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
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The Gabelli SRI Fund, Inc.
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(Exact name of registrant as specified in charter)
One Corporate Center
Rye, New York 10580-1422
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(Address of principal executive offices) (Zip code)
Bruce N. Alpert
Gabelli Funds, LLC
One Corporate Center
Rye, New York 10580-1422
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(Name and address of agent for service)
registrant's telephone number, including area code: 1-800-422-3554
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Date of fiscal year end: March 31
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Date of reporting period: September 30, 2007
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Form N-CSR is to be used by management investment companies to file reports with
the Commission not later than 10 days after the transmission to stockholders of
any report that is required to be transmitted to stockholders under Rule 30e-1
under the Investment Company Act of 1940 (17 CFR 270.30e-1). The Commission may
use the information provided on Form N-CSR in its regulatory, disclosure review,
inspection, and policymaking roles.
A registrant is required to disclose the information specified by Form N-CSR,
and the Commission will make this information public. A registrant is not
required to respond to the collection of information contained in Form N-CSR
unless the Form displays a currently valid Office of Management and Budget
("OMB") control number. Please direct comments concerning the accuracy of the
information collection burden estimate and any suggestions for reducing the
burden to Secretary, Securities and Exchange Commission, 100 F Street, NE,
Washington, DC 20549. The OMB has reviewed this collection of information under
the clearance requirements of 44 U.S.C. ss. 3507.
ITEM 1. REPORTS TO STOCKHOLDERS.
The Report to Shareholders is attached herewith.
THE GABELLI SRI FUND, INC.
SEMI-ANNUAL REPORT
SEPTEMBER 30, 2007
TO OUR SHAREHOLDERS,
The Gabelli SRI Fund (the "Fund") was down (1.01)% for the three month
period ended September 30, 2007 while the Standard & Poor's ("S&P") 500 Index
rose 2.33% over the same period. Since inception the Fund is down (2.10)%.
Enclosed are the investment portfolio and financial statements as of
September 30, 2007.
COMPARATIVE RESULTS
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AVERAGE ANNUAL RETURNS FROM INCEPTION (JUNE 1, 2007)
THROUGH SEPTEMBER 30, 2007 (a)
Since
Inception
Quarter (6/1/07)
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GABELLI SRI FUND CLASS AAA ....................... (1.01)% (2.10)%
S&P 500 Index .................................... 2.33 0.64
Class A .......................................... (1.01) (2.20)
(6.70)(b) (7.82)(b)
Class C .......................................... (1.11) (2.30)
(2.10)(c) (3.30)(c)
Class I .......................................... (0.91) (2.00)
THE CURRENT GROSS EXPENSE RATIO FOR CLASS AAA, A, C, AND I SHARES IS 2.55%,
2.55%, 3.30%, AND 2.30%, RESPECTIVELY. THE NET EXPENSE RATIO AFTER CONTRACTUAL
REIMBURSEMENTS BY THE ADVISER IN PLACE THROUGH MARCH 31, 2008 IS 2.00%, 2.00%,
2.75%, AND 1.75%, RESPECTIVELY. CLASS AAA AND I SHARES DO NOT HAVE A SALES
CHARGE. THE MAXIMUM SALES CHARGE FOR CLASS A AND C SHARES IS 5.75% AND 1.00%,
RESPECTIVELY.
(a) RETURNS REPRESENT PAST PERFORMANCE AND DO NOT GUARANTEE FUTURE RESULTS.
TOTAL RETURNS AND AVERAGE ANNUAL RETURNS REFLECT CHANGES IN SHARE PRICE
AND REINVESTMENT OF DISTRIBUTIONS AND ARE NET OF EXPENSES. INVESTMENT
RETURNS AND THE PRINCIPAL VALUE OF AN INVESTMENT WILL FLUCTUATE. WHEN
SHARES ARE REDEEMED, THEY MAY BE WORTH MORE OR LESS THAN THEIR ORIGINAL
COST. PERFORMANCE RETURNS FOR PERIODS LESS THAN ONE YEAR ARE NOT
ANNUALIZED. 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. INVESTORS SHOULD CAREFULLY
CONSIDER THE INVESTMENT OBJECTIVES, RISKS, CHARGES, AND EXPENSES OF THE
FUND BEFORE INVESTING. THE PROSPECTUS CONTAINS MORE INFORMATION ABOUT THIS
AND OTHER MATTERS AND SHOULD BE READ CAREFULLY BEFORE INVESTING. THE S&P
500 INDEX IS AN UNMANAGED INDICATOR OF STOCK MARKET PERFORMANCE. DIVIDENDS
ARE CONSIDERED REINVESTED. YOU CANNOT INVEST DIRECTLY IN AN INDEX.
(b) INCLUDES THE EFFECT OF THE MAXIMUM 5.75% SALES CHARGE AT THE BEGINNING OF
THE PERIOD.
(c) PERFORMANCE RESULTS INCLUDE THE DEFERRED SALES CHARGE FOR THE CLASS C
SHARES UPON REDEMPTION AT THE END OF THE PERIODS OF 1% OF THE FUND'S NET
ASSET VALUE ("NAV") PER SHARE AT THE TIME OF PURCHASE OR SALE, WHICHEVER
IS LOWER.
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We have separated the portfolio manager's commentary from the financial
statements and investment portfolio due to corporate governance regulations
stipulated by the Sarbanes-Oxley Act of 2002. We have done this to ensure that
the content of the portfolio manager's commentary is unrestricted. The financial
statements and investment portfolio are mailed separately from the commentary.
Both the commentary and the financial statements, including the portfolio of
investments, will be available on our website at www.gabelli.com/funds.
