N-CSR 1 sri-ncsr_033123.htm CERTIFIED ANNUAL SHAREHOLDER REPORT

 

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)  
     
 

John C. Ball

Gabelli Funds, LLC

One Corporate Center

Rye, New York 10580-1422

 
  (Name and address of agent for service)  

 

Registrant's telephone number, including area code: 1-800-422-3554

 

Date of fiscal year end: March 31

 

Date of reporting period: March 31, 2023

 

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, 450 Fifth Street, NW, Washington, DC 20549-0609. The OMB has reviewed this collection of information under the clearance requirements of 44 U.S.C. § 3507.

 

   
 

Item 1. Reports to Stockholders.

(a)The Report to Shareholders is attached herewith.

 

   
 

 

Gabelli SRI Fund, Inc.

Annual Report March 31, 2023

(Y)our Portfolio Management Team

 

       
Christopher J. Marangi Kevin V. Dreyer Ian Lapey Melody Prenner Bryant
Co-Chief Investment Officer Co-Chief Investment Officer Portfolio Manager Portfolio Manager
BA, Williams College BSE, University of BA, Williams College BA, Binghamton University
MBA, Columbia Pennsylvania MS, Northeastern  
Business School MBA, Columbia University  
  Business School MBA, New York  
    University  

 

To Our Shareholders,

 

For the fiscal year ended March 31, 2023, the net asset value (NAV) total return per Class AAA Share of the Gabelli SRI Fund was (6.8)% compared with a total return of (7.7)% for the Standard & Poor’s (S&P) 500 Index. Other classes of shares are available. See page 5 for performance information for all classes of shares.

 

Enclosed are the financial statements, including the schedule of investments, as of March 31, 2023.

 

Investment Objective and Strategy

 

On February 16, 2023, the Board of Directors of the Fund approved a change in the Fund’s name to the “Gabelli SRI Fund, Inc.” along with certain changes to the Fund’s principal investment strategies and techniques. The Fund filed an amendment to its registration statement with the Securities and Exchange Commission reflecting the changes to the Fund’s principal investment strategies and techniques, and corresponding changes to the Fund’s risks. This filing will be subject to review by the SEC and is expected to become effective on or around 60 days after filing (the Effective Date). It is currently expected that these changes will become effective on or about May 23, 2023.

 

As permitted by regulations adopted by the Securities and Exchange Commission, paper copies of the Fund’s annual and semiannual shareholder reports will no longer be sent by mail, unless you specifically request paper copies of the reports. Instead, the reports will be made available on the Fund’s website (www.gabelli.com), and you will be notified by mail each time a report is posted and provided with a website link to access the report. If you already elected to receive shareholder reports electronically, you will not be affected by this change and you need not take any action. To elect to receive all future reports on paper free of charge, please contact your financial intermediary, or, if you invest directly with the Fund, you may call 800-422-3554 or send an email request to info@gabelli.com.

 

 

 

Currently, the Fund seeks to achieve its investment goal of capital appreciation 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 Fund’s guidelines for social responsibility at the time of investment. As described in the Prospectus, under normal market conditions, the Fund invests its assets in stocks that are listed on a recognized securities exchange or similar market, such as the National Market System of the Financial Industry Regulatory Authority, Inc. The Fund may also invest in foreign securities, including those in emerging markets, and in securities that are convertible into common stocks. The Fund focuses on investments in companies whose securities are trading at a material discount to their private market value (PMV). PMV is the value Gabelli Funds, LLC (the Adviser), believes informed investors would be willing to pay for a company.

 

As of the Effective Date, the Fund plans to seek to achieve its investment 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 Fund’s guidelines for social responsibility at the time of investment. The Fund may also invest in foreign securities and in securities that are convertible into common stocks. The Fund will focus on investments in companies whose securities appear to be underpriced relative to their PMV.

 

Under the new investment strategy, the Adviser will employ a social screening overlay process on a pro-active basis at the time of investment to identify companies that meet Fund’s social guidelines. Pursuant to these guidelines, the Fund will not invest in companies that derive more than 10% of their revenues from the following areas: Tobacco, Cannabis, Alcohol, Gambling, or Weapons production. In accordance with the new investment strategy, after identifying companies that satisfy these social criteria, the Adviser then will invest in securities of companies that the Adviser believes are trading at a material discount to PMV. The Adviser will monitor each holding of a socially responsible company on a continuous basis to ensure its compliance with the Fund’s social guidelines. Securities that no longer meet these guidelines will be sold within a reasonable period of time after the Adviser makes such a determination.

 

Once the changes to the Fund’s name and principal investment strategies and techniques become effective, an updated Prospectus reflecting these changes will be available to shareholders of the Fund.

 

2 

 

Performance Discussion (Unaudited)

 

In the Fund’s first fiscal quarter (the second quarter of 2022), despite a challenging landscape, several traditionally defensive sectors added positively to portfolio returns. These areas included pharmaceutical firms, consumer packaged goods stalwarts, and health insurers. Cyclically sensitive stocks were the biggest detractors to the quarter’s performance. Technology holdings dependent on ad dollars saw slowed revenue growth, financial firms reliant on the consumer suffered from decreased discretionary spending, and agricultural equipment manufacturers continued to be subject to supply chain challenges.

 

The Fund’s second fiscal quarter was another difficult one for the market. The Federal Reserve’s decision to begin raising interest rates to combat inflation increased pressure on the consumer and companies with significant exposure to advertising and/or cable cord-cutting. US retailers have record levels of inventory on their books despite consumer wages staying high. However, amid macroeconomic concerns, there were some bright spots for the Fund’s holdings and signs the consumer remains resilient. A slight easing of supply chain constraints gave some relief to portfolio holdings.

 

The Fund’s third fiscal quarter saw positive results across the market, with the S&P 500 ESG Index outperforming the S&P 500 Index. The portfolio was propelled by agricultural holdings as farmers, left flush by higher commodity prices but facing higher input costs, invested in productivity enhancers that also conserve water, energy, and soil; and water technologies which benefited from increased consumer focus on water conservation and cleanliness. Despite these positive results, the Federal Reserve’s war on inflation continued, although at a slower pace with rate increases dropping from 75 basis points to 50 basis points. Fed Chairman Jerome Powell’s tone remained hawkish and pressure from higher interest rates was the primary headwind for financial services and technology stocks. The prospect of a recession continued to creep into headlines.

 

The Fund’s fourth fiscal quarter was positive, with a number of factors contributing to performance. The passage of the Inflation Reduction Act in 2022 directs nearly $400 billion in spending and tax credits to support clean electricity and transmission, clean transportation, and water management. While funding of these initiatives and the resulting earnings benefits will be realized over many years, the market has begun sorting winners and losers. Of course, an increase in the secular momentum behind sustainability was not the only primary factor driving first quarter returns as the market dealt with an increasing probability of recession and volatility in interest rates and commodity prices.

 

Top contributors to the portfolio were Xylem Inc. (4.1% of net assets as of March 31, 2023), a global leader in the design, manufacturing, and application of highly engineered technologies for the transportation, treatment, measurement, and testing of water. With more than $2 billion of backlog and minimal exposure to residential construction, Xylem should continue to thrive despite broader economic softening; Cavco Industries Inc. (1.7%), with a strong balance sheet and one of the largest manufactured home producers in the US, experienced robust earnings (the company’s backlog remained around $1 billion) driven by the continued growth of the manufactured housing market; and multinational consumer goods company Unilever plc, ADR (2.8%). Unilever was able to side step significant input cost inflation and saw increased sales growth and product turnover in 2022.

