Disclosures

Sustainability

Our Strategies for Incorporating Sustainability Risks

(Art. 3 Disclosure Regulation including declaration according to Art. 5 Disclosure Regulation)

We are obliged to provide the following information due to legal requirements.

  • As a company, we want to contribute to a more sustainable, resource-efficient economy with the aim of reducing the risks and impacts of climate change in particular. In addition to observing sustainability goals in our own corporate organization, we see it as our task to also sensitize our clients to aspects of sustainability in the design of their business relationship with us.
  • Environmental conditions, social upheavals and/or poor corporate governance can have negative impacts on the value of our clients’ investments and assets in multiple ways. These so-called sustainability risks can have direct effects on the asset, financial and earnings situation and also on the reputation of the investment objects. Since such risks cannot ultimately be completely ruled out, we have developed specific strategies for the securities services we offer to identify and limit sustainability risks.
  • To limit sustainability risks, we try to identify and, if possible, exclude investments in companies that have an increased risk potential. With specific exclusion criteria, we see ourselves in a position to align investment decisions or investment recommendations with environmental, social or corporate values. For this purpose, we usually rely on market-recognized valuation methods.
  • The identification of suitable investments can consist, on the one hand, of investing in or recommending investment funds whose investment policy is already equipped with a suitable and recognized sustainability filter for reducing sustainability risks. The identification of suitable investments to limit sustainability risks can also consist of relying on recognized rating agencies for product selection in asset management or for recommendations in investment advice. The specific details result from the individual agreements.
  • Assuming we succeed in identifying companies with increased risk potential and excluding them from investment, the remaining sustainability residual risks should only have a minor adverse effect on returns and not deviate significantly from the general market risk. Sustainability risks that are not identifiable to us in the identification process described above may have a significantly greater impact on returns.
  • Our remuneration policy is aligned with our strategies for considering sustainability risks. As part of our remuneration policy, we ensure that our employees are not remunerated or evaluated in a way that conflicts with our duty to act in the best interests of clients. Our remuneration policy also does not create incentives to recommend investments that do not correspond to the client’s investment strategy. Moreover, our remuneration structure does not encourage any willingness to recommend investment products with high sustainability risks.

 

Declaration on Non-Consideration of Adverse Impacts on Sustainability Factors

(Art. 4 Para. 1 Letter b) or Art. 4 Para. 5 Letter b) Disclosure Regulation)

We are obliged to provide the following information due to legal requirements:

  • Investment decisions can have adverse impacts on so-called sustainability factors (environmental, social and employee concerns, respect for human rights, anti-corruption and anti-bribery matters).
  • We have a fundamental interest in fulfilling our responsibility as a securities institution and contributing to avoiding such impacts in the context of our investment decisions or recommendations. However, the implementation of the existing legal requirements is currently unreasonable due to the existing and still threatening bureaucratic framework conditions. Moreover, essential legal questions are still unresolved.
  • To avoid legal disadvantages, we are therefore currently prevented from making a public declaration as to whether and in what way we consider adverse impacts on sustainability factors in the context of our investment decisions or investment recommendations. Therefore, we are obliged to declare on our website that we do not consider these for the time being and until further clarification.
  • Promotion of environmental or social characteristics within the meaning of Art. 8 Disclosure Regulation is not intended. Sustainable investments within the meaning of Art. 9 Disclosure Regulation are not targeted.
  • However, we expressly declare that this handling does not change our willingness to contribute to a more sustainable, resource-efficient economy with the aim of reducing the risks and impacts of climate change and other ecological or social grievances in particular.
  • As we currently do not offer a sustainability concept, we are obliged to provide the following notice according to Article 7 of Regulation (EU) 2020/852 (Taxonomy Regulation), which applies to both investment recommendations we provide as part of investment advice and investments made within the agreed investment guidelines as part of asset management: The investments underlying this financial product do not take into account the EU criteria for environmentally sustainable economic activities.

 

Status & published on 21.08.2024