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THE GABELLI SRI FUND, INC.
DISCLOSURE OF FUND EXPENSES (UNAUDITED)
For the Period from June 1, 2007 through September 30, 2007 EXPENSE TABLE
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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 period from June 1, 2007 through September 30, 2007,
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.
Beginning Ending Annualized Expenses
Account Value Account Value Expense Paid During
06/01/07 09/30/07 Ratio Period*
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THE GABELLI SRI FUND, INC.
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ACTUAL FUND RETURN
Class AAA $ 1,000.00 $ 979.00 2.00% $ 6.43
Class A $ 1,000.00 $ 978.00 2.00% $ 6.43
Class C $ 1,000.00 $ 977.00 2.75% $ 8.84
Class I $ 1,000.00 $ 980.00 1.75% $ 5.63
HYPOTHETICAL 5% RETURN
Class AAA $ 1,000.00 $ 1,009.75 2.00% $ 6.53
Class A $ 1,000.00 $ 1,009.75 2.00% $ 6.53
Class C $ 1,000.00 $ 1,007.32 2.75% $ 8.97
Class I $ 1,000.00 $ 1,010.57 1.75% $ 5.72
* Expenses are equal to the Fund's annualized expense ratio for the period
multiplied by the average account value over the period, multiplied by the
number of days in the period, then divided by 366.
2
SUMMARY OF PORTFOLIO HOLDINGS (UNAUDITED)
The following table presents portfolio holdings as a percent of total net assets
as of September 30, 2007:
THE GABELLI SRI FUND, INC.
U.S. Government Obligations ......................................... 30.4%
Health Care ......................................................... 12.1%
Food and Beverage ................................................... 8.3%
Telecommunications .................................................. 7.4%
Financial Services .................................................. 5.4%
Metals and Mining ................................................... 5.0%
Broadcasting ........................................................ 4.5%
Cable and Satellite ................................................. 4.5%
Retail .............................................................. 3.5%
Hotels and Gaming ................................................... 3.4%
Publishing .......................................................... 2.8%
Consumer Products ................................................... 2.8%
Specialty Chemicals ................................................. 2.7%
Automotive: Parts and Accessories ................................... 2.4%
Transportation ...................................................... 2.1%
Energy and Utilities ................................................ 1.7%
Business Services ................................................... 1.5%
Environmental Services .............................................. 1.5%
Diversified Industrial .............................................. 1.4%
Equipment and Supplies .............................................. 1.3%
Wireless Communications ............................................. 1.0%
Manufactured Housing and
Recreational Vehicles ............................................ 0.9%
Other Assets and Liabilities (Net) .................................. (6.6)%
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100.0%
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THE FUND FILES A COMPLETE SCHEDULE OF PORTFOLIO HOLDINGS WITH THE SECURITIES AND
EXCHANGE COMMISSION (THE "SEC") FOR THE FIRST AND THIRD QUARTERS OF EACH FISCAL
YEAR ON FORM N-Q, THE LAST OF WHICH WAS FILED FOR THE QUARTER ENDED JUNE 30,
2007. 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-Q 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 1-800-SEC-0330.
PROXY VOTING
The Fund files Form N-PX with its complete proxy voting record for the 12 months
ended June 30th, no later than August 31st 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.
3
THE GABELLI SRI FUND, INC.
SCHEDULE OF INVESTMENTS -- SEPTEMBER 30, 2007 (UNAUDITED)
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MARKET
SHARES COST VALUE
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COMMON STOCKS -- 76.2%
AUTOMOTIVE: PARTS AND ACCESSORIES -- 2.4%
700 Midas Inc.+ ............................. $ 14,980 $ 13,209
400 Modine Manufacturing Co. ................ 9,174 10,648
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24,154 23,857
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BROADCASTING -- 4.5%
500 Beasley Broadcast Group Inc.,
Cl. A ................................. 4,218 3,755
400 Gray Television Inc. .................... 3,824 3,396
200 Liberty Media Corp. -
Capital, Cl. A+ ....................... 24,606 24,966
1,000 Lin TV Corp., Cl. A+ .................... 16,092 13,010
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48,740 45,127
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BUSINESS SERVICES -- 1.5%
600 Intermec Inc.+ .......................... 15,062 15,672
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CABLE AND SATELLITE -- 4.5%
800 Cablevision Systems Corp.,
Cl. A+ ................................ 27,589 27,952
700 The DIRECTV Group Inc.+ ................. 16,056 16,996
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43,645 44,948
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CONSUMER PRODUCTS -- 2.8%
400 Procter & Gamble Co. .................... 26,223 28,136
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DIVERSIFIED INDUSTRIAL -- 1.4%
300 Crane Co. ............................... 13,236 14,391
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ENERGY AND UTILITIES -- 1.7%
700 Westar Energy Inc. ...................... 16,963 17,192
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ENVIRONMENTAL SERVICES -- 1.5%
400 Waste Management Inc. ................... 15,510 15,096
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EQUIPMENT AND SUPPLIES -- 1.3%
300 CIRCOR International Inc. ............... 12,502 13,623
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FINANCIAL SERVICES -- 5.4%
400 American Express Co. .................... 24,559 23,748
300 Citigroup Inc. .......................... 14,099 14,001
400 Sterling Bancorp ........................ 6,292 5,600
600 SWS Group Inc. .......................... 13,592 10,614
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58,542 53,963
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FOOD AND BEVERAGE -- 8.3%
500 Cadbury Schweppes plc, ADR .............. 25,778 23,260
400 General Mills Inc. ...................... 23,448 23,204
500 Groupe Danone, ADR ...................... 7,952 7,851
500 The Coca-Cola Co. ....................... 27,470 28,735
