Sustainability Related Disclosure In Accordance With Regulation (EU) 2019/2088

Disclosure on the integration of sustainability risks in our investment decision‐making process

As a company, we aim to contribute to a more sustainable, resources-efficient economy with the goal of reducing the risks and effects of climate change. In addition to observing sustainability goals in our corporate organization itself, we see it as our task to draw our customers ‘attention to aspects of sustainability in the business relationship with us. In the context of asset management and investment advice we inquire customers’ ideas and wishes in this regard and then implement them.

Environmental conditions, social exclusions and/or poor corporate governance can have negative effects on the value of our customers’ assets. These so-called sustainability risks can have direct effects on the assets, financial and earnings position and on the reputation of the investment properties. Since such risks cannot ultimately be completely avoided, we have developed specific strategies for the financial services we offer to be able to identify and reduce sustainability risks.

To reduce sustainability risks, we try to identify investments in companies and, if possible, to exclude them showing increased potential risk. With specific exclusion criteria, we see ourselves in a position to base investment decisions or provide recommendations on environmental, social, or company-related values. To this end, we usually use valuation methods recognized in the market.

The identification of suitable investments is because we invest or recommend investment funds whose investment policies are already prepared within a suitable and recognized ESG factors assessment to reduce sustainability risks. The identification of suitable investments with the aim to reduce sustainability risks can also consist in using recognized rating agencies for product selection in asset management or for recommendations in investment advice. The specific details depend on the individual agreements.

We integrate relevant sustainability risks, whether material or likely to be material, in our investment decision making processes, including the organisational, risk management and governance aspects of the company. The observance of these risks is decisive for the evaluation of the work performance of our employees and thus has a significant influence on future salary development. In this respect, the remuneration policy is in line with our strategies for including sustainability risks.

Regarding the consideration of adverse effects on sustainability factors

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

As a company, we aim to fulfil our responsibility as a financial service provider and help to avoid such effects as part of our investment decisions or investment recommendations. We are working on this and we will update this statement shortly.

However, we expressly declare that this practice does not change our willingness to contribute to a more sustainable, resource-efficient economy with the aim of reducing the risks and effects of climate change and other ecological or social grievances.