DISCLOSURES

DEUTSCH

Sustainability

Our strategies for the integration of sustainability risks for portfolio management and investment advisory

Atlan Family Office GmbH does not promote environmental or social characteristics in its investment policies or other concrete financial instruments.

Atlan Family Office GmbH does not integrate sustainability risks in its investment decision-making process or investment advice.

Sustainability risks have no influence on the remuneration policies of Atlan Family Office GmbH

Declaration on the consideration of adverse impacts on sustainability factors for portfolio management and investment advisory

Atlan Family Office GmbH does not consider principal adverse impacts of investment decisions on sustainability factors. This is because the implementation of the legal requirements given for this is unreasonable given the current state of the bureaucratic framework. In addition, essential legal issues are still unanswered.

Participation Policy

Atlan Family Office GmbH – hereinafter referred to as the “Institute” – as an asset manager within the meaning of Section 134a (1) No. 2 of the German Stock Corporation Act (AktG) is subject to the provisions of Sections 134b and 134c of the German Stock Corporation Act (AktG) and must therefore describe and publish its participation policy within the meaning of Section 134b (1) of the German Stock Corporation Act (AktG).

The Institute does not exercise any shareholder rights on behalf of its customers. No shareholders’ meetings are attended, no voting rights are exercised on behalf of customers, notifications from stock corporations are only acknowledged within the scope of mandatory notifications, and no active communication takes place with the Company or with other shareholders.

Therefore, the participation policy has been established as follows:

  1. the Institute does not exercise any shareholder rights within the meaning of Section 134b (1) no. 1 of the German Stock Corporation Act (AktG) that are based on participation in the Company. In particular, it does not exercise any rights related to general meetings of stock corporations. The right to a share in profits within the meaning of sections 60 et seq. AktG (German Stock Corporation Act) as well as to subscription rights are exercised in consultation with the customers.
  2. the monitoring of important matters of the companies within the meaning of Section 134b (1) No. 2 of the German Stock Corporation Act (AktG) is carried out by taking note of the legally required reporting of the companies in financial reports as well as ad hoc announcements.
  3. there shall be no exchange of views with corporate bodies and/or stakeholders of the Company within the meaning of Section 134b (1) no. 3 AktG.
  4. there shall be no cooperation with other shareholders within the meaning of section 134b (1) no. 4 of the AktG.
  5. in the event of conflicts of interest within the meaning of section 134b (1) no. 5 AktG, these shall be disclosed to the parties concerned in accordance with the statutory provisions and the further course of action shall be clarified with the parties concerned.
  6. annual reporting on the implementation of the participation policy within the meaning of Section 134b (2) of the German Stock Corporation Act (AktG) is not carried out, as no corresponding rights are exercised.
  7. voting behavior within the meaning of Section 134b (3) AktG is not published, as no participation in voting takes place.