Sustainability

Sustainability-related disclosures pursuant to Regulation (EU) 2019/2088
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As of: 1 October 2026

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Integration of sustainability risks (Art. 3)

Environmental conditions, social disruption and/or poor corporate governance can adversely affect the value of our clients' investments and assets in a number of ways. These so-called sustainability risks, i.e. events or conditions in the environmental, social or governance spheres, can have a direct impact on the net assets, financial position, results of operations and reputation of the investee entities. As such risks cannot be ruled out entirely, we incorporate them into our general risk assessment as part of our Finanzportfolioverwaltung (portfolio management) and Anlageberatung (investment advice).

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When selecting and monitoring investments, we take sustainability risks into account to the extent that they may be material to the value of an investment, alongside other factors such as valuation, liquidity and expected return. We do not, as standard, select or exclude investments on the basis of ESG ratings or sustainability criteria. We ask clients about their sustainability preferences as part of the Geeignetheitsprüfung (suitability assessment) and, on request, incorporate them into our joint investment planning. The specific details are set out in the individual agreements.

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No consideration of adverse impacts of investment decisions on sustainability factors (Art. 4)

Investment decisions can have adverse impacts on the environment (e.g. climate, water, biodiversity) and on social and employee matters, and can also undermine efforts to combat corruption and bribery.

As a matter of principle, we have a considerable interest in living up to our responsibility as an investment services provider and in helping to avoid such impacts in our investment decisions and investment recommendations. However, implementing the relevant legal requirements first requires that they be further specified. In addition, there are regulatory initiatives that have not yet been finalised and which, once finalised, may lead to a financial product's current classification as sustainable being assessed differently in future. Furthermore, uniform, finalised market standards and uniform criteria for assessing the sustainability of financial products are currently lacking.

To avoid legal disadvantages, we are therefore currently prevented from making a public statement as to whether and in what manner we consider adverse impacts of our investment decisions or investment recommendations on sustainability factors (environmental matters etc.). We are therefore required to state on our website that, provisionally and pending further clarification, we do not consider them (Art. 4(1)(b) and Art. 4(5)(b) SFDR).

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We expressly state, however, that this approach does not alter our willingness to contribute to more sustainable, resource-efficient economic activity, with the particular aim of reducing the risks and impacts of climate change and other environmental or social harms.

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We do not consider the principal adverse impacts of our investment decisions [and our investment advice] on sustainability factors at entity level. Given our size and the nature and scale of our activities, the associated requirements for data collection, measurement and reporting would be disproportionate. We do not currently plan to consider them. We will review this decision as soon as the data situation or our business model changes materially. Irrespective of this, the investment funds we advise consider principal adverse impacts at product level. Further details can be found in the pre-contractual information of the respective funds.

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Disclosure of remuneration policy with regard to sustainability risks (Art. 5)

Our remuneration policy does not currently take sustainability risks into account.

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Contact

If you would like further information on how our company addresses sustainability, please contact our management or your personal adviser directly.

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