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84,648 83,050
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HEALTH CARE -- 12.1%
800 Advanced Medical Optics Inc.+ ........... 25,860 24,472
500 Alpharma Inc., Cl. A .................... 12,051 10,680
200 AngioDynamics Inc.+ ..................... 3,230 3,770
1,000 Kyphon Inc.+ ............................ 68,855 70,000
1,000 Lifecore Biomedical Inc.+ ............... 12,401 12,900
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122,397 121,822
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MARKET
SHARES COST VALUE
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HOTELS AND GAMING -- 3.4%
200 Gaylord Entertainment Co.+ .............. $ 11,388 $ 10,644
500 Hilton Hotels Corp. ..................... 19,682 23,245
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31,070 33,889
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MANUFACTURED HOUSING AND RECREATIONAL VEHICLES -- 0.9%
300 Skyline Corp. ........................... 9,505 9,024
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METALS AND MINING -- 5.0%
500 Alcan Inc. .............................. 49,573 50,040
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PUBLISHING -- 2.8%
1,000 Lee Enterprises Inc. .................... 14,891 15,570
300 The E.W. Scripps Co., Cl. A ............. 13,278 12,600
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28,169 28,170
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RETAIL -- 3.5%
500 CVS Caremark Corp. ...................... 18,414 19,815
500 The Great Atlantic &
Pacific Tea Co. Inc.+ ................. 15,613 15,230
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34,027 35,045
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SPECIALTY CHEMICALS -- 2.7%
300 International Flavors &
Fragrances Inc. ....................... 15,129 15,858
400 Sensient Technologies Corp. ............. 10,439 11,548
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25,568 27,406
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TELECOMMUNICATIONS -- 7.4%
4,000 Dobson Communications
Corp., Cl. A+ ......................... 50,194 51,160
1,200 Sprint Nextel Corp. ..................... 25,038 22,800
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75,232 73,960
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TRANSPORTATION -- 2.1%
500 GATX Corp. .............................. 22,758 21,375
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WIRELESS COMMUNICATIONS -- 1.0%
100 United States Cellular Corp.+ ........... 7,960 9,820
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TOTAL COMMON STOCKS ..................... 765,484 765,606
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PRINCIPAL
AMOUNT
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U.S. GOVERNMENT OBLIGATIONS -- 30.4%
$ 308,000 U.S. Treasury Bill,
3.769%++, 12/27/07 .................... 305,261 305,233
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TOTAL
INVESTMENTS -- 106.6% ................. $1,070,745 1,070,839
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OTHER ASSETS AND LIABILITIES
(NET) -- (6.6)% ....................... (66,363)
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NET ASSETS -- 100.0% .................... $1,004,476
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+ Non-income producing security.
++ Represents annualized yield at date of purchase.
ADR American Depository Receipt
See accompanying notes to financial statements.
4
THE GABELLI SRI FUND, INC.
STATEMENT OF ASSETS AND LIABILITIES
SEPTEMBER 30, 2007 (UNAUDITED)
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ASSETS:
Investments, at value (cost $1,070,745) .................... $ 1,070,839
Dividends receivable ....................................... 842
Prepaid offering expense ................................... 38,557
Prepaid other expenses ..................................... 42,351
Other assets ............................................... 4,104
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TOTAL ASSETS ............................................... 1,156,693
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LIABILITIES:
Payable to investment adviser .............................. 26,138
Payable for distribution fees .............................. 175
Payable to custodian ....................................... 90,217
Payable for legal and audit fees ........................... 13,418
Payable for shareholder
communications expenses .................................. 12,692
Payable for registration expenses .......................... 9,577
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TOTAL LIABILITIES .......................................... 152,217
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NET ASSETS applicable to 102,592
shares outstanding ....................................... $ 1,004,476
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NET ASSETS CONSIST OF:
Paid-in capital, each class at $0.001 par value ............ $ 1,002,435
Accumulated net investment income .......................... 1,900
Accumulated net realized gain on investments ............... 47
Net unrealized appreciation on investments ................. 94
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NET ASSETS ................................................. $ 1,004,476
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SHARES OF CAPITAL STOCK:
CLASS AAA:
Net Asset Value, offering and redemption price
per share ($399,980 / 40,858 shares
outstanding; 500,000,000 shares authorized) .............. $ 9.79
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CLASS A:
Net Asset Value and redemption price per share
($39,828 / 4,072 shares outstanding;
500,000,000 shares authorized) ........................... $ 9.78
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Maximum offering price per share (NAV / 9425,
based on maximum sales charge of 5.75% of
the offering price) ...................................... $ 10.38
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CLASS C:
Net Asset Value and offering price per share
($108,305 / 11,088 shares outstanding;
500,000,000 shares authorized) ........................... $ 9.77(a)
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CLASS I:
Net Asset Value and offering price per share
($456,363 / 46,574 shares outstanding;
500,000,000 shares authorized) ........................... $ 9.80(a)
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(a) Redemption price varies based on the length of time held.
