.02 | (0.01 | ) | 1.48 | 1.47 | | | | | $ | 0.00 | (b) | 13.49 | 12.23 | 22,988 | (0.05 | ) | 1.93 | (c) | 1.93 | (c) | 47 | ||||||||||||||||||||||||||||||||||||||||||
2013 |
10.78 | (0.03 | ) | 1.27 | 1.24 | | | | | 0.00 | (b) | 12.02 | 11.50 | 22,050 | (0.27 | ) | 2.00 | (c) | 2.00 | (c) | 27 | |||||||||||||||||||||||||||||||||||||||||||
2012 |
12.86 | (0.07 | ) | (1.93 | ) | (2.00 | ) | $ | (0.05 | ) | $ | (0.03 | ) | $ | (0.00 | ) | $ | (0.08 | ) | 0.00 | (b) | 10.78 | (15.50 | ) | 23,423 | (0.69 | ) | 2.00 | (c) | 2.00 | (c) | 152 | ||||||||||||||||||||||||||||||||
2011 |
10.44 | (0.09 | ) | 3.31 | 3.22 | | (0.80 | ) | | (0.80 | ) | 0.00 | (b) | 12.86 | 32.77 | 16,631 | (0.82 | ) | 2.00 | 2.86 | 365 | |||||||||||||||||||||||||||||||||||||||||||
Class A |
|
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2015 |
$ | 13.48 | $ | (0.03 | ) | $ | 1.39 | $ | 1.36 | | | | | | $ | 14.84 | 10.09 | % | $ | 21,190 | (0.19 | )% | 1.64 | % | 1.64 | % | 28 | % | ||||||||||||||||||||||||||||||||||||
2014 |
12.01 | (0.00 | )(b) | 1.47 | 1.47 | | | | | $ | 0.00 | (b) | 13.48 | 12.24 | 26,119 | (0.02 | ) | 1.93 | (c) | 1.93 | (c) | 47 | ||||||||||||||||||||||||||||||||||||||||||
2013 |
10.77 | (0.03 | ) | 1.27 | 1.24 | | | | | 0.00 | (b) | 12.01 | 11.51 | 24,026 | (0.32 | ) | 2.00 | (c) | 2.00 | (c) | 27 | |||||||||||||||||||||||||||||||||||||||||||
2012 |
12.86 | (0.08 | ) | (1.93 | ) | (2.01 | ) | $ | (0.05 | ) | $ | (0.03 | ) | $ | (0.00 | ) | $ | (0.08 | ) | 0.00 | (b) | 10.77 | (15.58 | ) | 21,083 | (0.70 | ) | 2.00 | (c) | 2.00 | (c) | 152 | ||||||||||||||||||||||||||||||||
2011 |
10.42 | (0.10 | ) | 3.34 | 3.24 | | (0.80 | ) | | (0.80 | ) | 0.00 | (b) | 12.86 | 33.05 | 14,391 | (0.88 | ) | 2.00 | 2.86 | 365 | |||||||||||||||||||||||||||||||||||||||||||
Class C |
|
|||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
2015 |
$ | 12.92 | $ | (0.13 | ) | $ | 1.34 | $ | 1.21 | | | | | | $ | 14.13 | 9.37 | % | $ | 10,919 | (0.98 | )% | 2.39 | % | 2.39 | % | 28 | % | ||||||||||||||||||||||||||||||||||||
2014 |
11.61 | (0.10 | ) | 1.41 | 1.31 | | | | | $ | 0.00 | (b) | 12.92 | 11.28 | 10,229 | (0.80 | ) | 2.68 | (c) | 2.68 | (c) | 47 | ||||||||||||||||||||||||||||||||||||||||||
2013 |
10.48 | (0.11 | ) | 1.24 | 1.13 | | | | | 0.00 | (b) | 11.61 | 10.78 | 8,225 | (1.03 | ) | 2.75 | (c) | 2.75 | (c) | 27 | |||||||||||||||||||||||||||||||||||||||||||
2012 |
12.55 | (0.15 | ) | (1.89 | ) | (2.04 | ) | | $ | (0.03 | ) | | $ | (0.03 | ) | 0.00 | (b) | 10.48 | (16.21 | ) | 8,112 | (1.41 | ) | 2.75 | (c) | 2.75 | (c) | 152 | ||||||||||||||||||||||||||||||||||||
2011 |
10.28 | (0.18 | ) | 3.25 | 3.07 | | (0.80 | ) | | (0.80 | ) | 0.00 | (b) | 12.55 | 31.80 | 4,532 | (1.66 | ) | 2.75 | 3.61 | 365 | |||||||||||||||||||||||||||||||||||||||||||
Class I |
|
|||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
2015 |
$ | 13.64 | $ | (0.01 | ) | $ | 1.43 | $ | 1.42 | | | | | | $ | 15.06 | 10.41 | % | $ | 23,034 | (0.09 | )% | 1.39 | % | 1.39 | % | 28 | % | ||||||||||||||||||||||||||||||||||||
2014 |
12.13 | 0.03 | 1.48 | 1.51 | | | | | $ | 0.00 | (b) | 13.64 | 12.45 | 10,710 | 0.21 | 1.68 | (c) | 1.68 | (c) | 47 | ||||||||||||||||||||||||||||||||||||||||||||
2013 |
10.84 | (0.01 | ) | 1.30 | 1.29 | | | | | 0.00 | (b) | 12.13 | 11.90 | 7,415 | (0.13 | ) | 1.75 | (c) | 1.75 | (c) | 27 | |||||||||||||||||||||||||||||||||||||||||||
2012 |
12.94 | (0.04 | ) | (1.96 | ) | (2.00 | ) | $ | (0.07 | ) | $ | (0.03 | ) | $ | (0.00 | ) | $ | (0.10 | ) | 0.00 | (b) | 10.84 | (15.37 | ) | 4,646 | (0.37 | ) | 1.75 | (c) | 1.75 | (c) | 152 | ||||||||||||||||||||||||||||||||
2011 |
10.47 | (0.07 | ) | 3.34 | 3.27 | | (0.80 | ) | | (0.80 | ) | 0.00 | (b) | 12.94 | 33.17 | 1,383 | (0.65 | ) | 1.75 | 2.61 | 365 |
| Total return represents aggregate total return of a hypothetical $1,000 investment at the beginning of the year and sold at the end of the year including reinvestment of distributions and does not reflect applicable sales charges. Total return excluding the effect of the contribution from the Funds Adviser for the year ended March 31, 2012 was (15.67)%, (15.70)%, (16.28)%, and (15.38)% for Class AAA, Class A, Class C, and Class I Shares, respectively. |
(a) | Per share amounts have been calculated using the average shares outstanding method. |
(b) | Amount represents less than $0.005 per share. |
(c) | Under an expense deferral agreement with the Adviser, the Adviser recovered from the Fund $130,192, $83,801, and $56,477 for the years ended March 31, 2014, 2013, and 2012, respectively, representing previously reimbursed expenses from the Adviser. Had such payments not been made, the expense ratios for the years ended March 31, 2014, 2013, and 2012 would have been 1.74%, 1.85%, and 1.91% (Class AAA and Class A), 2.49%, 2.60%, and 2.66% (Class C), and 1.49%, 1.60%, and 1.66% (Class I), respectively. |
See accompanying notes to financial statements.
9
Gabelli SRI Fund, Inc.
Notes to Financial Statements
1. Organization. The Gabelli SRI Fund, Inc. was incorporated on March 1, 2007 in Maryland. The Fund is a diversified open-end management investment company registered under the Investment Company Act of 1940, as amended (the 1940 Act). The Fund commenced investment operations on June 1, 2007. The Funds primary objective is to seek capital appreciation. The Fund seeks to achieve its objective by investing substantially all, and in any case no less than 80%, of its assets in common stocks and preferred stocks of companies that meet the Funds guidelines for social responsibility at the time of investment.
2. Significant Accounting Policies. As an investment company, the Fund follows the investment company accounting and reporting guidance, which is part of U.S. generally accepted accounting principles (GAAP) that may require the use of management estimates and assumptions in the preparation of its financial statements. Actual results could differ from those estimates. The following is a summary of significant accounting policies followed by the Fund in the preparation of its financial statements.
