Conflict of Interest

Conflicts of interest, particularly in institutions providing a wide range of securities services, as well as financing and advising companies, cannot always be completely avoided. In accordance with MiFID II and other regulations, we provide the following overview of our comprehensive arrangements for handling these conflicts of interest.

Such conflicts may arise between our firm, other group companies, our management team, employees, tied agents, or other related parties and our clients, or between different clients.

Conflicts of interest may particularly occur:

• In investment advisory and asset management services due to our firm's interest in the sales of financial instruments, especially in-house products.
• Through receiving or granting inducements from or to third parties in connection with securities services for you.
• When using in-house funds in asset management.
• From performance-based compensation of employees and agents.
• Through granting incentives to our employees and agents.
• From other business activities of our firm.
• Due to relationships our firm has with issuers, such as credit relationships, participation in issuances, and collaborations.
• In the creation of marketing material about securities offered to clients.
• By gaining access to non-public information.
• From personal relationships between our staff or management and related parties.
• By the involvement of these persons in advisory or supervisory boards.

To prevent external interests from influencing advisory services, order execution, asset management, or financial analysis, we commit ourselves and our employees to high ethical standards. We expect diligence, integrity, lawful and professional conduct, compliance with market standards, and always prioritizing client interests.

Specifically, we implement measures such as:

• Establishing organizational procedures to safeguard client interests in investment advisory and asset management, e.g., through product approval processes.
• Rules on the acceptance and granting of inducements and their disclosure.
• Creating confidentiality areas by establishing information barriers, separation of responsibilities, and/or spatial separation.
• Maintaining insider or watch lists to monitor sensitive information and prevent insider trading.
• Keeping a restricted list to manage potential conflicts through business or advisory restrictions or bans on financial analysis.
• Requiring employees to disclose securities transactions when conflicts of interest may arise in their duties.
• Training our staff for awareness.
• Disclosing unavoidable conflicts to affected clients before business transactions or advisory sessions.
• Crediting inducements directly to the client’s account as legally required.

We specifically highlight:

• In asset management, you've delegated the decision-making for buying and selling financial instruments to your asset manager under agreed investment guidelines. Decisions on which funds to invest in may present conflicts if the funds' manager or advisor is the asset manager, who may receive additional compensation. We counter these risks with appropriate organizational measures, such as a client-interest-focused investment selection process. Before entering into asset management, we'll disclose the extent of inducements and provide an account of them.
  
  
• In performance-based compensation agreements, there’s a risk of disproportionate risk-taking by the asset manager. To mitigate this, we have internal monitoring and combine other fixed remuneration components. Conflicts of interest might also arise as we advise funds while managing assets and thus invest in funds where we are advisors. But this is no basis for selection in asset management.
  
  
• We receive free inducements from service providers related to our securities business, like marketing materials, training, and technical services. These are not directly linked to client services and are used to maintain high service quality and improvements.

In our financial analyses, we disclose relevant conflicts. Employees must report known potential conflicts immediately to the independent compliance officer.

After investigation, the compliance officer, with department and management input, proposes solutions to conflicts in our clients’ interest.

The compliance officer maintains a register of potential and actual conflicts and received inducements from issuers and service providers. This record is regularly reviewed and updated — unavoidable conflicts are always resolved in the client's interest.

We've provided this information as part of our obligation under asset management agreements to disclose everything obtained under the contract.

We're happy to provide further details upon request at 00352 24 69 35-0.