Our Strategies for integrating Sustainability Risks
(Art. 3 Regulation (EU) 2019/2088 “Disclosure Regulation”)
On the basis of statutory provisions (Art. 3 of the Disclosure Regulation), we are required to provide the following information: We do not intend to advertise environmental or social criteria in our investment strategies or for other specific financial instruments:
- We, as a Company, would like 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 adhering to sustainability goals in our own corporate organisation, we also consider it our duty to raise our clients’ awareness of sustainability considerations when structuring their business relationships with
- Environmental conditions, social upheaval and/or poor corporate governance can have a negative impact on the value of our clients’ investments and assets in a number of ways. These so-called sustainability risks can have a direct impact on the assets and financial and earnings situation as well as on the reputation of the investment assets. Because such risks cannot be completely ruled out in the end, we have developed specific strategies for the financial services we offer so that we can identify and limit sustainability risks.
- To limit sustainability risks, we attempt to identify and, if possible, exclude investments in companies that exhibit elevated risk potential. With specific exclusion criteria, we consider ourselves to be in a position to align investment decisions with environmental, social and corporate values. To this end, we generally use valuation methods that are recognised in the market.
- One way of identifying suitable investments is to invest in investment funds whose investment policy already has established a suitable and recognised sustainability filter to reduce sustainability risks. Identifying suitable investments to limit sustainability risks can also involve using recognised rating agencies for product selection as part of our Asset Management. The specific details are determined by the individual agreements.
- Our Company’s strategies for incorporating sustainability risks are also incorporated into the Company’s internal organisational guidelines. Compliance with these guidelines is essential for the evaluation of our employees’ work performance and therefore has a significant influence on future salary growth. In this respect, the remuneration policy is in line with our strategies for the inclusion of sustainability risks (Art. 5 Disclosure Regulation).
Declaration on not taking into consideration adverse effects on sustainability factors
(Art. 4 Regulation (EU) 2019/2088 “Disclosure Regulation”)
On the basis of statutory provisions (Art. 4 para. 1 a, 2 of the Disclosure Regulation), we are required to provide the following information:
- Investment decisions can have adverse impacts on the environment (e.g. climate, water, biodiversity) and on social and labour issues; they can 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 impacts in the context of our investment However, the implementation of the legal requirements specified for this is, based on the current circumstances, unreasonable due to existing and pending bureaucratic framework conditions. In addition, significant legal questions remain unresolved.
- Consequently, in order to avoid the potential for legal disadvantages, we are 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. For this reason, we are required to state on our website that we will not take them into account for the time being and until further clarification (Art. 4 para. 1 let. b) Disclosure Regulation).
- However, we expressly declare that this treatment does not affect our willingness to contribute to a more sustainable, resource-efficient economy with the aim, in particular, of reducing the risks and impacts of climate change and other environmental or social ills.