STATEMENT OF OPERATIONS
FOR THE PERIOD ENDED SEPTEMBER 30, 2007 (a) (UNAUDITED)
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INVESTMENT INCOME:
Interest ................................................... $ 3,975
Dividends .................................................. 1,697
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TOTAL INVESTMENT INCOME .................................... 5,672
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EXPENSES:
Investment advisory fees ................................... 1,872
Distribution fees - Class AAA .............................. 293
Distribution fees - Class A ................................ 22
Distribution fees - Class C ................................ 181
Registration expenses ...................................... 30,952
Offering expense ........................................... 20,774
Legal and audit fees ....................................... 15,643
Shareholder communications expenses ........................ 13,688
Shareholder services fees .................................. 6,193
Directors' fees ............................................ 2,805
Custodian fees ............................................. 2,429
Miscellaneous expenses ..................................... 1,269
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TOTAL EXPENSES BEFORE FEES WAIVED AND
EXPENSES REIMBURSED BY ADVISER ........................... 96,121
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LESS:
Fees waived and expenses reimbursed
by Adviser ............................................. (92,267)
Custodian fee credits .................................... (82)
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NET EXPENSES ............................................... 3,772
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NET INVESTMENT INCOME ...................................... 1,900
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NET REALIZED AND UNREALIZED GAIN
ON INVESTMENTS:
Net realized gain on investments ........................... 47
Net change in unrealized appreciation/
depreciation on investments .............................. 94
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NET REALIZED AND UNREALIZED GAIN
ON INVESTMENTS ........................................... 141
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NET INCREASE IN NET ASSETS RESULTING
FROM OPERATIONS .......................................... $ 2,041
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(a) The Gabelli SRI Fund, Inc. commenced investment operations on June 1,
2007.
See accompanying notes to financial statements.
5
THE GABELLI SRI FUND, INC.
STATEMENT OF CHANGES IN NET ASSETS
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PERIOD ENDED
SEPTEMBER 30, 2007 (a)
(UNAUDITED)
----------------------
OPERATIONS:
Net investment income .................................................... $ 1,900
Net realized gain on investments ......................................... 47
Net change in unrealized appreciation/depreciation on investments ........ 94
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NET INCREASE IN NET ASSETS RESULTING FROM OPERATIONS ..................... 2,041
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CAPITAL SHARE TRANSACTIONS:
Class AAA .............................................................. 406,828
Class A ................................................................ 40,302
Class C ................................................................ 107,227
Class I ................................................................ 448,078
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NET INCREASE IN NET ASSETS FROM CAPITAL SHARE TRANSACTIONS ............... 1,002,435
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NET INCREASE IN NET ASSETS .................................................. 1,004,476
NET ASSETS:
Beginning of period ...................................................... 0
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End of period (including undistributed net investment income of $1,900) .. $1,004,476
==========
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(a) The Gabelli SRI Fund, Inc. commenced investment operations on June 1,
2007.
See accompanying notes to financial statements.
6
THE GABELLI SRI FUND, INC.
NOTES TO FINANCIAL STATEMENTS (UNAUDITED)
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1. ORGANIZATION. The Gabelli SRI Fund, Inc. (the "Fund") was organized on March
1, 2007 as a Maryland corporation. The Fund is a diversified open-end management
investment company registered under the Investment Company Act of 1940, as
amended (the "1940 Act"). The Fund commenced investment operations on June 1,
2007. The Fund's primary objective is to seek capital appreciation.
2. SIGNIFICANT ACCOUNTING POLICIES. The preparation of financial statements in
accordance with United States ("U.S.") generally accepted accounting principles
requires management to make estimates and assumptions that affect the reported
amounts and disclosures in the financial statements. Actual results could differ
from those estimates. The following is a summary of significant accounting
policies followed by the Fund in the preparation of its financial statements.
SECURITY VALUATION. Portfolio securities listed or traded on a nationally
recognized securities exchange or traded in the U.S. over-the-counter market for
which market quotations are readily available are valued at the last quoted sale
price or a 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
instruments with remaining maturities of 60 days or less that are not credit
impaired are valued at amortized cost, unless the Board determines such amount
does not reflect the securities' fair value, in which case these securities will
be fair valued as determined by the Board. Debt instruments having a maturity
greater than 60 days for which market quotations are readily available are
valued at the average of the latest bid and asked prices. If there were no asked
prices quoted on such day, the security is valued using the closing bid price.
Futures contracts are valued at the closing settlement price of the exchange or
board of trade on which the applicable contract is traded.
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 to the
valuation and changes in valuation of similar securities, including a comparison
of foreign securities to the equivalent U.S. dollar value ADR 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.
In September 2006, the Financial Accounting Standards Board (the "FASB") issued
Statement of Financial Accounting Standards ("SFAS") 157, Fair Value
Measurements, which clarifies the definition of fair value and requires
companies to expand their disclosure about the use of fair value to measure
assets and liabilities in interim and annual periods subsequent to initial
recognition. Adoption of SFAS 157 requires the use of the price that would be
received to sell an asset or paid to transfer a liability in an orderly
transaction between market participants at the measurement date. SFAS 157 is
effective for financial statements issued for fiscal years beginning after
November 15, 2007, and interim periods within those fiscal years. At this time,
management is in the process of reviewing the requirements of SFAS 157 against
its current valuation policies to determine future applicability.
7
THE GABELLI SRI FUND, INC.
NOTES TO FINANCIAL STATEMENTS (CONTINUED) (UNAUDITED)
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REPURCHASE AGREEMENTS. The Fund may enter into repurchase agreements with
primary government securities dealers recognized by the Federal Reserve Board,
with member banks of the Federal Reserve System, or with other brokers or
dealers that meet credit guidelines established by the Adviser and reviewed by
the Board. Under the terms of a typical repurchase agreement, the Fund takes
possession of an underlying debt obligation subject to an obligation of the
seller to repurchase, and the Fund to resell, the obligation at an agreed-upon
price and time, thereby determining the yield during the Fund's holding period.
