Our strategies for incorporating sustainability risks
(Art. 3 Disclosure Regulation)

for publication on the website
for portfolio management and investment advice
including declaration according to Art. 5 Disclosure Regulation

Due to legal requirements (Art. 3 Disclosure Regulation), we are obliged to provide the following information. We do not intend to advertise ecological or social features in our financial services or for other specific financial instruments:

  • With our focus on health, sustainability is part of our DNA. We are convinced that sustainable action creates added value – not only for society, but also for our investors. Our actions are based on the United Nations Global Compact and the UN PRIs (Principles for Responsible Investments).

  • Environmental conditions, social upheavals and or poor corporate governance can have a negative impact on the value of our customers’ investments and assets in several respects. These so-called sustainability risks can have a direct impact on the net assets, financial position and results of operations, and also on the reputation of the investment properties. As such risks cannot ultimately be completely ruled out, we have developed specific strategies for the financial services we offer in order to identify and limit sustainability risks.

  • To limit sustainability risks, we try to identify and, if possible, exclude investments in those companies that show an increased risk potential. With specific exclusion criteria, we see ourselves in a position to align investment decisions or investment recommendations to environmental, social or corporate values. For this purpose, we generally make use of valuation methods recognized in the market.

  • To identify suitable investments for limiting sustainability risks, we use recognized rating agencies for product selection in portfolio management and for recommendations in investment advice. The specific details result from the individual agreements.

  • Our company’s strategies for incorporating sustainability risks are also incorporated in the company’s internal organizational guidelines. Compliance with these guidelines is decisive for the fundamental assessment of our employees’ work performance, but has no direct influence on future salary development. However, the compensation policy is in line with our strategic objectives and is geared towards long-term and sustainable business. It does not provide incentives to take risks. To this extent, the compensation policy is in line with our strategies for incorporating sustainability risks (Art. 5 Disclosure Regulation).

    Statement on the non-consideration of adverse effects on sustainability factors
    (Art. 4 Disclosure Regulation)

    for publication on the website
    for portfolio management and investment advice

Due to legal requirements (Art. 4 Para. 1 a Para. 2 Disclosure Regulation or Art. 4 Para. 5 a Disclosure Regulation) we are obliged to provide the following information:


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

  • In principle, we have a considerable interest in fulfilling our responsibility as a financial services provider and in helping to avoid such impacts as part of our investment decisions or investment recommendations. However, we do not currently consider any adverse impacts of investment decisions on sustainability factors. There is currently insufficient availability in the market of the relevant data that must be used to determine and weight adverse sustainability impacts.

    Therefore, we are required to state on our website that we do not take them into account for the time being and until further clarification (Art. 4 para. 1 b) Disclosure Regulation or Art. 4 para. 5 b) Disclosure Regulation).

  • However, we expressly declare that this handling 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.