Sustainability declaration

OUR STRATEGIES FOR THE INCLUSION OF SUSTAINABILITY RISKS (ART. 3 DISCLOSURE REGULATION)
Due to legal requirements (Art. 3 Disclosure Regulation), we are obliged to provide the following information. We do not intend to advertise environmental or social features in our investment strategies or for other specific financial instruments:

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 corporate organization itself, we also see it as our task to sensitize our customers to aspects of sustainability when structuring the business relationship they have with us.

Environmental conditions, social upheavals and or poor corporate governance can have a negative impact on the value of our customers’ investments and assets in several ways. These so-called sustainability risks can have a direct impact on the net assets, financial position and results of operations, and also on the reputation of the investment properties. As such risks cannot ultimately be completely ruled out, we have developed specific strategies for the financial services we offer in order to identify and limit sustainability risks.

To limit sustainability risks, we try to identify and, if possible, exclude investments in companies that show an increased risk potential. With specific exclusion criteria, we see ourselves in a position to align investment decisions with environmental, social or corporate values. To this end, we generally make use of valuation methods recognized in the market.

One way of identifying suitable investments is to invest in investment funds whose investment policy is already equipped with a suitable and recognized sustainability filter to reduce sustainability risks. The identification of suitable investments to limit sustainability risks may also consist of our using recognized rating agencies for product selection in asset management. The specific details result from the individual agreements.

Our company’s strategies for incorporating sustainability risks are also incorporated into our internal organizational guidelines. Observance of these guidelines is decisive for the assessment of our employees’ work performance and thus has a significant influence on future salary development. In this respect, the compensation policy is in line with our strategies for incorporating sustainability risks (Art. 5 Disclosure Regulation).

DECLARATION ON THE NON-INCLUSION OF ADVERSE EFFECTS ON SUSTAINABILITY FACTORS (ART. 4 DISCLOSURE REGULATION)
Due to legal requirements (Art. 4 para. 1 a para. 2 Disclosure Regulation), we are obliged to make the following disclosures:

Investment decisions may have adverse effects on the environment (e.g. climate, water, biodiversity), on social – and employee concerns, and may also be detrimental to the fight against corruption and bribery.

We have a fundamental interest in fulfilling our responsibility as a financial services provider and in helping to avoid such effects in our investment decisions. However, according to the current state of affairs, the implementation of the legal requirements specified for this purpose is unreasonable due to the existing and still impending bureaucratic framework conditions. In addition, major legal issues are still unresolved.

To avoid legal disadvantages, we are therefore currently prevented from making a public statement to the effect that and in what way we take into account adverse impacts on sustainability factors (environmental concerns, etc.) in the context of our investment decisions. Therefore, we are required to state on our website that we do not take them into account for the time being and until further clarification (Art. 4 para. 1 b) Disclosure Regulation).

However, we expressly state that this handling does not change our willingness to contribute to a more sustainable, resource-efficient economy with the aim of reducing, in particular, the risks and impacts of climate change and other environmental or social grievances.