 

Detractors from performance included Alphabet Inc., Cl. A (1.1%), an umbrella company whose subsidiaries include the core Google business. Alphabet saw its stock price fall over 20% for the year due to a number of factors including a significant decline in online search advertising and economic uncertainty; Sony Group Corp., ADR (3.7%) shares were negatively affected due to growing concerns about its video game business amid increased competition with Microsoft when its acquisition of Activision Blizzard is finalized, as well worries about the impact of looming global recession on consumer spending. While Sony’s diversified global businesses offer a defensive position for the long run, short term headwinds include cyclical weaknesses in video games and

 

3 

 

difficult year-over-year comparisons for its movie business; and International Flavors & Fragrances Inc. (0.4%), a leading global supplier of flavor and fragrances and ingredients used in food, beverage, and personal and household care products. IFF saw shares sold off due to reduced 2022 free cash flow expectations attributable to higher inventory, and management’s reluctance to raise full year guidance. Despite macroeconomic concerns, as an integrated solutions provider, IFF is integral to the creation of customer products and has significant pricing power.

 

We appreciate your confidence and trust.

 

The views expressed reflect the opinions of the Fund’s portfolio managers and Gabelli Funds, LLC, the Adviser, as of the date of this report and are subject to change without notice based on changes in market, economic, or other conditions. These views are not intended to be a forecast of future events and are no guarantee of future results.

 

4 

 

Comparative Results

 

Average Annual Returns through March 31, 2023 (a)(b) (Unaudited)

 

Total returns and average annual returns reflect changes in share price, reinvestment of distributions, and are net of expenses.

 

    1 Year    3 Year    5 Year    10 Year    Since
Inception
(6/1/07)
Class AAA (ESGGX)   (6.77)%   14.78%   5.11%   6.22%   5.71%
S&P 500 Index (c)   (7.73)   18.60    11.19    12.24    8.59 
S&P 500 ESG Index (c)   (7.41)   19.93    12.74    12.82    N/A 
Class A (ESGHX)   (6.71)   14.79    5.13    6.23    5.72 
With sales charge (d)   (12.07)   12.55    3.89    5.60    5.32 
Class C (ESGJX)   (6.76)   14.79    4.85    5.69    5.09 
Class I (ESGKX)   (6.73)   14.78    5.20    6.40    5.92 

 

(a)The Fund’s fiscal year ends March 31.

(b)Returns would have been lower had the Adviser not reimbursed certain expenses of the Fund. The Fund imposes a 2% redemption fee on shares sold or exchanged within seven days of purchase.

(c)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. The S&P 500 ESG Index is a market capitalization weighted, broad based index of large capitalization stocks meeting sustainability criteria, while maintaining similar overall industry weights as the S&P 500. Dividends are considered reinvested. You cannot invest directly in an index.

(d)Performance results include the effect of the maximum 5.75% sales charge at the beginning of the period.

 

In the current prospectuses dated July 29, 2022, the gross expense ratios for Class AAA, A, and I are 1.85%, 1.85%, and 1.60%, respectively, and the net expense ratios for all share classes after contractual reimbursements by the Adviser is 0.90%. See page 14 for the expense ratios for the year ended March 31, 2023. The contractual reimbursements are in effect through July 31, 2024. Class AAA and I Shares do not have a sales charge. The maximum sales charge for Class A Shares is 5.75%.

 

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.

 

Returns represent past performance and do not guarantee future results. 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.

 

 

5 

 

COMPARISON OF CHANGE IN VALUE OF A $10,000 INVESTMENT IN

Gabelli SRI Fund, Inc. (CLASS AAA SHARES), S&P 500 INDEX, AND S&P 500 ESG INDEX (Unaudited)

 

Average Annual Total Returns*
  1 Year 5 Year 10 Year
Class AAA (6.77)% 5.11% 6.22%

 

 

* 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.

 

6 

 

Gabelli SRI Fund, Inc.

Disclosure of Fund Expenses (Unaudited)

For the Six Month Period from October 1, 2022 through March 31, 2023Expense Table

 

 

We believe it is important for you to understand the impact of fees and expenses regarding your investment. All mutual funds have operating expenses. As a shareholder of a fund, you incur ongoing costs, which include costs for portfolio management, administrative services, and shareholder reports (like this one), among others. Operating expenses, which are deducted from a fund’s gross income, directly reduce the investment return of a fund. When a fund’s expenses are expressed as a percentage of its average net assets, this figure is known as the expense ratio. The following examples are intended to help you understand the ongoing costs (in dollars) of investing in your Fund and to compare these costs with those of other mutual funds. The examples are based on an investment of $1,000 made at the beginning of the period shown and held for the entire period.

 

The Expense Table below illustrates your Fund’s costs in two ways:

 

Actual Fund Return: This section provides information about actual account values and actual expenses. You may use this section to help you to estimate the actual expenses that you paid over the period after any fee waivers and expense reimbursements. The “Ending Account Value” shown is derived from the Fund’s actual return during the past six months, and the “Expenses Paid During Period” shows the dollar amount that would have been paid by an investor who started with $1,000 in the Fund. You may use this information, together with the amount you invested, to estimate the expenses that you paid over the period.

 

To do so, simply divide your account value by $1,000 (for example, an $8,600 account value divided by $1,000 = 8.6), then multiply the result by the number given for your Fund under the heading “Expenses Paid During Period” to estimate the expenses you paid during this period.

 

Hypothetical 5% Return: This section provides information about hypothetical account values and hypothetical expenses based on the Fund’s actual expense ratio. It assumes a hypothetical annualized return of 5% before expenses during the period shown. In this case – because the hypothetical return used is not the Fund’s actual return – the results do not apply to your investment and you cannot use the hypothetical account value and expense to estimate the actual ending account balance or expenses you

paid for the period. This example is useful in making comparisons of the ongoing costs of investing in the Fund and other funds. To do so, compare this 5% hypothetical example with the 5% hypothetical examples that appear in shareholder reports of other funds.

 

Please note that the expenses shown in the table are meant to highlight your ongoing costs only and do not reflect any transactional costs such as sales charges (loads), redemption fees, or exchange fees, if any, which are described in the Prospectus. If these costs were applied to your account, your costs would be higher. Therefore, the 5% hypothetical return is useful in comparing ongoing costs only, and will not help you determine the relative total costs of owning different funds. The “Annualized Expense Ratio” represents the actual expenses for the last six months and may be different from the expense ratio in the Financial Highlights which is for the fiscal year ended March 31, 2023.

 

  Beginning Ending Annualized Expenses
  Account Value Account Value Expense Paid During
  10/01/22 03/31/23 Ratio Period *
The Gabelli SRI Fund, Inc.        
Actual Fund Return        
Class AAA $1,000.00 $1,176.60 0.90% $ 4.88
Class A $1,000.00 $1,177.90 0.90% $ 4.89
Class C $1,000.00 $1,177.00 0.90% $ 4.88
Class I $1,000.00 $1,177.10 0.90% $ 4.89
Hypothetical 5% Return        
Class AAA $1,000.00 $1,020.44 0.90% $ 4.53
Class A $1,000.00 $1,020.44 0.90% $ 4.53
Class C $1,000.00 $1,020.44 0.90% $ 4.53
Class I $1,000.00 $1,020.44 0.90% $ 4.53

 

*Expenses are equal to the Fund’s annualized expense ratio for the last six months multiplied by the average account value over the period, multiplied by the number of days in the most recent fiscal half year (182 days), then divided by 365.

7 

 

Summary of Portfolio Holdings (Unaudited)

 

The following table presents portfolio holdings as a percent of net assets as of March 31, 2023:

 

The Gabelli SRI Fund, Inc.

 

Financial Services 17.1%   Beverage 1.7 %
Health Care 12.3%   Semiconductors 1.4 %
Food 9.7%   Cable and Satellite 1.3 %
Machinery 9.3%   Equipment and Supplies 1.2 %
Environmental Services 5.6%   Computer Hardware 0.8 %
Consumer Products 5.6%   Telecommunications 0.8 %
Energy and Utilities 4.4%   Business Services 0.7 %
Computer Software and Services 4.3%   Automotive: Parts and Accessories 0.6 %
U.S. Government Obligations 3.8%   Consumer Services 0.6 %
Diversified Industrial 3.7%   Broadcasting 0.6 %
Entertainment 3.4%   Transportation 0.4 %
Building and Construction 3.1%   Real Estate Investment Trust 0.3 %
Automotive 3.0%   Other Assets and Liabilities (Net) (0.2) %
Retail 2.5%     100.0 %
SpecialtyChemicals 2.0%        

 

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-PORT. Shareholders may obtain this information at www.gabelli.com or by calling the Fund at 800-GABELLI (800-422-3554). The Fund’s Form N-PORT is available on the SEC’s website at www.sec.gov and may also be reviewed and copied at the SEC’s 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 Fund’s 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 SEC’s website at www.sec.gov.

