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In the following, we provide information on our approach to the topic of sustainability. We are obliged by law to make the following disclosures. We do not intend to advertise ecological or social features in our investment strategies or for other specific financial instruments.

Our strategies for incorporating sustainability risks

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 organisation itself, we see it as our task to also sensitise our clients to aspects of sustainability in the design of the business relationship they have with us. In the context of asset management (or investment advice) - but not in the context of so-called non-advisory business - we ask them about their ideas and wishes in this regard and then implement them.

Environmental conditions, social upheavals and/or poor corporate governance can have a negative impact on the value of our clients' investments and assets in several ways. These so-called sustainability risks can have a direct impact on the asset, financial and earnings situation and also on the reputation of the investment properties. Since such risks cannot be completely ruled out, we have developed specific strategies for the financial services we offer in order to identify and limit sustainability risks.

In order to limit sustainability risks, we try to identify and, if possible, exclude investments in such companies that show an increased risk potential. With specific exclusion criteria, we see ourselves in a position to align investment decisions (or investment recommendations) with environmental, social or corporate values. For this purpose, we generally resort to valuation methods recognised in the market.

The identification of suitable investments can, on the one hand, consist of investing (or recommending) in investment funds whose investment policy is already equipped with a suitable and recognised sustainability filter to reduce sustainability risks. The identification of suitable investments for the limitation of sustainability risks can also consist of our using recognised rating agencies for the product selection in asset management (or for the recommendations in investment advice). The concrete details result from the individual agreements.

Our company's strategies for the inclusion of sustainability risks are also incorporated into the company's internal organisational guidelines. The observance of these guidelines is decisive for the evaluation of our employees' work performance and thus has a significant influence on future salary development. In this respect, the remuneration policy is in line with our strategies for the inclusion of sustainability risks.

Statement on the consideration of adverse impacts on sustainability factors

Investment decisions can have adverse effects on the environment (e.g. climate, water, biodiversity), on social and labour issues and can also be detrimental to the fight against corruption and bribery.

As a matter of principle, we have a considerable interest in fulfilling our responsibility as a financial services provider and in helping to avoid such effects in the context of our investment decisions (or investment recommendations). 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 threatening bureaucratic framework conditions. Moreover, essential legal questions are still unresolved.

In order 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 the adverse effects on sustainability factors (environmental concerns, etc.) in the context of our investment decisions (or investment recommendations). We are therefore required to state on our website that we do not take these into account for the time being and until further clarification.

However, we explicitly 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 ills.

Last update: 03/08/2021