Security Valuation. Portfolio securities listed or traded on a nationally recognized securities exchange or traded in the U.S. over-the-counter market for which market quotations are readily available are valued at the last quoted sale price or a markets official closing price as of the close of business on the day the securities are being valued. If there were no sales that day, the security is valued at the average of the closing bid and asked prices or, if there were no asked prices quoted on that day, then the security is valued at the closing bid price on that day. If no bid or asked prices are quoted on such day, the security is valued at the most recently available price or, if the Board of Directors (the Board) so determines, by such other method as the Board shall determine in good faith to reflect its fair market value. Portfolio securities traded on more than one national securities exchange or market are valued according to the broadest and most representative market, as determined by Gabelli Funds, LLC (the Adviser).
Portfolio securities primarily traded on a foreign market are generally valued at the preceding closing values of such securities on the relevant market, but may be fair valued pursuant to procedures established by the Board if market conditions change significantly after the close of the foreign market, but prior to the close of business on the day the securities are being valued. Debt instruments with remaining maturities of sixty days or less that are not credit impaired are valued at amortized cost, unless the Board determines such amount does not reflect the securities fair value, in which case these securities will be fair valued as determined by the Board. Debt instruments having a maturity greater than sixty days for which market quotations are readily available are valued at the average of the latest bid and asked prices. If there were no asked prices quoted on such day, the security is valued using the closing bid price. U.S. government obligations with maturities greater than sixty days are normally valued using a model that incorporates market observable data such as reported sales of similar securities, broker quotes, yields, bids, offers, and reference data. Certain securities are valued principally using dealer quotations.
Securities and assets for which market quotations are not readily available are fair valued as determined by the Board. Fair valuation methodologies and procedures may include, but are not limited to: analysis and review of available financial and non-financial information about the company; comparisons with the valuation and changes in valuation of similar securities, including a comparison of foreign securities with the equivalent U.S. dollar value American Depositary Receipt securities at the close of the U.S. exchange; and evaluation of any other information that could be indicative of the value of the security.
10
Gabelli SRI Fund, Inc.
Notes to Financial Statements (Continued)
The inputs and valuation techniques used to measure fair value of the Funds investments are summarized into three levels as described in the hierarchy below:
| Level 1 quoted prices in active markets for identical securities; |
| Level 2 other significant observable inputs (including quoted prices for similar securities, interest rates, prepayment speeds, credit risk, etc.); and |
| Level 3 significant unobservable inputs (including the Boards determinations as to the fair value of investments). |
A financial instruments level within the fair value hierarchy is based on the lowest level of any input both individually and in the aggregate that is significant to the fair value measurement. The inputs or methodology used for valuing securities are not necessarily an indication of the risk associated with investing in those securities. The summary of the Funds investments in securities by inputs used to value the Funds investments as of March 31, 2015 is as follows:
Valuation Inputs | |||||||||||||||
Level 1 Quoted Prices |
Level 2 Other Significant Observable Inputs |
Total Market Value at 3/31/15 | |||||||||||||
INVESTMENTS IN SECURITIES: |
|||||||||||||||
ASSETS (Market Value): |
|||||||||||||||
Common Stocks (a) |
$ | 73,549,407 | | $ | 73,549,407 | ||||||||||
U.S. Government Obligations |
| $ | 1,990,809 | 1,990,809 | |||||||||||
TOTAL INVESTMENTS IN SECURITIES ASSETS |
$ | 73,549,407 | $ | 1,990,809 | $ | 75,540,216 |
(a) | Please refer to the Schedule of Investments for the industry classifications of these portfolio holdings. |
The Fund did not have transfers between Level 1 and Level 2 during the year ended March 31, 2015. The Funds policy is to recognize transfers among Levels as of the beginning of the reporting period.
There were no Level 3 investments at March 31, 2015 or 2014.
Additional Information to Evaluate Qualitative Information.
General. The Fund uses recognized industry pricing services approved by the Board and unaffiliated with the Adviser to value most of its securities, and uses broker quotes provided by market makers of securities not valued by these and other recognized pricing sources. Several different pricing feeds are received to value domestic equity securities, international equity securities, preferred equity securities, and fixed income securities. The data within these feeds is ultimately sourced from major stock exchanges and trading systems where these securities trade. The prices supplied by external sources are checked by obtaining quotations or actual transaction prices from market participants. If a price obtained from the pricing source is deemed unreliable, prices will be sought from another pricing service or from a broker/dealer that trades that security or similar securities.
Fair Valuation. Fair valued securities may be common and preferred equities, warrants, options, rights, and fixed income obligations. Where appropriate, Level 3 securities are those for which market quotations are not available, such as securities not traded for several days, or for which current bids are not available, or which are restricted as to transfer. Among the factors to be considered to fair value a security are recent prices of comparable securities that are publicly traded, reliable prices of securities not publicly traded, the use of valuation models, current analyst reports, valuing the income or cash flow of the issuer, or cost if the preceding factors do not apply. The circumstances of Level 3 securities are frequently monitored to determine if fair valuation measures continue to apply.
11
Gabelli SRI Fund, Inc.
Notes to Financial Statements (Continued)
The Adviser reports quarterly to the Board the results of the application of fair valuation policies and procedures. These include back testing the prices realized in subsequent trades of these fair valued securities to fair values previously recognized.
Derivative Financial Instruments. The Fund may engage in various portfolio investment strategies by investing in a number of derivative financial instruments for the purposes of increasing the income of the Fund, hedging against changes in the value of its portfolio securities and in the value of securities it intends to purchase, or hedging against a specific transaction with respect to either the currency in which the transaction is denominated or another currency. Investing in certain derivative financial instruments, including participation in the options, futures, or swap markets, entails certain execution, liquidity, hedging, tax, and securities, interest, credit, or currency market risks. Losses may arise if the Advisers prediction of movements in the direction of the securities, foreign currency, and interest rate markets is inaccurate. Losses may also arise if the counterparty does not perform its duties under a contract, or that, in the event of default, the Fund may be delayed in or prevented from obtaining payments or other contractual remedies owed to it under derivative contracts. The creditworthiness of the counterparties is closely monitored in order to minimize these risks. Participation in derivative transactions involves investment risks, transaction costs, and potential losses to which the Fund would not be subject absent the use of these strategies. The consequences of these risks, transaction costs, and losses may have a negative impact on the Funds ability to pay distributions.
The Funds derivative contracts held at March 31, 2015, if any, are not accounted for as hedging instruments under GAAP and are disclosed in the Schedule of Investments together with the related counterparty.
Options. The Fund may purchase or write call or put options on securities or indices for the purpose of increasing the income of the Fund. As a writer of put options, the Fund receives a premium at the outset and then bears the risk of unfavorable changes in the price of the financial instrument underlying the option. The Fund would incur a loss if the price of the underlying financial instrument decreases between the date the option is written and the date on which the option is terminated. The Fund would realize a gain, to the extent of the premium, if the price of the financial instrument increases between those dates.
As a purchaser of put options, the Fund pays a premium for the right to sell to the seller of the put option the underlying security at a specified price. The seller of the put has the obligation to purchase the underlying security upon exercise at the exercise price. If the price of the underlying security declines, the Fund would realize a gain upon sale or exercise. If the price of the underlying security increases or stays the same, the Fund would realize a loss upon sale or at the expiration date, but only to the extent of the premium paid.
If a written call option is exercised, the premium is added to the proceeds from the sale of the underlying security in determining whether there has been a realized gain or loss. If a written put option is exercised, the premium reduces the cost basis of the security. In the case of call options, the exercise prices are referred to as in-the-money, at-the-money, and out-of-the- money, respectively. The Fund may write (a) in-the-money call options when the Adviser expects that the price of the underlying security will remain stable or decline during the option period, (b) at-the-money call options when the Adviser expects that the price of the underlying security will remain stable, decline, or advance moderately during the option period, and (c) out-of-the-money
12
Gabelli SRI Fund, Inc.