8 

 

 

Gabelli SRI Fund, Inc.

Schedule of Investments — March 31, 2023

 
Shares      Cost   Market
Value
 
     COMMON STOCKS — 96.4% 
     Automotive — 3.0% 
 7,641   Daimler Truck Holding AG†  $199,483   $257,798 
 3,650   Mercedes-Benz Group AG   174,384    280,177 
 1,900   Toyota Motor Corp., ADR   226,054    269,211 
         599,921    807,186 
     Automotive: Parts and Accessories — 0.6% 
 1,000   Genuine Parts Co.   136,014    167,310 
                
     Beverage — 1.7% 
 5,000   Danone SA   336,664    310,763 
 2,424   The Coca-Cola Co.   116,619    150,361 
         453,283    461,124 
     Broadcasting — 0.6% 
 5,500   Liberty Media Corp.- Liberty SiriusXM, Cl. C†   209,511    153,945 
                
     Building and Construction — 3.1% 
 5,750   Canfor Corp.†   93,250    92,409 
 1,460   Cavco Industries Inc.†   305,653    463,900 
 4,550   Johnson Controls International plc   219,408    274,001 
         618,311    830,310 
                
     Business Services — 0.7% 
 235   Mastercard Inc., Cl. A   81,888    85,401 
 400   Visa Inc., Cl. A   80,652    90,184 
         162,540    175,585 
                
     Cable and Satellite — 1.3% 
 8,300   Comcast Corp., Cl. A   161,422    314,653 
 2,200   EchoStar Corp., Cl. A†   61,351    40,238 
         222,773    354,891 
     Computer Hardware — 0.8% 
 1,700   International Business          
     Machines Corp.   215,675    222,853 
                
     Computer Software and Services — 4.3% 
 2,950   Alphabet Inc., Cl. A†   163,796    306,004 
 380   Cadence Design Systems Inc.†   71,176    79,834 
 2,175   Cisco Systems Inc.   95,074    113,698 
 2,500   Gen Digital Inc.   46,141    42,900 
 10,000   Hewlett Packard Enterprise Co.   130,822    159,300 
 690   Microsoft Corp.   82,119    198,927 
 213   Rockwell Automation Inc.   50,368    62,505 
 475   Salesforce Inc.†   86,835    94,895 
 815   VMware Inc., Cl. A†   68,780    101,753 
         795,111    1,159,816 
                
     Consumer Products — 5.6% 
 5,000   Church & Dwight Co. Inc.   474,997    442,050 
Shares      Cost   Market
Value
 
 1,000   Johnson Outdoors Inc., Cl. A  $76,964   $63,010 
 10,955   Sony Group Corp., ADR   388,170    993,071 
         940,131    1,498,131 
     Consumer Services — 0.6% 
 8,500   Resideo Technologies Inc.†   85,979    155,380 
                
     Diversified Industrial — 3.7% 
 10,800   ABB Ltd., ADR   274,698    370,440 
 660   Agilent Technologies Inc.   69,355    91,304 
 16,000   Bollore SE   85,768    98,733 
 570   Eaton Corp. plc   83,562    97,664 
 15,000   Flex Ltd.†   275,746    345,150 
         789,129    1,003,291 
     Energy and Utilities — 4.4% 
 15,400   NextEra Energy Inc.   595,590    1,187,032 
                
     Entertainment — 3.4% 
 1,620   Madison Square Garden Sports Corp.   268,499    315,657 
 1,250   The Walt Disney Co.†   140,513    125,162 
 3,000   Universal Music Group NV   84,947    75,823 
 36,400   Vivendi SE   414,589    367,125 
 3,300   Vivendi SE, ADR   34,461    33,122 
         943,009    916,889 
     Environmental Services — 5.6% 
 650   Ecolab Inc.   99,267    107,595 
 16,199   Evoqua Water Technologies Corp.†   160,898    805,414 
 2,500   Waste Connections Inc.   73,247    347,675 
 1,500   Waste Management Inc.   238,255    244,755 
         571,667    1,505,439 
     Equipment and Supplies — 1.2% 
 15,000   Ardagh Metal Packaging SA   128,606    61,200 
 10,000   Mueller Water Products Inc., Cl. A   32,735    139,400 
 325   Parker-Hannifin Corp.   47,211    109,236 
         208,552    309,836 
     Financial Services — 17.1% 
 20,730   Aegon NV   85,429    88,825 
 3,910   Ally Financial Inc.   104,522    99,666 
 4,300   American Express Co.   378,923    709,285 
 1,000   Axis Capital Holdings Ltd.   53,386    54,520 
 32,700   Banco Bilbao Vizcaya Argentaria SA   176,679    233,028 
 850   Capital One Financial Corp.   78,272    81,736 
 1,110   Citigroup Inc.   51,600    52,048 
 27,000   Commerzbank AG†   189,985    284,089 
 4,296   Credit Agricole SA   45,820    48,444 
 62,300   Daiwa Securities Group Inc.   308,158    291,382 

See accompanying notes to financial statements.

 

9 

 

Gabelli SRI Fund, Inc.

Schedule of Investments (Continued) — March 31, 2023

 
Shares      Cost   Market
Value
 
     COMMON STOCKS (Continued) 
     Financial Services (Continued) 
 889   Diamond Hill Investment Group Inc.  $160,103   $146,312 
 1,000   First American Financial Corp.   54,040    55,660 
 4,850   Flushing Financial Corp.   72,342    72,217 
 18,200   ING Groep NV   139,136    215,735 
 1,200   Intercontinental Exchange Inc.   151,910    125,148 
 2,600   Moelis & Co., Cl. A   98,322    99,944 
 103,900   NatWest Group plc   300,385    337,859 
 2,776   NN Group NV   105,779    100,734 
 800   PayPal Holdings Inc.†   35,613    60,752 
 2,085   S&P Global Inc.   733,557    718,845 
 2,550   Shinhan Financial Group Co. Ltd., ADR   69,121    68,697 
 18,800   Standard Chartered plc   115,465    142,443 
 3,850   State Street Corp.   225,632    291,407 
 2,200   The Bank of New York Mellon Corp.   92,688    99,968 
 3,000   TrustCo Bank Corp. NY   95,999    95,820 
         3,922,866    4,574,564 
     Food — 9.7% 
 10,000   Mondelēz International Inc., Cl. A   283,219    697,200 
 9,550   Nestlé SA   547,792    1,163,389 
 14,400   Unilever plc, ADR   544,432    747,792 
         1,375,443    2,608,381 
     Health Care — 12.3% 
 3,425   Baxter International Inc.   254,068    138,918 
 300   Becton Dickinson & Co.   67,538    74,262 
 7,550   Bristol-Myers Squibb Co.   363,602    523,290 
 550   Danaher Corp.   146,338    138,622 
 2,300   Gilead Sciences Inc.   145,264    190,831 
 4,000   Haleon plc, ADR   29,750    32,560 
 495   HCA Healthcare Inc.   57,340    130,522 
 5,000   Henry Schein Inc.†   294,863    407,700 
 275   Illumina Inc.†   75,630    63,951 
 500   IQVIA Holdings Inc.†   103,336    99,445 
 635   Laboratory Corp. of America Holdings   176,756    145,682 
 2,150   Medtronic plc   198,238    173,333 
 1,460   Merck & Co. Inc.   127,151    155,329 
 885   The Cigna Group   212,757    226,144 
 1,195   Vertex Pharmaceuticals Inc.†   289,484    376,509 
 2,595   Zoetis Inc.   125,852    431,912 
         2,667,967    3,309,010 
Shares      Cost   Market
Value
 