The Fund will always receive and maintain securities as collateral whose market
value, including accrued interest, will be at least equal to 102% of the dollar
amount invested by the Fund in each agreement. The Fund will make payment for
such securities only upon physical delivery or upon evidence of book entry
transfer of the collateral to the account of the custodian. To the extent that
any repurchase transaction exceeds one business day, the value of the collateral
is marked-to-market on a daily basis to maintain the adequacy of the collateral.
If the seller defaults and the value of the collateral declines or if bankruptcy
proceedings are commenced with respect to the seller of the security,
realization of the collateral by the Fund may be delayed or limited. At
September 30, 2007, there were no open repurchase agreements.
SWAP AGREEMENTS. The Fund may enter into equity swap transactions. The use of
equity swaps is a highly specialized activity that involves investment
techniques and risks different from those associated with ordinary portfolio
security transactions. In an equity swap, a set of future cash flows are
exchanged between two counterparties. One of these cash flow streams will
typically be based on a reference interest rate combined with the performance of
a notional value of shares of a stock. The other will be based on the
performance of the shares of a stock. There is no assurance that the swap
contract counterparties will be able to meet their obligations pursuant to the
swap contracts, or that, in the event of default, the Fund will succeed in
pursuing contractual remedies. The Fund thus assumes the risk that it may be
delayed in or prevented from obtaining payments owed to it pursuant to the swap
contracts. The creditworthiness of the swap contract counterparties is closely
monitored in order to minimize the risk. Depending on the general state of
short-term interest rates and the returns of the Fund's portfolio securities at
that point in time, such a default could negatively affect the Fund's ability to
make dividend payments. In addition, at the time an equity swap transaction
reaches its scheduled termination date, there is a risk that the Fund will not
be able to obtain a replacement transaction or that the terms of the replacement
will not be as favorable as on the expiring transaction. If this occurs, it
could have a negative impact on the Fund's ability to make dividend payments.
The use of derivative instruments involves, to varying degrees, elements of
market and counterparty risk in excess of the amount recognized in the Statement
of Assets and Liabilities.
Unrealized gains related to swaps are reported as an asset and unrealized losses
are reported as a liability in the Statement of Assets and Liabilities. The
change in value of swaps, including the accrual of periodic amounts of interest
to be paid or received on swaps is reported as unrealized gains or losses in the
Statement of Operations. A realized gain or loss is recorded upon payment or
receipt of a periodic payment or termination of swap agreements.
OPTIONS. The Fund may purchase or write call or put options on securities or
indices. As a writer of put options, the Fund receives a premium at the outset
and then bears the risk of unfavorable changes in the price of the financial
instrument underlying the option. The Fund would incur a loss if the price of
the underlying financial instrument decreases between the date the option is
written and the date on which the option is terminated. The Fund would realize a
gain, to the extent of the premium, if the price of the financial instrument
increases between those dates.
8
THE GABELLI SRI FUND, INC.
NOTES TO FINANCIAL STATEMENTS (CONTINUED) (UNAUDITED)
- --------------------------------------------------------------------------------
As a purchaser of put options, the Fund pays a premium for the right to sell to
the seller of the put option the underlying security at a specified price. The
seller of the put has the obligation to purchase the underlying security upon
exercise at the exercise price. If the price of the underlying security
declines, the Fund would realize a gain upon sale or exercise. If the price of
the underlying security increases or stays the same, the Fund would realize a
loss upon sale or at expiration date, but only to the extent of the premium
paid.
In the case of call options, these exercise prices are referred to as
"in-the-money," "at-the-money," and "out-of-the-money," respectively. The Fund
may write (a) in-the-money call options when the Adviser expects that the price
of the underlying security will remain stable or decline moderately during the
option period, (b) at-the-money call options when the Adviser expects that the
price of the underlying security will remain stable or advance moderately during
the option period, and (c) out-of-the-money call options when the Adviser
expects that the premiums received from writing the call option will be greater
than the appreciation in the price of the underlying security above the exercise
price. By writing a call option, the Fund limits its opportunity to profit from
any increase in the market value of the underlying security above the exercise
price of the option. Out-of-the-money, at-the-money, and in-the-money put
options (the reverse of call options as to the relation of exercise price to
market price) may be utilized in the same market environments that such call
options are used in equivalent transactions. At September 30, 2007, the Fund had
no investments in options.
FUTURES CONTRACTS. The Fund may engage in futures contracts for the purpose of
hedging against changes in the value of its portfolio securities and in the
value of securities it intends to purchase. Upon entering into a futures
contract, the Fund is required to deposit with the broker an amount of cash or
cash equivalents equal to a certain percentage of the contract amount. This is
known as the "initial margin." Subsequent payments ("variation margin") are made
or received by the Fund each day, depending on the daily fluctuations in the
value of the contract, which are included in unrealized
appreciation/depreciation on investments and futures contracts. The Fund
recognizes a realized gain or loss when the contract is closed.
There are several risks in connection with the use of futures contracts as a
hedging instrument. The change in value of futures contracts primarily
corresponds with the value of their underlying instruments, which may not
correlate with the change in value of the hedged investments. In addition, there
is the risk that the Fund may not be able to enter into a closing transaction
because of an illiquid secondary market. At September 30, 2007, there were no
open futures contracts.
FORWARD FOREIGN EXCHANGE CONTRACTS. The Fund may engage in forward foreign
exchange contracts for hedging a specific transaction with respect to either the
currency in which the transaction is denominated or another currency as deemed
appropriate by the Adviser. Forward foreign exchange contracts are valued at the
forward rate and are marked-to-market daily. The change in market value is
included in unrealized appreciation/depreciation on investments and foreign
currency translations. When the contract is closed, the Fund records a realized
gain or loss equal to the difference between the value of the contract at the
time it was opened and the value at the time it was closed.