Notes to Financial Statements (Continued)
call options when the Adviser expects that the premiums received from writing the call option will be greater than the appreciation in the price of the underlying security above the exercise price. By writing a call option, the Fund limits its opportunity to profit from any increase in the market value of the underlying security above the exercise price of the option. Out-of-the-money, at-the-money, and in-the-money put options (the reverse of call options as to the relation of exercise price to market price) may be utilized in the same market environments that such call options are used in equivalent transactions. At March 31, 2015, the Fund held no investments in option contracts.
Foreign Currency Translations. The books and records of the Fund are maintained in U.S. dollars. Foreign currencies, investments, and other assets and liabilities are translated into U.S. dollars at current exchange rates. Purchases and sales of investment securities, income, and expenses are translated at the exchange rate prevailing on the respective dates of such transactions. Unrealized gains and losses that result from changes in foreign exchange rates and/or changes in market prices of securities have been included in unrealized appreciation/depreciation on investments and foreign currency translations. Net realized foreign currency gains and losses resulting from changes in exchange rates include foreign currency gains and losses between trade date and settlement date on investment securities transactions, foreign currency transactions, and the difference between the amounts of interest and dividends recorded on the books of the Fund and the amounts actually received. The portion of foreign currency gains and losses related to fluctuation in exchange rates between the initial purchase trade date and subsequent sale trade date is included in realized gain/(loss) on investments.
Foreign Securities. The Fund may directly purchase securities of foreign issuers. Investing in securities of foreign issuers involves special risks not typically associated with investing in securities of U.S. issuers. The risks include possible revaluation of currencies, the inability to repatriate funds, less complete financial information about companies, and possible future adverse political and economic developments. Moreover, securities of many foreign issuers and their markets may be less liquid and their prices more volatile than securities of comparable U.S. issuers.
Foreign Taxes. The Fund may be subject to foreign taxes on income, gains on investments, or currency repatriation, a portion of which may be recoverable. The Fund will accrue such taxes and recoveries as applicable, based upon its current interpretation of tax rules and regulations that exist in the markets in which it invests.
Restricted Securities. The Fund may invest up to 15% of its net assets in securities for which the markets are restricted. Restricted securities include securities whose disposition is subject to substantial legal or contractual restrictions. The sale of restricted securities often requires more time and results in higher brokerage charges or dealer discounts and other selling expenses than does the sale of securities eligible for trading on national securities exchanges or in the over-the-counter markets. Restricted securities may sell at a price lower than similar securities that are not subject to restrictions on resale. Securities freely saleable among qualified institutional investors under special rules adopted by the SEC may be treated as liquid if they satisfy liquidity standards established by the Board. The continued liquidity of such securities is not as well assured as that of publicly traded securities, and accordingly the Board will monitor their liquidity. There were no restricted securities at March 31, 2015.
13
Gabelli SRI Fund, Inc.
Notes to Financial Statements (Continued)
Securities Transactions and Investment Income. Securities transactions are accounted for on the trade date with realized gain/(loss) on investments determined by using the identified cost method. Interest income (including amortization of premium and accretion of discount) is recorded on the accrual basis. Premiums and discounts on debt securities are amortized using the effective yield to maturity method. Dividend income is recorded on the ex-dividend date, except for certain dividends from foreign securities that are recorded as soon after the ex-dividend date as the Fund becomes aware of such dividends.
Determination of Net Asset Value and Calculation of Expenses. Certain administrative expenses are common to, and allocated among, various affiliated funds. Such allocations are made on the basis of each funds average net assets or other criteria directly affecting the expenses as determined by the Adviser pursuant to procedures established by the Board.
In calculating the NAV per share of each class, investment income, realized and unrealized gains and losses, redemption fees, and expenses other than class specific expenses are allocated daily to each class of shares based upon the proportion of net assets of each class at the beginning of each day. Distribution expenses are borne solely by the class incurring the expense.
Distributions to Shareholders. Distributions to shareholders are recorded on the ex-dividend date. Distributions to shareholders are based on income and capital gains as determined in accordance with federal income tax regulations, which may differ from income and capital gains as determined under GAAP. These differences are primarily due to differing treatments of income and gains on various investment securities and foreign currency transactions held by the Fund, timing differences, and differing characterizations of distributions made by the Fund. Distributions from net investment income for federal income tax purposes include net realized gains on foreign currency transactions. These book/tax differences are either temporary or permanent in nature. To the extent these differences are permanent, adjustments are made to the appropriate capital accounts in the period when the differences arise. Permanent differences were primarily due to the write-off of the current year net operating loss and the tax treatment of currency gains and losses. These reclassifications have no impact on the NAV of the Fund. For the year ended March 31, 2015, reclassifications were made to decrease accumulated net investment loss by $72,414, and increase accumulated net realized gain on investments and foreign currency transactions by $3,397, with an offsetting adjustment to paid-in capital.
No distributions were made during the year ended March 31, 2015 or 2014.
Provision for Income Taxes. The Fund intends to continue to qualify as a regulated investment company under Subchapter M of the Internal Revenue Code of 1986, as amended (the Code). It is the policy of the Fund to comply with the requirements of the Code applicable to regulated investment companies and to distribute substantially all of its net investment company taxable income and net capital gains. Therefore, no provision for federal income taxes is required.
At March 31, 2015, the components of accumulated earnings/losses on a tax basis were as follows:
Undistributed long term capital gains |
$ | 205,845 | ||
Net unrealized appreciation on investments and foreign currency translations |
14,715,840 | |||
Qualified late year loss deferral |
(140,223 | ) | ||
|
|
|||
Total |
$ | 14,781,462 | ||
|
|
14
Gabelli SRI Fund, Inc.
Notes to Financial Statements (Continued)
The Fund is permitted to carry capital losses forward for an unlimited period. Capital losses that are carried forward will retain their character as either short term or long term capital losses.
During the year ended March 31, 2015, the Fund utilized capital loss carryforwards of $4,754,255.
At March 31, 2015, the temporary differences between book basis and tax basis unrealized appreciation on investments were due to deferral of losses from wash sales for tax purposes.
The following summarizes the tax cost of investments and the related net unrealized appreciation at March 31, 2015:
Cost | Gross Unrealized Appreciation |
Gross Unrealized Depreciation |
Net Unrealized Appreciation | |||||||||||||||||
Investments |
$ | 60,819,567 | $ | 15,561,060 | $ | (840,411 | ) | $ | 14,720,649 |
The Fund is required to evaluate tax positions taken or expected to be taken in the course of preparing the Funds tax returns to determine whether the tax positions are more-likely-than-not of being sustained by the applicable tax authority. Income tax and related interest and penalties would be recognized by the Fund as tax expense in the Statement of Operations if the tax positions were deemed not to meet the more-likely-than-not threshold. For the year ended March 31, 2015, the Fund did not incur any income tax, interest, or penalties. As of March 31, 2015, the Adviser has reviewed all open tax years and concluded that there was no impact to the Funds net assets or results of operations. The Funds federal and state tax returns for the prior three fiscal years remain open, subject to examination. On an ongoing basis, the Adviser will monitor the Funds tax positions to determine if adjustments to this conclusion are necessary.
3. Investment Advisory Agreement and Other Transactions. The Fund has entered into an investment advisory agreement (the Advisory Agreement) with the Adviser which provides that the Fund will pay the Adviser a fee, computed daily and paid monthly, at the annual rate of 1.00% of the value of its average daily net assets. In accordance with the Advisory Agreement, the Adviser provides a continuous investment program for the Funds portfolio, oversees the administration of all aspects of the Funds business and affairs, and pays the compensation of all Officers and Directors of the Fund who are affiliated persons of the Adviser.
The Adviser has contractually agreed to waive its investment advisory fee and/or to reimburse expenses of the Fund to the extent necessary to maintain the annualized total operating expenses of the Fund (excluding brokerage, interest, taxes, and extraordinary expenses) until at least July 31, 2015 at no more than 2.00%, 2.00%, 2.75%, and 1.75% of the value of the Funds average daily net assets for Class AAA, Class A, Class C, and Class I, respectively. In addition, the Fund has agreed, during the three year period following any waiver or reimbursement by the Adviser, to repay such amount to the extent, after giving effect to the repayment, such adjusted annualized total operating expenses of the Fund would not exceed the foregoing limitations. The agreements are renewable annually.