    Machinery — 9.3%
 420   Caterpillar Inc.  $75,612   $96,113 
 84,500   CNH Industrial NV   698,214    1,290,315 
 10,550   Xylem Inc.   279,184    1,104,585 
         1,053,010    2,491,013 
     Real Estate Investment Trust — 0.3% 
 725   Alexandria Real Estate Equities Inc.   112,804    91,053 
                
     Retail — 2.5% 
 2,000   Lowe’s Companies Inc.   226,460    399,940 
 965   NIKE Inc., Cl. B   125,842    118,348 
 615   Target Corp.   96,230    101,862 
 1,650   Walgreens Boots Alliance Inc.   65,955    57,057 
         514,487    677,207 
     Semiconductors — 1.4% 
 3,100   Intel Corp.   157,186    101,277 
 340   NVIDIA Corp.   17,285    94,442 
 930   QUALCOMM Inc.   119,742    118,649 
 470   Teradyne Inc.   41,616    50,530 
         335,829    364,898 
     Specialty Chemicals — 2.0% 
 1,110   Air Products and Chemicals Inc.   303,208    318,803 
 1,100   International Flavors & Fragrances Inc.   125,216    101,156 
 650   Rogers Corp.†   71,965    106,230 
         500,389    526,189 
     Telecommunications — 0.8% 
 570   American Tower Corp., REIT   141,046    116,474 
 8,000   Vodafone Group plc, ADR   90,788    88,320 
         231,834    204,794 
     Transportation — 0.4% 
 1,475   Canadian Pacific Railway Ltd.   108,678    113,487 
                
     TOTAL COMMON STOCKS   18,370,503    25,869,614 

See accompanying notes to financial statements.

 

10 

 

Gabelli SRI Fund, Inc.

Schedule of Investments (Continued) — March 31, 2023

 
Principal
Amount
      Cost   Market
Value
 
     U.S. GOVERNMENT OBLIGATIONS — 3.8% 
$1,013,000   U.S. Treasury Bills, 4.342% to 4.715%††, 04/27/23 to 06/29/23  $1,004,947   $1,005,186 
                
     TOTAL INVESTMENTS — 100.2%  $19,375,450    26,874,800 
                
     Other Assets and Liabilities (Net) — (0.2)%    (45,801)
                
     NET ASSETS — 100.0%   $26,828,999 

 

 

 

Non-income producing security.

Represents annualized yields at dates of purchase.

 

ADRAmerican Depositary Receipt

REITReal Estate Investment Trust

 

See accompanying notes to financial statements.

 

11 

 

 

Gabelli SRI Fund, Inc.

 

Statement of Assets and Liabilities

March 31, 2023

 

Assets:    
Investments, at value (cost $19,375,450)  $26,874,800 
Receivable for investments sold   100,482 
Receivable for Fund shares sold   119 
Receivable from Adviser   61,139 
Dividends and interest receivable   127,425 
Prepaid expenses   13,689 
Total Assets   27,177,654 
Liabilities:     
Payable to bank   47,363 
Payable for investments purchased   170,018 
Payable for Fund shares redeemed   630 
Payable for investment advisory fees   22,358 
Payable for distribution fees   3,862 
Payable for payroll expenses   854 
Payable for legal and audit fees   65,010 
Payable for shareholder communications   25,721 
Other accrued expenses   12,839 
Total Liabilities   348,655 
Net Assets     
(applicable to 2,194,471 shares outstanding)  $26,828,999 
Net Assets Consist of:     
Paid-in capital  $19,412,631 
Total distributable earnings   7,416,368 
Net Assets  $26,828,999 
      
Shares of Capital Stock, each at $0.001 par value:     
Class AAA:     
Net Asset Value, offering, and redemption price per share ($7,818,405 ÷ 645,459 shares outstanding)  $12.11 
Class A:     
Net Asset Value and redemption price per share ($7,506,921 ÷ 620,537 shares outstanding)  $12.10 
Maximum offering price per share (NAV ÷ 0.9425, based on maximum sales charge of 5.75% of the offering price)  $12.84 
Class C:     
Net Asset Value and redemption price per share ($792,488 ÷ 74,962 shares outstanding)  $10.57 
Class I:     
Net Asset Value, offering, and redemption price per share ($10,711,185 ÷ 853,513 shares outstanding)  $12.55 

Statement of Operations

For the Year Ended March 31, 2023

 

Investment Income:    
Dividends (net of foreign withholding taxes of $36,471)  $575,056 
Interest   16,606 
Total Investment Income   591,662 
Expenses:     
Investment advisory fees   296,658 
Distribution fees - Class AAA   21,282 
Distribution fees - Class A   21,349 
Distribution fees - Class C   11,287 
Legal and audit fees   103,038 
Registration expenses   51,903 
Shareholder communications expenses   51,289 
Directors’ fees   25,416 
Shareholder services fees   18,655 
Custodian fees   12,542 
Payroll expenses   2,255 
Miscellaneous expenses   14,860 
Total Expenses   630,534 
Less:     
Expense reimbursements by Adviser (See Note 3)   (362,773)
Expenses paid indirectly by broker (See Note 6)   (762)
Total credits and reimbursements   (363,535)
Net Expenses   266,999 
Net Investment Income   324,663 
Net Realized and Unrealized Gain/(Loss) on     
Investments and Foreign Currency:     
Net realized gain on investments   88,567 
Net realized loss on foreign currency transactions   (1,799)
      
Net realized gain on investments and foreign currency transactions   86,768 
Net change in unrealized appreciation/depreciation:     
on investments   (3,090,437)
on foreign currency translations   (606)
      
Net change in unrealized appreciation/depreciation on investments and foreign currency translations   (3,091,043)
Net Realized and Unrealized Gain/(Loss) on Investments and Foreign Currency   (3,004,275)
Net Decrease in Net Assets Resulting from Operations  $(2,679,612)

See accompanying notes to financial statements.

 

12 

 

 

Gabelli SRI Fund, Inc.

 

Statement of Changes in Net Assets

 

 

   Year Ended
March 31, 2023
    Year Ended
March 31, 2022
               
Operations:                
Net investment income    $324,663       $213,182 
Net realized gain on investments and foreign currency transactions     86,768        3,598,399 
Net change in unrealized appreciation/depreciation on investments and foreign currency translations     (3,091,043)       (2,683,346)
Net Increase/(Decrease) in Net Assets Resulting from Operations     (2,679,612)       1,128,235 
                 
Distributions to Shareholders:                
Accumulated earnings                
Class AAA     (396,594)       (1,407,628)
Class A     (381,895)       (1,524,724)
Class C     (47,040)       (326,226)
Class I     (540,906)       (1,843,131)
Total Distributions to Shareholders     (1,366,435)       (5,101,709)
                 
Capital Share Transactions:                
Class AAA     (1,035,288)       563,566 
Class A     (1,906,015)       474,394 
Class C     (682,352)       (1,173,731)
Class I     (1,285,808)       1,353,584 
Net Increase/(Decrease) in Net Assets from Capital Share Transactions     (4,909,463)       1,217,813 
                 
Net Decrease in Net Assets     (8,955,510)       (2,755,661)
Net Assets:                
Beginning of year     35,784,509        38,540,170 
End of year    $26,828,999       $35,784,509 

See accompanying notes to financial statements.