The use of forward foreign exchange contracts does not eliminate fluctuations in
the underlying prices of the Fund's portfolio securities, but it does establish
a rate of exchange that can be achieved in the future. Although forward foreign
exchange contracts limit the risk of loss due to a decline in the value of the
hedged currency, they also limit any potential gain that might result should the
value of the currency increase. In addition, the Fund could be exposed to risks
if the counterparties to the contracts are unable to meet the terms of their
contracts. At September 30, 2007, there were no open forward foreign exchange
contracts.
9
THE GABELLI SRI FUND, INC.
NOTES TO FINANCIAL STATEMENTS (CONTINUED) (UNAUDITED)
- --------------------------------------------------------------------------------
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 the 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 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 ability 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
those of 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 AND ILLIQUID SECURITIES. The Fund may invest up to 15% of its net
assets in securities for which the markets are illiquid. Illiquid securities
include securities the disposition of which is subject to substantial legal or
contractual restrictions. The sale of illiquid securities often requires more
time and results in higher brokerage charges or dealer discounts and other
selling expenses than does the sale of securities eligible for trading on
national securities exchanges or in the over-the-counter markets. Restricted
securities may sell at a price lower than similar securities that are not
subject to restrictions on resale. Securities freely saleable among qualified
institutional investors under special rules adopted by the SEC may be treated as
liquid if they satisfy liquidity standards established by the Board. The
continued liquidity of such securities is not as well assured as that of
publicly traded securities, and accordingly the Board will monitor their
liquidity.
SECURITIES TRANSACTIONS AND INVESTMENT INCOME. Securities transactions are
accounted for on the trade date with realized gain or loss on investments
determined by using the identified cost method. Interest income (including
amortization of premium and accretion of discount) is recorded on the accrual
basis. Premiums and discounts on debt securities are amortized using the
effective yield to maturity method. Dividend income is recorded on the
ex-dividend date except for certain dividends which are recorded as soon as the
Fund is informed of the dividend.
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.
10
THE GABELLI SRI FUND, INC.
NOTES TO FINANCIAL STATEMENTS (CONTINUED) (UNAUDITED)
- --------------------------------------------------------------------------------
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.
CUSTODIAN FEE CREDITS AND INTEREST EXPENSE. When cash balances are maintained in
the custody account, the Fund receives credits which are used to offset
custodian fees. The gross expenses paid under the custody arrangement are
included in custodian fees in the Statement of Operations with the corresponding
expense offset, if any, shown as "custodian fee credits." When cash balances are
overdrawn, the Fund is charged an overdraft fee equal to 110% of the 90 day
Treasury Bill rate. This amount, if any, would be shown as "interest expense" in
the Statement of Operations.
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 U.S. generally accepted
accounting principles. These differences are primarily due to differing
treatments of income and gains on various investment securities and foreign
currency transactions held by the Fund, timing differences, and differing
characterizations of distributions made by the Fund. Distributions from net
investment income 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. These
reclassifications have no impact on the NAV of the Fund.
PROVISION FOR INCOME TAXES. The Fund intends 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.
The following summarizes the tax cost of investments and the related unrealized
appreciation/(depreciation) at September 30, 2007:
GROSS GROSS
UNREALIZED UNREALIZED NET UNREALIZED
COST APPRECIATION DEPRECIATION APPRECIATION
---------- ------------ ------------ --------------
Investments ...... $1,070,745 $22,388 $(22,294) $94
FASB Interpretation No. 48, "Accounting for Uncertainty in Income Taxes, an
Interpretation of FASB Statement No. 109" (the "Interpretation") established a
minimum threshold for financial statement recognition of the benefit of
positions taken in filing tax returns (including whether the Fund is taxable in
a particular jurisdiction) and required certain expanded tax disclosures. The
Fund has adopted the Interpretation and it had no impact on the amounts reported
in the financial statements.
11
THE GABELLI SRI FUND, INC.
NOTES TO FINANCIAL STATEMENTS (CONTINUED) (UNAUDITED)
- --------------------------------------------------------------------------------
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 has contractually agreed to waive its
investment advisory fee and/or to reimburse expenses of the Fund to the extent
necessary to maintain the annualized total operating expenses of the Fund
(excluding brokerage, interest, taxes, and extraordinary expenses) until at
least March 31, 2008, at no more than 2.00%, 2.00%, 2.75%, and 1.75% of the
value of the Fund's average daily net assets for Class AAA, Class A, Class C,
and Class I, respectively. For the period ended September 30, 2007, the Adviser
reimbursed the Fund in the amount of $92,267. In addition, the Fund has agreed,
during the three year period following any waiver or reimbursement by the
Adviser, to repay such amount to the extent, after giving effect to the
repayment, such adjusted annualized total operating expenses of the Fund would
not exceed 2.00%, 2.00%, 2.75%, and 1.75% of the value of the Fund's average
daily net assets for Class AAA, Class A, Class C, and Class I, respectively. For
the period ended September 30, 2007, the cumulative amount which the Fund may
repay the Adviser is $92,267.
The Fund pays each Director that is not considered to be an affiliated person an
annual retainer of $3,000 plus $500 for each Board meeting attended and they are
reimbursed for any out of pocket expenses incurred in attending meetings. All
Board committee members receive $500 per meeting attended and the chairman of
each committee also receives $1,000 per year. Directors who are directors or
employees of the Adviser or an affiliated company receive no compensation or
expense reimbursement from the Fund.