The Fund pays each Director who is not considered an affiliated person an annual retainer of $3,000 plus $500 for each Board meeting attended. Each Director is reimbursed by the Fund for any out of pocket expenses incurred in attending meetings. All Board committee members receive $500 per meeting attended and the Chairman of each committee and the Lead Director each receive an annual fee of $1,000. A Director may receive a single meeting fee, allocated among the participating funds, for participation in certain meetings held on behalf of multiple funds. Directors who are directors or employees of the Adviser or an affiliated company receive no compensation or expense reimbursement from the Fund.
15
Gabelli SRI Fund, Inc.
Notes to Financial Statements (Continued)
4. Distribution Plan. The Funds Board has adopted a distribution plan (the Plan) for each class of shares, except for Class I Shares, pursuant to Rule 12b-1 under the 1940 Act. Under the Class AAA, Class A, and Class C Share Plans, payments are authorized to G.distributors, LLC (the Distributor), an affiliate of the Adviser, at annual rates of 0.25%, 0.25%, and 1.00%, respectively, of the average daily net assets of those classes, the annual limitations under each Plan. Such payments are accrued daily and paid monthly.
5. Portfolio Securities. Purchases and sales of securities during the year ended March 31, 2015, other than short term securities and U.S. Government obligations, aggregated $19,913,177 and $22,031,908, respectively.
6. Transactions with Affiliates. During the year ended March 31, 2015, the Fund paid brokerage commissions on security trades of $9,992 to G.research, Inc., an affiliate of the Adviser. Additionally, the Distributor retained a total of $7,514 from investors representing commissions (sales charges and underwriting fees) on sales and redemptions of Fund shares.
The cost of calculating the Funds NAV per share is a Fund expense pursuant to the Advisory Agreement. During the year ended March 31, 2015, the Fund paid or accrued $45,000 to the Adviser in connection with the cost of computing the Funds NAV.
7. Capital Stock. The Fund offers four classes of shares Class AAA Shares, Class A Shares, Class C Shares, and Class I Shares. Class AAA Shares are offered without a sales charge only to investors who acquire them directly from the Distributor, through selected broker/dealers, or the transfer agent. Class I Shares are offered without a sales charge, directly through the Distributor, or brokers that have entered into selling agreements specifically with respect to Class I Shares. Class A Shares are subject to a maximum front-end sales charge of 5.75%. Class C Shares are subject to a 1.00% contingent deferred sales charge for one year after purchase.
The Fund imposes a redemption fee of 2.00% on all classes of shares that are redeemed or exchanged on or before the seventh day after the date of a purchase. The redemption fee is deducted from the proceeds otherwise payable to the redeeming shareholders and is retained by the Fund as an increase in paid-in capital. The redemption fees retained by the Fund during the years ended March 31, 2015 and 2014, if any, can be found in the Statement of Changes in Net Assets under Redemption Fees.
16
Gabelli SRI Fund, Inc.
Notes to Financial Statements (Continued)
Transactions in shares of capital stock were as follows:
Year Ended March 31, 2015 |
Year Ended March 31, 2014 |
|||||||||||||||
Shares | Amount | Shares | Amount | |||||||||||||
Class AAA |
||||||||||||||||
Shares sold |
113,647 | $ | 1,583,459 | 342,130 | $ | 4,285,156 | ||||||||||
Shares redeemed |
(412,037 | ) | (5,814,889 | ) | (472,060 | ) | (6,017,765 | ) | ||||||||
|
|
|
|
|
|
|
|
|||||||||
Net decrease |
(298,390 | ) | $ | (4,231,430 | ) | (129,930 | ) | $ | (1,732,609 | ) | ||||||
|
|
|
|
|
|
|
|
|||||||||
Class A |
||||||||||||||||
Shares sold |
210,006 | $ | 2,943,862 | 536,956 | $ | 6,727,613 | ||||||||||
Shares redeemed |
(720,647 | ) | (10,075,663 | ) | (599,128 | ) | (7,504,554 | ) | ||||||||
|
|
|
|
|
|
|
|
|||||||||
Net decrease |
(510,641 | ) | $ | (7,131,801 | ) | (62,172 | ) | $ | (776,941 | ) | ||||||
|
|
|
|
|
|
|
|
|||||||||
Class C |
||||||||||||||||
Shares sold |
143,637 | $ | 1,935,354 | 220,555 | $ | 2,670,011 | ||||||||||
Shares redeemed |
(162,271 | ) | (2,196,454 | ) | (137,669 | ) | (1,679,912 | ) | ||||||||
|
|
|
|
|
|
|
|
|||||||||
Net increase/(decrease) |
(18,634 | ) | $ | (261,100 | ) | 82,886 | $ | 990,099 | ||||||||
|
|
|
|
|
|
|
|
|||||||||
Class I |
||||||||||||||||
Shares sold |
1,109,346 | $ | 15,632,733 | 310,417 | $ | 3,927,839 | ||||||||||
Shares redeemed |
(365,033 | ) | (5,239,629 | ) | (136,554 | ) | (1,770,229 | ) | ||||||||
|
|
|
|
|
|
|
|
|||||||||
Net increase |
744,313 | $ | 10,393,104 | 173,863 | $ | 2,157,610 | ||||||||||
|
|
|
|
|
|
|
|
8. Indemnifications. The Fund enters into contracts that contain a variety of indemnifications. The Funds maximum exposure under these arrangements is unknown. However, the Fund has not had prior claims or losses pursuant to these contracts. Management has reviewed the Funds existing contracts and expects the risk of loss to be remote.
9. Subsequent Events. Management has evaluated the impact on the Fund of all subsequent events occurring through the date the financial statements were issued and has determined that there were no subsequent events requiring recognition or disclosure in the financial statements.
17
Gabelli SRI Fund, Inc.
Report of Independent Registered Public Accounting Firm
To the Board of Directors and Shareholders of
Gabelli SRI Fund, Inc.:
In our opinion, the accompanying statement of assets and liabilities, including the schedule of investments, and the related statements of operations and of changes in net assets and the financial highlights present fairly, in all material respects, the financial position of Gabelli SRI Fund, Inc. (the Fund) at March 31, 2015, the results of its operations for the year then ended, the changes in its net assets for each of the two years in the period then ended and the financial highlights for each of the five years in the period then ended, in conformity with accounting principles generally accepted in the United States of America. These financial statements and financial highlights (hereafter referred to as financial statements) are the responsibility of the Funds management. Our responsibility is to express an opinion on these financial statements based on our audits. We conducted our audits of these financial statements in accordance with the standards of the Public Company Accounting Oversight Board (United States). Those standards require that we plan and perform the audit to obtain reasonable assurance about whether the financial statements are free of material misstatement. An audit includes examining, on a test basis, evidence supporting the amounts and disclosures in the financial statements, assessing the accounting principles used and significant estimates made by management, and evaluating the overall financial statement presentation. We believe that our audits, which included confirmation of securities at March 31, 2015 by correspondence with the custodian and broker, provide a reasonable basis for our opinion.
PricewaterhouseCoopers LLP
New York, New York
May 28, 2015
18
Gabelli SRI Fund, Inc.
Additional Fund Information (Unaudited)
The business and affairs of the Fund are managed under the direction of the Funds Board of Directors. Information pertaining to the Directors and officers of the Fund is set forth below. The Funds Statement of Additional Information includes additional information about the Funds Directors and is available without charge, upon request, by calling 800-GABELLI (800-422-3554) or by writing to Gabelli SRI Fund, Inc. at One Corporate Center, Rye, NY 10580-1422.
