Commitment to a sustainable future.

According to Art. 6 (1) and (2) of the Disclosure Regulation, we are required to provide the following information:

• As a company, we want to make a contribution to a more sustainable, resource-efficient economy with the aim of reducing the risks and effects of climate change in particular. In addition to respecting sustainability goals in our corporate organization itself, we also see it as our task to sensitize our customers to aspects of sustainability when designing the business relationship with us.
• Environmental conditions, social distortions and/or poor corporate governance can have negative effects on the value of our clients' investments and assets in several ways. These so-called sustainability risks can have a direct impact on the net assets, financial and earnings situation as well as on the reputation of investment properties. Since such risks cannot ultimately be completely ruled out, we have developed specific strategies for the investment services we offer in order to be able to identify and limit sustainability risks.
• To limit sustainability risks, we try to identify and, if possible, exclude investments in companies that have an increased risk potential. With specific exclusion criteria, we are able to base investment decisions or investment recommendations on environmental, social or company-related values. For this purpose, we usually use valuation methods recognized in the market.
• Identifying suitable investments may consist, on the one hand, of investing in investment funds or recommending investment funds whose investment policy is already equipped with a suitable and recognized sustainability filter to reduce sustainability risks. Identifying suitable investments to limit sustainability risks may also involve using recognized rating agencies for product selection in asset management or for recommendations in investment advice. The specific details are set out in the individual agreements.
• Provided that we are able to identify companies with increased risk potential and exclude them from an investment, the remaining sustainability risks are likely to have only a minor adverse effect on returns and not significantly deviate from the general market risk. Sustainability risks that are not apparent to us in the identification process described above can have a significantly greater impact on returns.

Statement on disregard of adverse effects on sustainability factors (Art. 7 Disclosure Regulation)

Pursuant to Art. 7 para. 2 in conjunction with Art. 4 para. 1 letter b) and Art. 4 para. 5 letter b) Disclosure Regulation, we are required to provide the following information:

• Investment decisions can have adverse effects on so-called sustainability factors (environmental, social and employee concerns, respect for human rights, the fight against corruption and bribery).
• We generally have a significant interest in meeting our responsibilities as an investment institution and helping to avoid such effects as part of our investment decisions and recommendations. However, according to the current state of affairs, the implementation of the existing legal requirements is unreasonable due to the existing and still impending bureaucratic framework conditions. In addition, significant legal issues remain unresolved.
• In order to avoid legal disadvantages, we are therefore currently prevented from making a public statement that and in what way we take adverse effects on sustainability factors into account as part of our investment decisions or investment recommendations. We are therefore required to make a statement to the effect that we will not take this into account provisionally and until further clarification (Art. 4 para. 1 letter b) or Art. 4 para. 5 letter b) Disclosure Regulation).
• An advertisement of ecological or social characteristics within the meaning of Art. 8 Disclosure Regulation is not intended. Sustainable investments within the meaning of Art. 9 Disclosure Regulation are not sought.
• However, we expressly state that this approach does not change our willingness to contribute to a more sustainable, resource-efficient economy with the aim, in particular, of reducing the risks and effects of climate change and other ecological or social grievances.