 

13 

 

 

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 Ended
March 31
  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
   Total
Distributions
   Redemption
Fees(a)
   Net Asset Value,
End of Year
   Total Return†   Net Assets, End of
Year (in 000’s)
   Net Investment
Income (Loss)
   Operating
Expenses Before
Reimbursement(b)
   Operating
Expenses Net of
Reimbursement
   Portfolio
Turnover
Rate
 
Class AAA                                                              
2023  $13.63   $0.13   $(1.07)  $(0.94)  $(0.23)  $(0.35)  $(0.58)  $   $12.11   (6.77)%  $7,818   1.09%  2.19%  0.90%  25%
2022   15.25    0.08    0.44    0.52    (0.23)   (1.91)   (2.14)       13.63   2.53    9,982   0.52   1.85   0.90   34 
2021   10.40    0.19    5.73    5.92    (0.09)   (0.98)   (1.07)       15.25   58.17    10,547   1.42   1.91   0.90   18 
2020   14.03    0.16(c)   (1.59)   (1.43)   (0.09)   (2.11)   (2.20)   0.00(d)   10.40   (13.50)   7,530   1.13(c)  1.92   1.14   18 
2019   15.35    0.07    (0.37)   (0.30)      (1.02)   (1.02)   0.00(d)   14.03   (1.92)   11,227   0.49   1.87   1.25   29 
Class A                                                              
2023  $13.61   $0.13   $(1.06)  $(0.93)  $(0.23)  $(0.35)  $(0.58)  $   $12.10   (6.71)%  $7,507   1.10%  2.19%  0.90%  25%
2022   15.23    0.09    0.43    0.52    (0.23)   (1.91)   (2.14)       13.61   2.54    10,647   0.54   1.85   0.90   34 
2021   10.39    0.19    5.72    5.91    (0.09)   (0.98)   (1.07)       15.23   58.13    11,335   1.41   1.91   0.90   18 
2020   14.02    0.15(c)   (1.58)   (1.43)   (0.09)   (2.11)   (2.20)   0.00(d)   10.39   (13.51)   7,455   1.11(c)  1.92   1.13   18 
2019   15.33    0.08    (0.37)   (0.29)       (1.02)   (1.02)   0.00(d)   14.02   (1.85)   8,958   0.51   1.87   1.25   29 
Class C                                                              
2023  $11.93   $0.12   $(0.94)  $(0.82)  $(0.23)  $(0.31)  $(0.54)  $   $10.57   (6.76)%  $793   1.13%  2.94%  0.90%  25%
2022   13.59    0.10    0.38    0.48    (0.23)   (1.91)   (2.14)       11.93   2.55    1,679   0.70   2.59   0.90   34 
2021   9.35    0.17    5.14    5.31    (0.09)   (0.98)   (1.07)       13.59   58.18    3,040   1.44   2.66   0.90   18 
2020   12.80    0.08(c)   (1.42)   (1.34)       (2.11)   (2.11)   0.00(d)   9.35   (13.93)   4,022   0.60(c)  2.67   1.68   18 
2019   14.20    (0.03)   (0.35)   (0.38)       (1.02)   (1.02)   0.00(d)   12.80   (2.65)   7,347   (0.25)  2.62   2.00   29 
Class I                                                              
2023  $14.11   $0.14   $(1.11)  $(0.97)  $(0.23)  $(0.36)  $(0.59)  $   $12.55   (6.73)%  $10,711   1.09%  1.94%  0.90%  25%
2022   15.72    0.08    0.45    0.53    (0.23)   (1.91)   (2.14)       14.11   2.52    13,477   0.52   1.60   0.90   34 
2021   10.70    0.19    5.90    6.09    (0.09)   (0.98)   (1.07)       15.72   58.13    13,618   1.41   1.66   0.90   18 
2020   14.38    0.19(c)   (1.64)   (1.45)   (0.12)   (2.11)   (2.23)   0.00(d)   10.70   (13.32)   9,995   1.30(c)  1.67   0.97   18 
2019   15.67    0.11    (0.38)   (0.27)       (1.02)   (1.02)   0.00(d)   14.38   (1.68)   15,660   0.74   1.62   1.00   29 

 

 

Total return represents aggregate total return of a hypothetical investment at the beginning of the year and sold at the end of the year including reinvestment of distributions and does not reflect the applicable sales charges.

(a)Per share amounts have been calculated using the average shares outstanding method.

(b)The Fund received credits from a designated broker who agreed to pay certain Fund operating expenses. For all periods presented, there was no impact on the expense ratios.

(c)Includes income resulting from special dividends. Without these dividends, the per share income amounts would have been $0.13 (Class AAA and Class A), $0.05 (Class C), and $0.16 (Class I), respectively, and the net investment income ratio would have been 0.94% (Class AAA), 0.92% (Class A), 0.42% (Class C), and 1.12% (Class I), respectively.

(d)Amount represents less than $0.005 per share.

 

See accompanying notes to financial statements.

 

14 

 

 

Gabelli SRI Fund, Inc.

Notes to Financial Statements

 

1.  Organization. The Gabelli SRI Fund, Inc. (formerly known as Gabelli ESG 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’s 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 Fund’s guidelines for social responsibility at the time of investment. The Fund commenced investment operations on June 1, 2007.

 

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.

 

The global outbreak of the novel coronavirus disease, known as COVID-19, has caused adverse effects on many companies, sectors, nations, regions, and the markets in general, and may continue for an unpredictable duration. The effects of this pandemic may materially impact the value and performance of the Fund, its ability to buy and sell fund investments at appropriate valuations, and its ability to achieve its investment objectives.

 

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 market’s 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 obligations 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, 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. Certain securities are valued principally using dealer quotations. Futures contracts are valued at the closing settlement price of the exchange or board of trade on which the applicable contract is traded. OTC futures and options on futures for which market quotations are readily available will be valued by quotations received from a pricing service or, if no quotations are available from a pricing service, by quotations obtained from one of more dealers in the instrument in question by the Adviser.

 

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  

 

15 

 

 

Gabelli SRI Fund, Inc.

Notes to Financial Statements (Continued)

 

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.

 

The inputs and valuation techniques used to measure fair value of the Fund’s 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 Board’s determinations as to the fair value of investments).

 

A financial instrument’s 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 Fund’s investments in securities by inputs used to value the Fund’s investments as of March 31, 2023 is as follows:

 

   Valuation Inputs     
   Level 1
Quoted Prices
   Level 2 Other
Significant
Observable Inputs
   Total Market Value
at 03/31/23
 
INVESTMENTS IN SECURITIES:               
ASSETS (Market Value):               
Common Stocks (a)  $25,869,614       $25,869,614 
U.S. Government Obligations      $1,005,186    1,005,186 
TOTAL INVESTMENTS IN SECURITIES – ASSETS  $25,869,614   $1,005,186   $26,874,800 

 

 

(a)       Please refer to the Schedule of Investments for the industry classifications of these portfolio holdings.

 

There were no Level 3 investments at March 31, 2023 or March 31, 2022.

 

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 are 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.

 

16 

 

 

Gabelli SRI Fund, Inc.

Notes to Financial Statements (Continued)

 

Fair Valuation. Fair valued securities may be common or preferred equities, warrants, options, rights, or 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. When fair valuing a security, factors to consider include 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. A significant change in the unobservable inputs could result in a lower or higher value in Level 3 securities. The circumstances of Level 3 securities are frequently monitored to determine if fair valuation measures continue to apply.

 

The Adviser reports quarterly to the Board the results of the application of fair valuation policies and procedures. These may include backtesting the prices realized in subsequent trades of these fair valued securities to fair values previously recognized.

 

Investments in other Investment Companies. The Fund may invest, from time to time, in shares of other investment companies (or entities that would be considered investment companies but are excluded from the definition pursuant to certain exceptions under the 1940 Act) (the Acquired Funds) in accordance with the 1940 Act and related rules. Shareholders in the Fund would bear the pro rata portion of the periodic expenses of the Acquired Funds in addition to the Fund’s expenses. During the fiscal year ended March 31, 2023, the Fund did not incur periodic expenses charged by Acquired Funds.

 

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

 

17 

 

 

Gabelli SRI Fund, Inc.

Notes to Financial Statements (Continued)

 

restrictions. The sale of restricted securities often requires more time and results in higher brokerage charges or dealer discounts and other selling expenses than 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. At March 31, 2023, the Fund did not hold any restricted securities.