Name, Position(s) and Age |
Term of Office |
Number of Funds |
Principal Occupation(s) During Past Five Years |
Other Directorships Held by Director3 | ||||
INTERESTED DIRECTOR4: | ||||||||
Mario J. Gabelli, CFA Director and Chief Investment Officer Age: 72 |
Since 2007 | 28 | Chairman, Chief Executive Officer, and Chief Investment OfficerValue Portfolios of GAMCO Investors, Inc., and Chief Investment Officer Value Portfolios of Gabelli Funds, LLC and GAMCO Asset Management Inc.; Director/ Trustee or Chief Investment Officer of other registered investment companies in the Gabelli/ GAMCO Fund Complex; Chief Executive Officer of GGCP, Inc. | Director of Morgan Group Holdings, Inc. (holding company); Chairman of the Board and Chief Executive Officer of LICT Corp. (multimedia and communication services); Director of CIBL, Inc. (broadcasting and wireless communications); Director of ICTC Group, Inc. (communications); Director of RLJ Acquisition Inc. (blank check company) (2011-2012) | ||||
NON-INTERESTED DIRECTORS5: |
||||||||
Clarence A. Davis Director Age: 73 |
Since 2007 | 2 | Former Chief Executive Officer of Nestor, Inc. (2007-2009); Former Chief Operating Officer (2000-2005) and Chief Financial Officer (1999- 2000) of the American Institute of Certified Public Accountants | Director of Telephone & Data Systems, Inc. (telephone services); Director of Pennichuck Corp. (water supply) (2009-2012) | ||||
Vincent D. Enright Director Age: 71 |
Since 2007 | 17 | Former Senior Vice President and Chief Financial Officer of KeySpan Corporation (public utility)(1994-1998) | Director of Echo Therapeutics, Inc. (therapeutics and diagnostics) (2008-2014); Director of the LGL Group, Inc. (diversified manufacturing) (2011-2014) | ||||
William F. Heitmann Director Age: 66 |
Since 2012 | 3 | Senior Vice President of Finance, Verizon Communications, and President, Verizon Investment Management (1971-2010) | Director and Audit Committee Chair of DRS Technologies (defense electronic systems) | ||||
Anthonie C. van Ekris Director Age: 80 |
Since 2007 | 20 | Chairman and Chief Executive Officer of BALMAC International, Inc. (commodities and futures trading) | |
19
Gabelli SRI Fund, Inc.
Additional Fund Information (Continued) (Unaudited)
Name, Position(s) Address1 and Age |
Term of Office and Length of Time Served2 |
Principal Occupation(s) During Past Five Years | ||
OFFICERS: |
||||
Bruce N. Alpert President Age: 63 |
Since 2007 | Executive Vice President and Chief Operating Officer of Gabelli Funds, LLC since 1988; and an Officer of registered investment companies in the Gabelli/GAMCO Fund Complex; Director of Teton Advisors, Inc. 1998-2012; Chairman of Teton Advisors, Inc. 2008-2010; President of Teton Advisors, Inc. 1998-2008; Senior Vice President of GAMCO Investors, Inc. since 2008 | ||
Andrea R. Mango Secretary Age: 42 |
Since November 2013 | Counsel of Gabelli Funds, LLC; Corporate Vice President within the Corporate Compliance Department of New York Life Insurance Company 2011-2013; Vice President and Counsel of Deutsche Bank 2006-2011 | ||
Agnes Mullady Treasurer Age: 56 |
Since 2007 | President and Chief Operating Officer of the Fund Division of Gabelli Funds, LLC since September 2010; Chief Executive Officer of G.distributors, LLC since 2011; Senior Vice President of GAMCO Investors, Inc. since 2009; Vice President of Gabelli Funds, LLC since 2007; Officer of all of the registered investment companies in the Gabelli/GAMCO Fund Complex | ||
Richard J. Walz Chief Compliance Officer Age: 55 |
Since November 2013 | Chief Compliance Officer of the Gabelli/GAMCO Fund Complex; Chief Compliance Officer of AEGON USA Investment Management LLC 2011-2013; Chief Compliance Officer of Cutwater Asset Management 2004-2011 |
1 | Address: One Corporate Center, Rye, NY 10580-1422, unless otherwise noted. |
2 | Each Director will hold office for an indefinite term until the earliest of (i) the next meeting of shareholders, if any, called for the purpose of considering the election or re-election of such Director and until the election and qualification of his or her successor, if any, elected at such meeting, or (ii) the date a Director resigns or retires, or a Director is removed by the Board of Directors or shareholders, in accordance with the Funds By-Laws and Articles of Incorporation. Each officer will hold office for an indefinite term until the date he or she resigns or retires or until his or her successor is elected and qualified. |
3 | This column includes only directorships of companies required to report to the SEC under the Securities Exchange Act of 1934, as amended, i.e., public companies, or other investment companies registered under the 1940 Act. |
4 | Interested person of the Fund as defined in the 1940 Act. Mr. Gabelli is considered an interested person because of his affiliation with Gabelli Funds, LLC which acts as the Funds investment adviser. |
5 | Directors who are not interested persons are considered Independent Directors. |
20
Gabelli/GAMCO Funds and Your Personal Privacy
|
Who are we?
The Gabelli/GAMCO Funds are investment companies registered with the Securities and Exchange Commission under the Investment Company Act of 1940. We are managed by Gabelli Funds, LLC and GAMCO Asset Management Inc., which are affiliated with GAMCO Investors, Inc. GAMCO Investors, Inc. is a publicly held company that has subsidiaries that provide investment advisory or brokerage services for a variety of clients.
What kind of non-public information do we collect about you if you become a fund shareholder?
If you apply to open an account directly with us, you will be giving us some non-public information about yourself. The non-public information we collect about you is:
| Information you give us on your application form. This could include your name, address, telephone number, social security number, bank account number, and other information. |
| Information about your transactions with us, any transactions with our affiliates, and transactions with the entities we hire to provide services to you. This would include information about the shares that you buy or redeem. If we hire someone else to provide services like a transfer agent we will also have information about the transactions that you conduct through them. |
What information do we disclose and to whom do we disclose it?
We do not disclose any non-public personal information about our customers or former customers to anyone other than our affiliates, our service providers who need to know such information, and as otherwise permitted by law. If you want to find out what the law permits, you can read the privacy rules adopted by the Securities and Exchange Commission. They are in volume 17 of the Code of Federal Regulations, Part 248. The Commission often posts information about its regulations on its website, www.sec.gov.
What do we do to protect your personal information?
We restrict access to non-public personal information about you to the people who need to know that information in order to provide services to you or the fund and to ensure that we are complying with the laws governing the securities business. We maintain physical, electronic, and procedural safeguards to keep your personal information confidential.
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GABELLI SRI FUND, INC.
One Corporate Center
Rye, NY 10580-1422
Portfolio Management Team Biographies
Christopher C. Desmarais joined GAMCO Investors, Inc. in 1993. Currently he is a Managing Director of GAMCO Asset Management, Inc., a portfolio manager of Gabelli Funds, LLC, as well as the Director of Socially Responsive Investments. He is a co-portfolio manager of the Fund, and his responsibilities also include marketing and client service of GAMCOs Value, Growth, and International capabilities for institutional, endowment, and family office clients as well as direct oversight of all of the Firms SRI equity products. He is a graduate of Fairfield University with a B.A. in Economics.
Christopher J. Marangi joined Gabelli in 2003 as a research analyst. He currently serves as a portfolio manager of Gabelli Funds, LLC and manages several funds within the Gabelli/GAMCO Fund Complex. Mr. Marangi graduated magna cum laude and Phi Beta Kappa with a BA in Political Economy from Williams College and holds an MBA with honors from Columbia Business School.
Kevin V. Dreyer joined Gabelli in 2005 as a research analyst covering companies within the consumer sector. He currently serves as a portfolio manager of Gabelli Funds, LLC and manages several funds within the Gabelli/GAMCO Fund Complex. Mr. Dreyer received a BSE from the University of Pennsylvania and an MBA from Columbia Business School.
We have separated the portfolio managers commentary from the financial statements and investment portfolio due to corporate governance regulations stipulated by the Sarbanes-Oxley Act of 2002. We have done this to ensure that the content of the portfolio managers commentary is unrestricted. The financial statements and investment portfolio are mailed separately from the commentary. Both the commentary and the financial statements, including the portfolio of investments, will be available on our website at www.gabelli.com.