4. DISTRIBUTION PLAN. The Fund's Board has adopted a distribution plan (the
"Plan") for each class of shares pursuant to Rule 12b-1 under the 1940 Act.
Gabelli & Company, Inc. ("Gabelli & Company"), an affiliate of the Adviser,
serves as distributor of the Fund. Under the Class AAA, Class A, and Class C
Share Plans, payments are authorized to Gabelli & Company 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 proceeds from the sales of securities for
the period ended September 30, 2007, other than short-term securities,
aggregated $765,484 and $0, respectively.
6. TRANSACTIONS WITH AFFILIATES. During the period ended September 30, 2007, the
Fund paid brokerage commissions on security trades of $698 to Gabelli & Company.
Additionally, Gabelli & Company informed the Fund that it received $313 from
investors representing commissions (sales charges and underwriting fees) on
sales and redemptions of Fund shares.
7. CAPITAL STOCK TRANSACTIONS. The Fund currently offers four classes of shares
- - Class AAA Shares, Class A Shares, Class C Shares, and Class I Shares. Class
AAA Shares are offered only to investors who acquire them directly from Gabelli
& Company, or through selected broker/dealers, or the transfer agent without a
sales charge. Class A Shares are subject to a maximum front-end sales charge of
5.75%. Class C Shares are subject to a 1.00% CDSC for one year after purchase.
Class I Shares are offered to institutional investors that acquire the Fund
directly through Gabelli & Company.
12
THE GABELLI SRI FUND, INC.
NOTES TO FINANCIAL STATEMENTS (CONTINUED) (UNAUDITED)
- --------------------------------------------------------------------------------
The Fund imposes a redemption fee of 2.00% on Class AAA Shares, Class A Shares,
Class C Shares, and Class I 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. The Fund did not retain any redemption fees during the
period ended September 30, 2007.
The redemption fee does not apply to redemptions of shares where (i) the shares
were purchased through automatic reinvestment of dividends or other
distributions, (ii) the redemption was initiated by the Fund, (iii) the shares
were purchased through programs that collect the redemption fee at the program
level and remit them to the Fund, or (iv) the shares were purchased through
programs that the Adviser determines to have appropriate anti-short-term trading
policies in place or as to which the Adviser has received assurances that
look-through redemption fee procedures or effective anti-short-term trading
policies and procedures are in place.
Transactions in shares of capital stock were as follows:
PERIOD ENDED
SEPTEMBER 30, 2007 (a)
(UNAUDITED)
-----------------------------
SHARES AMOUNT
-------- --------
CLASS AAA
-----------------------------
Shares sold ................................... 40,994 $408,147
Shares redeemed ............................... (136) (1,319)
-------- --------
Net increase ............................... 40,858 $406,828
======== ========
CLASS A
-----------------------------
Shares sold ................................... 4,074 $ 40,321
Shares redeemed ............................... (2) (19)
-------- --------
Net increase ............................... 4,072 $ 40,302
======== ========
CLASS C
-----------------------------
Shares sold ................................... 11,090 $107,246
Shares redeemed ............................... (2) (19)
-------- --------
Net increase ............................... 11,088 $107,227
======== ========
CLASS I
-----------------------------
Shares sold ................................... 46,574 $448,078
-------- --------
Net increase ............................... 46,574 $448,078
======== ========
- ----------
(a) The Gabelli SRI Fund, Inc. commenced investment operations on June 1,
2007.
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 and expects the risk of loss to be remote.
13
THE GABELLI SRI FUND, INC.
NOTES TO FINANCIAL STATEMENTS (CONTINUED) (UNAUDITED)
- --------------------------------------------------------------------------------
9. OTHER MATTERS. The Adviser and/or affiliates received subpoenas from the
Attorney General of the State of New York and the SEC requesting information on
mutual fund share trading practices involving certain funds managed by the
Adviser. GAMCO Investors, Inc. ("GAMCO"), the Adviser's parent company,
responded to these requests for documents and testimony. In June 2006, GAMCO
began discussions with the SEC regarding a possible resolution of their inquiry.
In February 2007, the Adviser made an offer of settlement to the staff of the
SEC for communication to the Commission for its consideration to resolve this
matter. This offer of settlement is subject to agreement regarding the specific
language of the SEC's administrative order and other settlement documents. On a
separate matter, in September 2005, the Adviser was informed by the staff of the
SEC that the staff may recommend to the Commission that an administrative remedy
and a monetary penalty be sought from the Adviser in connection with the actions
of two of nine closed-end funds managed by the Adviser relating to Section 19(a)
and Rule 19a-1 of the 1940 Act. These provisions require registered investment
companies to provide written statements to shareholders when a dividend is made
from a source other than net investment income. While the two closed-end funds
sent annual statements and provided other materials containing this information,
the funds did not send written statements to shareholders with each distribution
in 2002 and 2003. The Adviser believes that all of the funds are now in
compliance. The Adviser believes that these matters would have no effect on the
Fund or any material adverse effect on the Adviser or its ability to manage the
Fund.
14
THE GABELLI SRI FUND, INC.