 

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 an accrual basis. Premiums and discounts on debt securities are amortized using the effective yield to maturity method or amortized to earliest call date, if applicable. 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 fund’s 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 and timing differences. 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 tax treatment of currency gains and losses. These reclassifications have no impact on the NAV of the Fund.

 

The tax character of distributions paid during the fiscal years ended March 31, 2023 and 2022 was as follows:

 

   Year Ended
March 31, 2023
 Year Ended
March 31, 2022
Distributions paid from:              
Ordinary income    $545,591     $783,314 
Net long term capital gains     820,844      4,318,395 
Total distributions paid    $1,366,435     $5,101,709 

 

18 

 

 

Gabelli SRI Fund, Inc.

Notes to Financial Statements (Continued)

 

 

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, 2023, the components of accumulated earnings/losses on a tax basis were as follows:

 

Undistributed ordinary income  $319,460 
Net unrealized appreciation on investments and foreign currency translations   7,320,457 
Qualified late year loss deferrals*   (223,549)
Total  $7,416,368 

 

*Under the current law, qualified late year losses realized after October 31 and prior to the Fund’s year end may be elected as occurring on the first day of the following year. For the fiscal year ended March 31, 2023, the Fund elected to defer $223,549 of late year short term losses.

 

At March 31, 2023, the temporary difference between book basis and tax basis unrealized appreciation on investments was primarily due to deferral of losses from wash sales for tax purposes and spinoff adjustments.

 

The following summarizes the tax cost of investments and the related net unrealized appreciation at March 31, 2023:

 

   Cost  Gross
Unrealized
Appreciation
  Gross
Unrealized
Depreciation
  Net Unrealized
Appreciation
Investments  $19,553,521  $8,454,570  $(1,133,291)  $7,321,279

 

The Fund is required to evaluate tax positions taken or expected to be taken in the course of preparing the Fund’s 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. During the fiscal year ended March 31, 2023, the Fund did not incur any income tax, interest, or penalties. As of March 31, 2023, the Adviser has reviewed all open tax years and concluded that there was no impact to the Fund’s net assets or results of operations. The Fund’s 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 Fund’s 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 Fund’s portfolio, oversees the administration of all aspects of the Fund’s business and affairs, and pays the compensation of all Officers and Directors of the Fund who are affiliated persons of the Adviser.

 

The Adviser amended its contractual agreement with respect to each share class of the Fund to waive its investment advisory fees and/or to reimburse expenses to the extent necessary to maintain the annualized

 

19 

 

 

Gabelli SRI Fund, Inc.

Notes to Financial Statements (Continued)

 

total operating expenses of the Fund (excluding brokerage costs, acquired fund fees and expenses, interest, taxes, and extraordinary expenses) until at least July 31, 2024 at no more than 0.90% of the value of the Fund’s average daily net assets for each share class of the Fund. During the fiscal year ended March 31, 2023, the Adviser reimbursed the Fund in the amount of $362,773. 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, that after giving effect to the repayment, such adjusted annualized total operating expenses of the Fund would not exceed 0.90% of the value of the Fund’s average daily net assets for each share class of the Fund. The arrangement is renewable annually. At March 31, 2023, the cumulative amount which the Fund may repay the Adviser, subject to the terms above, is $1,063,111:

 

For the fiscal year ended March 31, 2021, expiring March 31, 2024   $346,140 
For the fiscal year ended March 31, 2022, expiring March 31, 2025    354,198 
For the fiscal year ended March 31, 2023, expiring March 31, 2026    362,773 
    $1,063,111 

 

4.  Distribution Plan. The Fund’s 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 fiscal year ended March 31, 2023, other than short term securities and U.S. Government obligations, aggregated $7,101,827 and $12,759,708, respectively.

 

6. Transactions with Affiliates and Other Arrangements. During the fiscal year ended March 31, 2023, the Fund paid $677 in brokerage commissions on security trades to G.research, LLC, an affiliate of the Adviser. Additionally, the Distributor retained a total of $169 from investors representing commissions (sales charges and underwriting fees) on sales and redemptions of Fund shares.

 

During the fiscal year ended March 31, 2023, the Fund received credits from a designated broker who agreed to pay certain Fund operating expenses. The amount of such expenses paid through this directed brokerage arrangement during this period was $762.

 

The cost of calculating the Fund’s NAV per share is a Fund expense pursuant to the Advisory Agreement. Under the sub-administration agreement with Bank of New York Mellon, the fees paid include the cost of calculating the Fund’s NAV. The Fund reimburses the Adviser for this service. The Adviser did not seek a reimbursement during the fiscal year ended March 31, 2023.

 

The Corporation pays retainer and per meeting fees to Directors not affiliated with the Adviser, plus specified amounts to the Lead Director and Audit Committee Chairman. Directors are also reimbursed for out of pocket expenses incurred in attending meetings. Directors who are directors or employees of the Adviser or an affiliated company receive no compensation or expense reimbursement from the Corporation.

 

7.  Capital Stock. The Fund offers three classes of shares – Class AAA Shares, Class A Shares, and Class I Shares. Effective January 27, 2020, the Fund’s Class AAA, Class A and Class C Shares “closed to purchases from new investors”. “Closed to purchases from new investors” means (i) with respect to the Class AAA and

 

20 

 

 

Gabelli SRI Fund, Inc.

Notes to Financial Statements (Continued)

 

Class A Shares, no new investors may purchase shares of such classes, but existing shareholders may continue to purchase additional shares of such classes after the Effective Date, and (ii) with respect to Class C Shares, neither new investors nor existing shareholders may purchase any additional shares of such class after the Effective Date. These changes will have no effect on existing shareholders’ ability to redeem shares of the Fund as described in the Fund’s Prospectus. Additionally on the Effective Date, Class I Shares of the Fund became available to investors with a minimum initial investment amount of $1,000 and purchasing shares directly through the Distributor, or investors purchasing Class I Shares through brokers or financial intermediaries that have entered into selling agreements with the Distributor specifically with respect to Class I Shares.

 

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 fiscal years ended March 31, 2023 and 2022, if any, can be found in the Statement of Changes in Net Assets under Redemption Fees.

 

Transactions in shares of capital stock were as follows:

 

   Year Ended
March 31, 2023
   Year Ended
March 31, 2022
 
   Shares   Amount   Shares   Amount 
Class AAA                    
Shares sold   5,257   $64,173    7,525   $118,061 
Shares issued upon reinvestment of distributions   33,230    392,449    96,102    1,392,519 
Shares redeemed   (125,551)   (1,491,910)   (62,680)   (947,014)
Net increase/(decrease)   (87,064)  $(1,035,288)   40,947   $563,566 
Class A                    
Shares sold   22,162   $268,560    53,841   $832,881 
Shares issued upon reinvestment of distributions   30,347    358,098    99,686    1,442,456 
Shares redeemed   (214,334)   (2,532,673)   (115,184)   (1,800,943)
Net increase/(decrease)   (161,825)  $(1,906,015)   38,343   $474,394 
Class C                    
Shares issued upon reinvestment of distributions   4,562   $47,040    25,728   $326,226 
Shares redeemed   (70,423)   (729,392)   (108,539)   (1,499,957)
Net decrease   (65,861)  $(682,352)   (82,811)  $(1,173,731)
Class I                    
Shares sold   61,252   $746,423    75,995   $1,238,767 
Shares issued upon reinvestment of distributions   43,240    529,258    119,990    1,799,854 
Shares redeemed   (206,164)   (2,561,489)   (106,970)   (1,685,037)
Net increase/(decrease)   (101,672)  $(1,285,808)   89,015   $1,353,584 

 

8.  Indemnifications. The Fund enters into contracts that contain a variety of indemnifications. The Fund’s 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 Fund’s existing contracts and expects the risk of loss to be remote.

 

21 

 

 

Gabelli SRI Fund, Inc.