Item 2. Code of Ethics.
(a) | The registrant, as of the end of the period covered by this report, has adopted a code of ethics that applies to the registrants principal executive officer, principal financial officer, principal accounting officer or controller, or persons performing similar functions, regardless of whether these individuals are employed by the registrant or a third party. |
(c) | There have been no amendments, during the period covered by this report, to a provision of the code of ethics that applies to the registrants principal executive officer, principal financial officer, principal accounting officer or controller, or persons performing similar functions, regardless of whether these individuals are employed by the registrant or a third party, and that relates to any element of the code of ethics description. |
(d) | The registrant has not granted any waivers, including an implicit waiver, from a provision of the code of ethics that applies to the registrants principal executive officer, principal financial officer, principal accounting officer or controller, or persons performing similar functions, regardless of whether these individuals are employed by the registrant or a third party, that relates to one or more of the items set forth in paragraph (b) of this items instructions. |
Item 3. Audit Committee Financial Expert.
As of the end of the period covered by the report, the registrants board of directors has determined that Clarence A. Davis and Vincent D. Enright are qualified to serve as audit committee financial experts serving on its audit committee and that they are independent, as defined by Item 3 of Form N-CSR.
Item 4. Principal Accountant Fees and Services.
Audit Fees
(a) | The aggregate fees billed for each of the last two fiscal years for professional services rendered by the principal accountant for the audit of the registrants annual financial statements or services that are normally provided by the accountant in connection with statutory and regulatory filings or engagements for those fiscal years are $22,000 for 2014 and $22,660 for 2015. |
Audit-Related Fees
(b) | The aggregate fees billed in each of the last two fiscal years for assurance and related services by the principal accountant that are reasonably related to the performance of the audit of the registrants financial statements and are not reported under paragraph (a) of this Item are $0 for 2014 and $0 for 2015. |
Tax Fees
(c) | The aggregate fees billed in each of the last two fiscal years for professional services rendered by the principal accountant for tax compliance, tax advice, and tax planning are $3,640 for 2014 and $3,760 for 2015. Tax fees represent tax compliance services provided in connection with the review of the Registrants tax returns. |
All Other Fees
(d) | The aggregate fees billed in each of the last two fiscal years for products and services provided by the principal accountant, other than the services reported in paragraphs (a) through (c) of this Item are $0 for 2014 and $0 for 2015. |
(e)(1) | Disclose the audit committees pre-approval policies and procedures described in paragraph (c)(7) of Rule 2-01 of Regulation S-X. |
Pre-Approval Policies and Procedures. The Audit Committee (Committee) of the registrant is responsible for pre-approving (i) all audit and permissible non-audit services to be provided by the independent registered public accounting firm to the registrant and (ii) all permissible non-audit services to be provided by the independent registered public accounting firm to the Adviser, Gabelli Funds, LLC, and any affiliate of Gabelli Funds, LLC (Gabelli) that provides services to the registrant (a Covered Services Provider) if the independent registered public accounting firms engagement related directly to the operations and financial reporting of the registrant. The Committee may delegate its responsibility to pre-approve any such audit and permissible non-audit services to the Chairperson of the Committee, and the Chairperson must report to the Committee, at its next regularly scheduled meeting after the Chairpersons pre-approval of such services, his or her decision(s). The Committee may also establish detailed pre-approval policies and procedures for pre-approval of such services in accordance with applicable laws, including the delegation of some or all of the Committees pre-approval responsibilities to the other persons (other than Gabelli or the registrants officers). Pre-approval by the Committee of any permissible non-audit services is not required so long as: (i) the permissible non-audit services were not recognized by the registrant at the time of the engagement to be non-audit services; and (ii) such services are promptly brought to the attention of the Committee and approved by the Committee or Chairperson prior to the completion of the audit.
(e)(2) | The percentage of services described in each of paragraphs (b) through (d) of this Item that were approved by the audit committee pursuant to paragraph (c)(7)(i)(C) of Rule 2-01 of Regulation S-X are as follows: |
(b) N/A
(c) 100%
(d) N/A
(f) | The percentage of hours expended on the principal accountants engagement to audit the registrants financial statements for the most recent fiscal year that were attributed to work performed by persons other than the principal accountants full-time, permanent employees was 0%. |
(g) | The aggregate non-audit fees billed by the registrants accountant for services rendered to the registrant, and rendered to the registrants investment adviser (not including any sub-adviser whose role is primarily portfolio management and is subcontracted with or overseen by another investment adviser), and any entity controlling, controlled by, or under common control with the adviser that provides ongoing services to the registrant for each of the last two fiscal years of the registrant was $0 for 2014 and $0 for 2015. |
(h) | The registrants audit committee of the board of directors has considered whether the provision of non-audit services that were rendered to the registrants investment adviser (not including any sub-adviser whose role is primarily portfolio management and is subcontracted with or overseen by another investment adviser), and any entity controlling, controlled by, or under common control with the investment adviser that provides ongoing services to the registrant that were not pre-approved pursuant to paragraph (c)(7)(ii) of Rule 2-01 of Regulation S-X is compatible with maintaining the principal accountants independence. |
Item 5. Audit Committee of Listed registrants.
Not applicable.
Item 6. Investments.
(a) | Schedule of Investments in securities of unaffiliated issuers as of the close of the reporting period is included as part of the report to shareholders filed under Item 1 of this form. |
(b) | Not applicable. |
Item 7. Disclosure of Proxy Voting Policies and Procedures for Closed-End Management Investment Companies.
Not applicable.
Item 8. Portfolio Managers of Closed-End Management Investment Companies.
Not applicable.
Item 9. Purchases of Equity Securities by Closed-End Management Investment Company and Affiliated Purchasers.
Not applicable.
Item 10. Submission of Matters to a Vote of Security Holders.
There have been no material changes to the procedures by which the shareholders may recommend nominees to the registrants board of directors, where those changes were implemented after the registrant last provided disclosure in response to the requirements of Item 407(c)(2)(iv) of Regulation S-K (17 CFR 229.407) (as required by Item 22(b)(15) of Schedule 14A (17 CFR 240.14a-101)), or this Item.
Item 11. Controls and Procedures.
(a) | The registrants principal executive and principal financial officers, or persons performing similar functions, have concluded that the registrants disclosure controls and procedures (as defined in Rule 30a-3(c) under the Investment Company Act of 1940, as amended (the 1940 Act) (17 CFR 270.30a-3(c))) are effective, as of a date within 90 days of the filing date of the report that includes the disclosure required by this paragraph, based on their evaluation of these controls and procedures required by Rule 30a-3(b) under the 1940 Act (17 CFR 270.30a-3(b)) and Rules 13a-15(b) or 15d-15(b) under the Securities Exchange Act of 1934, as amended (17 CFR 240.13a-15(b) or 240.15d-15(b)). |
(b) | There were no changes in the registrants internal control over financial reporting (as defined in Rule 30a-3(d) under the 1940 Act (17 CFR 270.30a-3(d)) that occurred during the registrants second fiscal quarter of the period covered by this report that has materially affected, or is reasonably likely to materially affect, the registrants internal control over financial reporting. |
Item 12. Exhibits.
(a)(1) | Code of ethics, or any amendment thereto, that is the subject of disclosure required by Item 2 is attached hereto. |
(a)(2) | Certifications pursuant to Rule 30a-2(a) under the 1940 Act and Section 302 of the Sarbanes-Oxley Act of 2002 are attached hereto. |
(a)(3) | Not applicable. |
(b) | Certifications pursuant to Rule 30a-2(b) under the 1940 Act and Section 906 of the Sarbanes- Oxley Act of 2002 are attached hereto. |
(12.other) Not applicable.
SIGNATURES
Pursuant to the requirements of the Securities Exchange Act of 1934 and the Investment Company Act of 1940, the registrant has duly caused this report to be signed on its behalf by the undersigned, thereunto duly authorized.