FINANCIAL HIGHLIGHTS (UNAUDITED)
- --------------------------------------------------------------------------------
Selected data for a share of capital stock outstanding throughout the period:
INCOME
FROM INVESTMENT OPERATIONS
--------------------------------------
Net
Net Asset Realized and Total Net Asset
Period Value, Net Unrealized from Value,
Ended Beginning Investment Loss on Investment End of Total
September 30 of Period Income(a) Investments Operations Period Return+
- ------------ --------- ---------- ------------ ---------- --------- -------
CLASS AAA
2007(b) $10.00 $0.03 $(0.24) $(0.21) $9.79 (2.10)%
CLASS A
2007(b) $10.00 $0.03 $(0.25) $(0.22) $9.78 (2.20)%
CLASS C
2007(b) $10.00 $0.00(d) $(0.23) $(0.23) $9.77 (2.30)%
CLASS I
2007(b) $10.00 $0.04 $(0.24) $(0.20) $9.80 (2.00)%
RATIOS TO AVERAGE NET ASSETS/SUPPLEMENTAL DATA
-------------------------------------------------------------------------
Net Assets Expenses Expenses
Period End of Net Net of Before Portfolio
Ended Period Investment Waivers/ Waivers/ Turnover
September 30 (in 000's) Income/(Loss) Reimbursements Reimbursements Rate
- ------------ ----------- ------------- -------------- -------------- ---------
CLASS AAA
2007(b) $400 1.05%(c) 2.00%(c) 51.62%(c) 0%
CLASS A
2007(b) $ 40 0.93%(c) 2.00%(c) 51.43%(c) 0%
CLASS C
2007(b) $108 (0.10)%(c) 2.75%(c) 51.93%(c) 0%
CLASS I
2007(b) $456 1.40%(c) 1.75%(c) 50.15%(c) 0%
- ----------
+ Total return represents aggregate total return of a hypothetical $1,000
investment at the beginning of the period and sold at the end of the
period including reinvestment of distributions and does not reflect
applicable sales charges. Total return for a period of less than one year
is not annualized.
(a) Per share amounts have been calculated using the average shares
outstanding method.
(b) The Gabelli SRI Fund, Inc. commenced investment operations on June 1,
2007.
(c) Annualized.
(d) Amount represents less than $0.005 per share.
See accompanying notes to financial statements.
15
[GRAPHIC OMITTED]
THE
GABELLI
SRI
FUND, INC.
SEMI-ANNUAL REPORT
SEPTEMBER 30, 2007
THE GABELLI SRI FUND, INC.
One Corporate Center
Rye, New York 10580-1422
800-GABELLI
800-422-3554
FAX: 914-921-5118
WEBSITE: WWW.GABELLI.COM
E-MAIL: INFO@GABELLI.COM
Net Asset Value per share available daily by calling
800-GABELLI after 6:00 P.M.
BOARD OF DIRECTORS
Mario J. Gabelli, CFA Clarence A. Davis
CHAIRMAN AND CHIEF CHIEF EXECUTIVE OFFICER,
EXECUTIVE OFFICER, NESTOR, INC.
GAMCO INVESTORS, INC.
Anthonie C. van Ekris
Vincent D. Enright CHAIRMAN, BALMAC
FORMER SENIOR VICE PRESIDENT INTERNATIONAL, INC.
AND CHIEF FINANCIAL OFFICER
KEYSPAN CORP.
OFFICERS
Bruce N. Alpert Agnes Mullady
PRESIDENT TREASURER
James E. McKee Peter D. Goldstein
SECRETARY CHIEF COMPLIANCE OFFICER
DISTRIBUTOR
Gabelli & Company, Inc.
CUSTODIAN
Mellon Trust of New England, N.A.
LEGAL COUNSEL
Paul, Hastings, Janofsky & Walker LLP
- --------------------------------------------------------------------------------
This report is submitted for the general information of the shareholders of The
Gabelli SRI Fund, Inc. It is not authorized for distribution to prospective
investors unless preceded or accompanied by an effective prospectus.
- --------------------------------------------------------------------------------
GAB1794Q207SR
ITEM 2. CODE OF ETHICS.
Not applicable.
ITEM 3. AUDIT COMMITTEE FINANCIAL EXPERT.
Not applicable.
ITEM 4. PRINCIPAL ACCOUNTANT FEES AND SERVICES.
Not applicable.
ITEM 5. AUDIT COMMITTEE OF LISTED REGISTRANTS.
Not applicable.
ITEM 6. SCHEDULE OF INVESTMENTS.
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.
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 registrant's second fiscal
quarter of 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. EXHIBITS.
(a)(1) Not applicable.
(a)(2) Certifications pursuant to Rule 30a-2(a) under the 1940 Act and
Section 302 of the Sarbanes-Oxley Act of 2002 are attached hereto.
(a)(3) Not applicable.
(b) Certifications pursuant to Rule 30a-2(b) under the 1940 Act and
Section 906 of the Sarbanes-Oxley Act of 2002 are attached hereto.
SIGNATURES
Pursuant to the requirements of the Securities Exchange Act of 1934 and the
Investment Company Act of 1940, the registrant has duly caused this report to be
signed on its behalf by the undersigned, thereunto duly authorized.
(registrant) The Gabelli SRI Fund, Inc.
-------------------------------------------------------------------
By (Signature and Title)* /s/ Bruce N. Alpert
-------------------------------------------------------
Bruce N. Alpert, Principal Executive Officer
Date 11/30/07
----------------------------------------------------------------------------
Pursuant to the requirements of the Securities Exchange Act of 1934 and the
Investment Company Act of 1940, this report has been signed below by the
following persons on behalf of the registrant and in the capacities and on the
dates indicated.
By (Signature and Title)* /s/ Bruce N. Alpert
-------------------------------------------------------
Bruce N. Alpert, Principal Executive Officer
Date 11/30/07
----------------------------------------------------------------------------
By (Signature and Title)* /s/ Agnes Mullady
-------------------------------------------------------
Agnes Mullady,
Principal Financial Officer and Treasurer
Date 11/30/07
----------------------------------------------------------------------------
* Print the name and title of each signing officer under his or her signature.