Notes to Financial Statements (Continued)

 

9.  Subsequent Events. On February 16, 2023, the Board of Directors of the Fund approved a change in the Fund’s name to the “Gabelli SRI Fund, Inc.” along with certain changes to the Fund’s principal investment strategies and techniques. The Fund filed an amendment to its registration statement with the Securities and Exchange Commission reflecting the changes to the Fund’s principal investment strategies and techniques, and corresponding changes to the Fund risks. This filing will be subject to review by the SEC and is expected to become effective on or around 60 days after filing (the Effective Date). It is currently expected that these changes will become effective on or about May 23, 2023.

 

Management has evaluated the impact on the Fund of all other subsequent events occurring through the date the financial statements were issued and has determined that there were no other subsequent events requiring recognition or disclosure in the financial statements.

 

22 

 

 

Gabelli SRI Fund, Inc.

Report of Independent Registered Public Accounting Firm

 

To the Board of Directors and Shareholders of

Gabelli SRI Fund, Inc.:

 

Opinion on the Financial Statements

We have audited the accompanying statement of assets and liabilities, including the schedule of investments, of Gabelli SRI Fund, Inc. (the “Fund”) as of March 31, 2023, the related statement of operations for the year ended March 31, 2023, the statement of changes in net assets for each of the two years in the period ended March 31, 2023, including the related notes, and the financial highlights for each of the five years in the period ended March 31, 2023 (collectively referred to as the “financial statements”). In our opinion, the financial statements present fairly, in all material respects, the financial position of the Fund as of March 31, 2023, 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 ended March 31, 2023 and the financial highlights for each of the five years in the period ended March 31, 2023 in conformity with accounting principles generally accepted in the United States of America.

 

Basis for Opinion

These financial statements are the responsibility of the Fund’s management. Our responsibility is to express an opinion on the Fund’s financial statements based on our audits. We are a public accounting firm registered with the Public Company Accounting Oversight Board (United States) (PCAOB) and are required to be independent with respect to the Fund in accordance with the U.S. federal securities laws and the applicable rules and regulations of the Securities and Exchange Commission and the PCAOB.

 

We conducted our audits of these financial statements in accordance with the standards of the PCAOB. Those standards require that we plan and perform the audit to obtain reasonable assurance about whether the financial statements are free of material misstatement, whether due to error or fraud.

 

Our audits included performing procedures to assess the risks of material misstatement of the financial statements, whether due to error or fraud, and performing procedures that respond to those risks. Such procedures included examining, on a test basis, evidence regarding the amounts and disclosures in the financial statements. Our audits also included evaluating the accounting principles used and significant estimates made by management, as well as evaluating the overall presentation of the financial statements. Our procedures included confirmation of securities owned as of March 31, 2023 by correspondence with the custodian and brokers; when replies were not received from brokers, we performed other auditing procedures. We believe that our audits provide a reasonable basis for our opinion.

 

/s/PricewaterhouseCoopers LLP

New York, New York

May 25, 2023

 

We have served as the auditor of one or more investment companies in the Gabelli Fund Complex since 1986.

 

23 

 

 

Gabelli SRI Fund, Inc.

Liquidity Risk Management Program (Unaudited)

 

In accordance with Rule 22e-4 under the 1940 Act, the Fund has established a liquidity risk management program (the LRM Program) to govern its approach to managing liquidity risk. The LRM Program is administered by the Liquidity Committee (the Committee), which is comprised of members of Gabelli Funds, LLC management. The Board has designated the Committee to administer the LRM Program.

 

The LRM Program’s principal objectives include supporting the Fund’s compliance with limits on investments in illiquid assets and mitigating the risk that the Fund will be unable to meet its redemption obligations in a timely manner. The LRM Program also includes elements that support the management and assessment of liquidity risk, including an annual assessment of factors that influence the Fund’s liquidity and the monthly classification and re-classification of certain investments that reflect the Committee’s assessment of their relative liquidity under current market conditions.

 

At a meeting of the Board held on August 16, 2022, the Board received a written report from the Committee regarding the design and operational effectiveness of the LRM Program. The Committee determined, and reported to the Board, that the LRM Program is reasonably designed to assess and manage the Fund’s liquidity risk and has operated adequately and effectively since its implementation. The Committee reported that there were no liquidity events that impacted the Fund or its ability to timely meet redemptions without dilution to existing shareholders. The Committee noted that the Fund is primarily invested in highly liquid securities and, accordingly, continues to be exempt from the requirement to determine a “highly liquid investment minimum” as defined in the Rule 22e-4. Because of that continued qualification for the exemption, the Fund has not adopted a “highly liquid investment minimum” amount. The Committee further noted that while changes to the LRM Program were made during the Review Period and reported to the Board, no material changes were made to the LRM Program as a result of the Committee’s annual review.

 

There can be no assurance that the LRM Program will achieve its objectives in the future. Please refer to the Fund’s Prospectus for more information regarding its exposure to liquidity risk and other principal risks to which an investment in the Fund may be subject.

 

24 

 

 

Gabelli SRI Fund, Inc.

Additional Fund Information (Unaudited)

 

The business and affairs of the Fund are managed under the direction of the Fund’s Board of Directors. Information pertaining to the Directors and Officers of the Fund is set forth below. The Fund’s Statement of Additional Information includes additional information about the Fund’s Directors and is available without charge, upon request, by calling 800-GABELLI (800-422-3554) or by writing to The Gabelli SRI Fund at One Corporate Center, Rye, NY 10580-1422.

 

Name, Position(s)
Address1
and Year of Birth
Term of Office
and
Length of
Time Served2
Number of
Funds
in Fund
Complex
Overseen
by Trustee
Principal Occupation(s)
During Past Five Years
Other Directorships
Held by Director3
         
INTERESTED DIRECTOR4:        
         
Mario J. Gabelli, CFA
Director and Chief
Investment Officer
1942
Since 2007 315 Chairman, Co-Chief Executive Officer, and Chief Investment Officer– Value 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 within the Gabelli Fund Complex; Chief Executive Officer of GGCP, Inc.; Executive Chairman of Associated Capital Group, Inc. Director of Morgan Group Holding Co. (holding company) (2001-2019); Chairman of the Board and Chief Executive Officer of LICT Corp. (multimedia and communication services company); Director of CIBL, Inc. (broadcasting and wireless communications); Director of ICTC Group Inc. (communications) (2013-2018)
         
INDEPENDENT DIRECTORS6:      
       
Clarence A. Davis7
Director
1941
Since 2007 3 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); Director of PMV Consumer Acquisition Corp.
         
Vincent D. Enright
Director
1943
Since 2007 17 Former Senior Vice President and Chief Financial Officer of KeySpan Corp. (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. Heitman
Director
1949
Since 2012 4 Managing Director and Senior Advisor of Perlmutter Investment Company (real estate); Senior Vice President of Finance, Verizon Communications, and President, Verizon Investment Management (1971-2011) Director and Audit Committee Chairman of Syncreon (contract logistics provider) (2011-2019)

 

25 

 

Gabelli SRI Fund, Inc.

Additional Fund Information (Unaudited) (Continued)

 

Name, Position(s)
Address1
and Year of Birth
Term of Office
and
Length of
Time Served2
Number of
Funds
in Fund
Complex
Overseen
by Trustee
Principal Occupation(s)
During Past Five Years
Other Directorships
Held by Director3
         
Anthonie C. van Ekris7
Director
1934
Since 2007 23 Chairman and Chief Executive Officer of BALMAC International, Inc.(global import/export company)

 

26 

 

Gabelli SRI Fund, Inc.