(Registrant) The Gabelli SRI Fund, Inc. |
By (Signature and Title)* /s/ Bruce N. Alpert |
Bruce N. Alpert, Principal Executive Officer |
Date 6/05/2015 |
Pursuant to the requirements of the Securities Exchange Act of 1934 and the Investment Company Act of 1940, this report has been signed below by the following persons on behalf of the registrant and in the capacities and on the dates indicated.
By (Signature and Title)* /s/ Bruce N. Alpert |
Bruce N. Alpert, Principal Executive Officer |
Date 6/05/2015 |
By (Signature and Title)* /s/ Agnes Mullady |
Agnes Mullady, Principal Financial Officer and Treasurer |
Date 6/05/2015 |
* Print the name and title of each signing officer under his or her signature.
EX-99.CODE ETH
Joint Code of Ethics for Chief Executive
and Senior Financial Officers of the Gabelli/GAMCO/TETON Funds
Each affiliated registered investment company (each a Company) is committed to conducting business in accordance with applicable laws, rules and regulations and the highest standards of business ethics, and to full and accurate disclosure -- financial and otherwise -- in compliance with applicable law. This Code of Ethics, applicable to each Companys Chief Executive Officer, President, Chief Financial Officer and Treasurer (or persons performing similar functions) (together, Senior Officers), sets forth policies to guide you in the performance of your duties.
As a Senior Officer, you must comply with applicable law. You also have a responsibility to conduct yourself in an honest and ethical manner. You have leadership responsibilities that include creating a culture of high ethical standards and a commitment to compliance, maintaining a work environment that encourages the internal reporting of compliance concerns and promptly addressing compliance concerns.
This Code of Ethics recognizes that the Senior Officers are subject to certain conflicts of interest inherent in the operation of investment companies, because the Senior Officers currently or may in the future serve as Senior Officers of each of the Companies, as officers or employees of the investment advisor to the Companies or service providers thereof (the Advisor) and/or affiliates of the Advisor (the Advisory Group) and as officers or trustees/directors of other registered investment companies and unregistered investment funds advised by the Advisory Group. This Code of Ethics also recognizes that certain laws and regulations applicable to, and certain policies and procedures adopted by, the Companies or the Advisory Group govern your conduct in connection with many of the conflict of interest situations that arise in connection with the operations of the Companies, including:
| the Investment Company Act of 1940, and the rules and regulation promulgated thereunder by the Securities and Exchange Commission (the 1940 Act); |
| the Investment Advisers Act of 1940, and the rules and regulations promulgated thereunder by the Securities and Exchange Commission (the Advisers Act); |
| the Code of Ethics adopted by each Company pursuant to Rule 17j-1(c) under the 1940 Act (collectively, the Trusts 1940 Act Code of Ethics); |
| one or more codes of ethics adopted by the Advisory Group that have been reviewed and approved by those trustees/directors (the Directors) of each Company that are not interested persons of such Company (the Independent Directors) within the meaning of the 1940 Act (the Advisory Groups 1940 Act Code of Ethics and, together with such Companys 1940 Act Code of Ethics, the 1940 Act Codes of Ethics); |
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| the policies and procedures adopted by each Company to address conflict of interest situations, such as procedures under Rule 10f-3, Rule 17a-7 and Rule 17e-1 under the 1940 Act (collectively, the Conflict Policies); and |
| the Advisory Groups policies and procedures to address, among other things, conflict of interest situations and related matters (collectively, the Advisory Policies). |
The provisions of the 1940 Act, the Advisers Act, the 1940 Act Codes of Ethics, the Conflict Policies and the Advisory Policies are referred to herein collectively as the Additional Conflict Rules.
This Code of Ethics is different from, and is intended to supplement, the Additional Conflict Rules. Accordingly, a violation of the Additional Conflict Rules by a Senior Officer is hereby deemed not to be a violation of this Code of Ethics, unless and until the Directors shall determine that any such violation of the Additional Conflict Rules is also a violation of this Code of Ethics.
Senior Officers Should Act Honestly and Candidly
Each Senior Officer has a responsibility to each Company to act with integrity. Integrity requires, among other things, being honest and candid. Deceit and subordination of principle are inconsistent with integrity.
Each Senior Officer must:
| act with integrity, including being honest and candid while still maintaining the confidentiality of information where required by law or the Additional Conflict Rules; |
| comply with the laws, rules and regulations that govern the conduct of each Companys operations and report any suspected violations thereof in accordance with the section below entitled Compliance With Code Of Ethics; and |
| adhere to a high standard of business ethics. |
Conflicts Of Interest
A conflict of interest for the purpose of this Code of Ethics occurs when your private interests interfere in any way, or even appear to interfere, with the interests of a Company.
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Senior Officers are expected to use objective and unbiased standards when making decisions that affect each Company, keeping in mind that Senior Officers are subject to certain inherent conflicts of interest because Senior Officers of a Company also are or may be officers of other Companies and/or the Advisory Group (as a result of which it is incumbent upon you to be familiar with and to seek to comply with the Additional Conflict Rules).
You are required to conduct the business of each Company in an honest and ethical manner, including the ethical handling of actual or apparent conflicts of interest between personal and business relationships. When making any investment, accepting any position or benefits, participating in any transaction or business arrangement or otherwise acting in a manner that creates or appears to create a conflict of interest with respect to each Company where you are receiving a personal benefit, you should act in accordance with the letter and spirit of this Code of Ethics.
If you are in doubt as to the application or interpretation of this Code of Ethics to you as a Senior Officer of a Company, you should make full disclosure of all relevant facts and circumstances to the Chief Compliance Officer of the Advisory Group (the CCO) and obtain the approval of the CCO prior to taking action.
Some conflict of interest situations that should always be approved by the CCO, if material, include the following:
| the receipt of any entertainment or non-nominal gift by the Senior Officer, or a member of his or her family, from any company with which a Company has current or prospective business dealings (other than the Advisory Group), unless such entertainment or gift is business related, reasonable in cost, appropriate as to time and place, and not so frequent as to raise any question of impropriety; |
| any ownership interest in, or any consulting or employment relationship with, of any of the Companies service providers, other than the Advisory Group; or |
| a direct or indirect financial interest in commissions, transaction charges or spreads paid by a Company for effecting portfolio transactions or for selling or redeeming shares other than an interest arising from the Senior Officers employment by the Advisory Group, such as compensation or equity ownership. |
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Disclosures
It is the policy of each Company to make full, fair, accurate, timely and understandable disclosure in compliance with all applicable laws and regulations in all reports and documents that such Company files with, or submits to, the Securities and Exchange Commission or a national securities exchange and in all other public communications made by such Company. As a Senior Officer, you are required to promote compliance with this policy and to abide by such Companys standards, policies and procedures designed to promote compliance with this policy.
Each Senior Officer must:
| familiarize himself or herself with the disclosure requirements applicable to each Company as well as the business and financial operations of each Company; and |
| not knowingly misrepresent, or cause others to misrepresent, facts about any Company to others, including to the Directors, such Companys independent auditors, such Companys counsel, any counsel to the Independent Directors, governmental regulators or self-regulatory organizations. |
Compliance With Code Of Ethics
If you know of or suspect a violation of this Code of Ethics or other laws, regulations, policies or procedures applicable to the Company, you must report that information on a timely basis to the CCO or report it anonymously by following the whistle blower policies adopted by the Advisory Group from time to time. No one will be subject to retaliation because of a good faith report of a suspected violation.
Each Company will follow these procedures in investigating and enforcing this Code of Ethics, and in reporting on this Code of Ethics:
| the CCO will take all appropriate action to investigate any actual or potential violations reported to him or her; |
| violations and potential violations will be reported to the Board of Directors of each affected Company after such investigation; |
| if the Board of Directors determines that a violation has occurred, it will take all appropriate disciplinary or preventive action; and |
| appropriate disciplinary or preventive action may include a letter of censure, suspension, dismissal or, in the event of criminal or other serious violations of law, notification of the Securities and Exchange Commission or other appropriate law enforcement authorities. |
Waivers Of Code Of Ethics
Except as otherwise provided in this Code of Ethics, the CCO is responsible for applying this Code of Ethics to specific situations in which questions are presented to the CCO and has the authority to interpret this Code of Ethics in any particular situation. The CCO shall take all action he or she considers appropriate to investigate any actual or potential violations reported under this Code of Ethics.
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The CCO is authorized to consult, as appropriate, with counsel to the affected Company, the Advisory Group or the Independent Directors, and is encouraged to do so.
The Board of Directors of the affected Company is responsible for granting waivers of this Code of Ethics, as appropriate. Any changes to or waivers of this Code of Ethics will, to the extent required, be disclosed on Form N-CSR, or otherwise, as provided by Securities and Exchange Commission rules.
Recordkeeping
Each Company will maintain and preserve for a period of not less than six (6) years from the date an action is taken, the first two (2) years in an easily accessible place, a copy of the information or materials supplied to the Boards of Directors pursuant to this Code of Ethics:
| that provided the basis for any amendment or waiver to this Code of Ethics; and |
| relating to any violation of this Code of Ethics and sanctions imposed for such violation, together with a written record of the approval or action taken by the relevant Board of Directors. |
Confidentiality
All reports and records prepared or maintained pursuant to this Code of Ethics shall be considered confidential and shall be maintained and protected accordingly. Except as otherwise required by law or this Code of Ethics, such matters shall not be disclosed to anyone other than the Independent Directors and their counsel, the Companies and their counsel, the Advisory Group and its counsel and any other advisors, consultants or counsel retained by the Directors, the Independent Directors or any committee of Directors.
Amendments
This Code of Ethics may not be amended as to any Company except in written form, which is specifically approved by a majority vote of the affected Companys Directors, including a majority of its Independent Directors.
No Rights Created
This Code of Ethics is a statement of certain fundamental principles, policies and procedures that govern each of the Senior Officers in the conduct of the Companies business. It is not intended to and does not create any rights in any employee, investor, supplier, competitor, shareholder or any other person or entity.
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ACKNOWLEDGMENT FORM
I have received and read the Joint Code of Ethics for Chief Executive and Senior Financial Officers, and I understand its contents. I agree to comply fully with the standards contained in the Code of Ethics and the Companys related policies and procedures. I understand that I have an obligation to report any suspected violations of the Code of Ethics on a timely basis to the Chief Compliance Officer or report it anonymously by following the whistle blower policies adopted by the Advisory Group from time to time.
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Certification Pursuant to Rule 30a-2(a) under the 1940 Act and Section 302 of the
Sarbanes-Oxley Act
I, Bruce N. Alpert, certify that:
1. | I have reviewed this report on Form N-CSR of The Gabelli SRI Fund, Inc.; |
2. | Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the period covered by this report; |
3. | Based on my knowledge, the financial statements, and other financial information included in this report, fairly present in all material respects the financial condition, results of operations, changes in net assets, and cash flows (if the financial statements are required to include a statement of cash flows) of the registrant as of, and for, the periods presented in this report; |
4. | The registrants other certifying officer(s) and I are responsible for establishing and maintaining disclosure controls and procedures (as defined in Rule 30a-3(c) under the Investment Company Act of 1940) and internal control over financial reporting (as defined in Rule 30a-3(d) under the Investment Company Act of 1940) for the registrant and have: |
(a) | Designed such disclosure controls and procedures, or caused such disclosure controls and procedures to be designed under our supervision, to ensure that material information relating to the registrant, including its consolidated subsidiaries, is made known to us by others within those entities, particularly during the period in which this report is being prepared; |
(b) | Designed such internal control over financial reporting, or caused such internal control over financial reporting to be designed under our supervision, to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes in accordance with generally accepted accounting principles; |
(c) | Evaluated the effectiveness of the registrants disclosure controls and procedures and presented in this report our conclusions about the effectiveness of the disclosure controls and procedures, as of a date within 90 days prior to the filing date of this report based on such evaluation; and |
(d) | Disclosed in this report any change in the registrants internal control over financial reporting that occurred during the second fiscal quarter of the period covered by this report that has materially affected, or is reasonably likely to materially affect, the registrants internal control over financial reporting; and |
5. | The registrants other certifying officer(s) and I have disclosed to the registrants auditors and the audit committee of the registrants board of directors (or persons performing the equivalent functions): |
(a) | All significant deficiencies and material weaknesses in the design or operation of internal control over financial reporting which are reasonably likely to adversely affect the registrants ability to record, process, summarize, and report financial information; and |
(b) | Any fraud, whether or not material, that involves management or other employees who have a significant role in the registrants internal control over financial reporting. |
Date: 6/05/2015 | /s/ Bruce N. Alpert | |
Bruce N. Alpert, Principal Executive Officer |
Certification Pursuant to Rule 30a-2(a) under the 1940 Act and Section 302 of the
Sarbanes-Oxley Act
I, Agnes Mullady, certify that:
1. | I have reviewed this report on Form N-CSR of The Gabelli SRI Fund, Inc.; |
2. | Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the period covered by this report; |
3. | Based on my knowledge, the financial statements, and other financial information included in this report, fairly present in all material respects the financial condition, results of operations, changes in net assets, and cash flows (if the financial statements are required to include a statement of cash flows) of the registrant as of, and for, the periods presented in this report; |
4. | The registrants other certifying officer(s) and I are responsible for establishing and maintaining disclosure controls and procedures (as defined in Rule 30a-3(c) under the Investment Company Act of 1940) and internal control over financial reporting (as defined in Rule 30a-3(d) under the Investment Company Act of 1940) for the registrant and have: |
(a) | Designed such disclosure controls and procedures, or caused such disclosure controls and procedures to be designed under our supervision, to ensure that material information relating to the registrant, including its consolidated subsidiaries, is made known to us by others within those entities, particularly during the period in which this report is being prepared; |
(b) | Designed such internal control over financial reporting, or caused such internal control over financial reporting to be designed under our supervision, to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes in accordance with generally accepted accounting principles; |
(c) | Evaluated the effectiveness of the registrants disclosure controls and procedures and presented in this report our conclusions about the effectiveness of the disclosure controls and procedures, as of a date within 90 days prior to the filing date of this report based on such evaluation; and |
(d) | Disclosed in this report any change in the registrants internal control over financial reporting that occurred during the second fiscal quarter of the period covered by this report that has materially affected, or is reasonably likely to materially affect, the registrants internal control over financial reporting; and |
5. | The registrants other certifying officer(s) and I have disclosed to the registrants auditors and the audit committee of the registrants board of directors (or persons performing the equivalent functions): |
(a) | All significant deficiencies and material weaknesses in the design or operation of internal control over financial reporting which are reasonably likely to adversely affect the registrants ability to record, process, summarize, and report financial information; and |
(b) | Any fraud, whether or not material, that involves management or other employees who have a significant role in the registrants internal control over financial reporting. |
Date: 6/05/2015 | /s/ Agnes Mullady | |
Agnes Mullady, Principal Financial Officer and Treasurer |
Certification Pursuant to Rule 30a-2(b) under the 1940 Act and Section 906 of the
Sarbanes-Oxley Act
I, Bruce N. Alpert, Principal Executive Officer of The Gabelli SRI Fund, Inc. (the Registrant), certify that:
1. | The Form N-CSR of the Registrant (the Report) fully complies with the requirements of Section 13(a) or 15(d) of the Securities Exchange Act of 1934, as amended; and |
2. | The information contained in the Report fairly presents, in all material respects, the financial condition and results of operations of the Registrant. |
Date: 6/05/2015 |
/s/ Bruce N. Alpert | |||
Bruce N. Alpert, Principal Executive Officer |
I, Agnes Mullady, Principal Financial Officer and Treasurer of The Gabelli SRI Fund, Inc. (the Registrant), certify that:
1. | The Form N-CSR of the Registrant (the Report) fully complies with the requirements of Section 13(a) or 15(d) of the Securities Exchange Act of 1934, as amended; and |
2. | The information contained in the Report fairly presents, in all material respects, the financial condition and results of operations of the Registrant. |
Date: 6/05/2015 |
/s/ Agnes Mullady | |||
Agnes Mullady, Principal Financial Officer and Treasurer |
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