Additional Fund Information (Unaudited) (Continued)

 

Name, Position(s)
Address1
and Year of Birth
Term of Office
and Length of
Time Served2
Principal Occupation(s)
During Past Five Years
     
OFFICERS:    
     
John C. Ball
President and
Treasurer
1976
Since 2017 Officer of registered investment companies within the Gabelli Fund Complex since 2017; Vice President and Assistant Treasurer of AMG Funds, 2014-2017; Chief Executive Officer, G.distributors, LLC since December 2020
     
Peter Goldstein
Secretary and Vice
President
1953
Since 2020 General Counsel, GAMCO Investors, Inc. and Chief Legal Officer, Associated Capital Group, Inc. since 2021; General Counsel and Chief Compliance Officer, Buckingham Capital Management, Inc. (2012-2020); Chief Legal Officer and Chief Compliance Officer, The Buckingham Research Group, Inc. (2012-2020)
     
Richard J. Walz
Chief Compliance
Officer
1959
Since 2021 Chief Compliance Officer of registered investment companies within the Fund Complex since 2013

 

 

1Address: One Corporate Center, Rye, NY 10580-1422, unless otherwise noted.

2Each 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 Fund’s By-Laws and Articles of Incorporation. For officers, includes time served in prior officer positions with the Fund. 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.

3This 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 Fund’s investment adviser.

5As of March 31, 2023, there was a total of 50 registered investment companies in the Fund Complex. Of the 48 registered investment companies, Mr. Gabelli serves as a director or trustee for 31 funds, sole portfolio manager of 6 funds, and part of the portfolio management team of 15 funds.

6Directors who are not interested persons are considered “Independent” Directors.

7Mr. Davis is a director of PMV Consumer Acquisition Corp. and Mr. van Ekris is an independent director of Gabelli International Ltd., Gabelli Fund LDC, GAMA Capital Opportunities Master Ltd., and GAMCO International SICAV, which may be deemed to be controlled by Mario J. Gabelli and/or affiliates and in that event would be deemed to be under common control with the Fund’s Adviser.

 

 

27 

 

 

Gabelli SRI Fund, Inc.

2023 TAX NOTICE TO SHAREHOLDERS (Unaudited)

 

For the fiscal year ended March 31, 2023, the Fund paid to shareholders ordinary income distributions (comprised of investment income) totaling $0.234, $0.234, $0.234, and $0.234 per share for Class AAA, Class A, Class C, and Class I Shares, respectively, and long term capital gains totaling $820,844, or the maximum allowable. The distribution of long term capital gains has been designated as a capital gain dividend by the Fund’s Board of Directors. For the fiscal year ended March 31, 2023, 49.38% of the ordinary income distribution qualifies for the dividends received deduction available to corporations. The Fund designates 100% of the ordinary income distribution as qualified dividend income pursuant to the Jobs and Growth Tax Relief Reconciliation Act of 2003. The Fund designates 0.07% of the ordinary income distribution as qualified interest income pursuant to the Tax Relief, Unemployment Reauthorization, and Job Creation Act of 2010.

 

U.S. Government Income:

 

The percentage of the ordinary income distribution paid by the Fund during the fiscal year ended March 31, 2023 which was derived from U.S. Treasury securities was 0.06%. Such income is exempt from state and local tax in all states. However, many states, including New York and California, allow a tax exemption for a portion of the income earned only if a mutual fund has invested at least 50% of its assets at the end of each quarter of the Fund’s fiscal year in U.S. Government securities. The Gabelli SRI Fund did not meet this strict requirement in 2023. The percentage of U.S. Government securities held as of March 31, 2023 was 3.8%. Due to the diversity in state and local tax law, it is recommended that you consult your personal tax adviser as to the applicability of the information provided to your specific situation.

___________ 

All designations are based on financial information available as of the date of this annual report and, accordingly, are subject to change. For each item, it is the intention of the Fund to designate the maximum amount permitted under the Internal Revenue Code and the regulations thereunder.

 

 

 

 

Gabelli Funds and Your Personal Privacy

 

Who are we?

 

The Gabelli 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, which is affiliated with GAMCO Investors, Inc., a publicly held company with subsidiaries and affiliates that provide investment advisory 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.

 

 

 

 

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GABELLI SRI FUND, INC.

One Corporate Center

 Rye, NY 10580-1422

 

Portfolio Management Team Biographies

 

Christopher J. Marangi joined Gabelli in 2003 as a research analyst. Currently he is a Managing Director and Co-Chief Investment Officer for GAMCO Investors, Inc.’s Value team. In addition, he serves as a portfolio manager of Gabelli Funds, LLC and manages several funds within the 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 degree with honors from Columbia Business School.

 

Kevin V. Dreyer joined Gabelli in 2005 as a research analyst covering companies within the consumer sector. Currently he is a Managing Director and Co-Chief Investment Officer for GAMCO Investors, Inc.’s Value team. In addition, he serves as a portfolio manager of Gabelli Funds, LLC and manages several funds within the Fund Complex. Mr. Dreyer received a BSE from the University of Pennsylvania and an MBA degree from Columbia Business School.

 

Ian Lapey joined Gabelli in October 2018 as a portfolio manager. Prior to joining Gabelli, Mr. Lapey was a research analyst and partner at Moerus Capital Management LLC. Prior to joining Moerus, he was a partner, research analyst, and a portfolio manager at Third Avenue Management. Mr. Lapey holds an MBA degree in Finance and Statistics from the Stern School of Business at New York University. He also holds a Master’s degree in Accounting from Northeastern University and a BA in Economics from Williams College.

 

Melody Prenner Bryant joined GAMCO Investors, Inc. in September 2018 and is a portfolio manager of Gabelli Funds, LLC and manages several funds within the Fund Complex. Previously, Ms. Prenner Bryant was a managing director and chief investment officer for Trevor Stewart Burton & Jacobsen Inc., a New York based registered investment adviser. She has held senior and portfolio management positions at Neuberger Berman, LLC, John A. Levin & Co., and Kempner Asset Management. Ms. Prenner Bryant received her BA in Political Science from The State University of New York at Binghamton and attended the Leonard N. Stern School of Business, New York University.

 

 

 

 

 

 

   
 

 

 

(b)Not applicable.

 

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 registrant’s 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 registrant’s 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 registrant’s 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 item’s instructions.

 

Item 3. Audit Committee Financial Expert.

As of the end of the period covered by the report, the registrant’s board of directors has determined that Vincent D. Enright is qualified to serve as audit committee financial expert serving on its audit committee and that he is “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 registrant's 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 $24,401 for 2022 and $25,621 for 2023.

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 registrant's financial statements and are not reported under paragraph (a) of this Item are $0 for 2022 and $0 for 2023.

 

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 $4,180 for 2022 and $4,390 for 2023. Tax fees represent tax compliance services provided in connection with the review of the Registrant’s 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 2022 and $0 for 2023.

 

(e)(1)Disclose the audit committee's 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 firm's 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 Chairperson's 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 Committee's pre-approval responsibilities to the other persons (other than Gabelli or the registrant's 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) 0%

(d) N/A

(f)The percentage of hours expended on the principal accountant's engagement to audit the registrant's financial statements for the most recent fiscal year that were attributed to work performed by persons other than the principal accountant's full-time, permanent employees was less than fifty percent.
(g)The aggregate non-audit fees billed by the registrant's accountant for services rendered to the registrant, and rendered to the registrant's 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 2021 and $0 for 2022.
(h)The registrant's audit committee of the board of directors has considered whether the provision of non-audit services that were rendered to the registrant's 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 accountant's 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 registrant’s 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 registrant’s principal executive and principal financial officers, or persons performing similar functions, have concluded that the registrant’s 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 registrant’s 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 period covered by this report that has materially affected, or is reasonably likely to materially affect, the registrant’s internal control over financial reporting.

 

Item 12. Disclosure of Securities Lending Activities for Closed-End Management Investment Companies.

Not applicable.

 

Item 13. 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)(2)(1)Not applicable.
   
(a)(2)(2)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. 

 

 

   
 

 

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/ John C. Ball  
    John C. Ball, Principal Executive Officer  

 

Date   June 2, 2023  

 

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/ John C. Ball  
    John C. Ball, Principal Executive Officer  

 

Date   June 2, 2023  

 

By (Signature and Title)*   /s/ John C. Ball  
    John C. Ball, Principal Financial Officer and Treasurer  

 

Date   June 2, 2023  

 

* Print the name and title of each signing officer under his or her signature.