Legal Notice

Introduction / Summary

On March 10, 2021 the Regulation (EU) 2019/2088 of November 27, 2019 on sustainability-related disclosures in the financial services sector (Sustainable Finance Disclosure Regulation, SFDR) entered into force. This regulation aims to support sustainable investment by obliging financial market participants and financial advisors to disclose sustainability-related risks to investors and clients.
Pursuant to Article 3 SFDR, financial market participants shall be obliged to publish information about the integration of sustainability risks within investment decision-making procedures and in investment advice. The approach pursued by Deutsche Oppenheim will be explained in more detail below.

Deutsche Oppenheim Family Office AG applies an overarching approach to the management of sustainability that is set out in a number of group level policies and procedures. The group-wide Sustainability Policy delineates our main sustainability principles as well as the key requirements and responsibilities in connection with sustainability-related enquiries, non-financial sustainability
reporting and ratings, environmental and social due diligence in the context of reputational risk management, and, together with relevant risk frameworks and broader commitments, provides relevant context regarding the Deutsche Oppenheim's view on sustainability topics.

Whilst Deutsche Oppenheim Family Office AG does not currently apply an overarching formal policy regarding the integration of sustainability risks in the investment decision-making and advisory processes, Deutsche Oppenheim Family Office AG still takes sustainability risks into account, as further described in the following sections. In addition, business areas are working towards inclusion of the integration of sustainability risks within relevant policies and guidelines. These will be further enhanced on an ongoing basis as more sustainability related data becomes available over time.

Definition of sustainability risks

The following examples can help to clarify sustainability risks:

• As a result of the occurrence of extreme weather events as a consequence of climate change (known as physical risks), for example, production locations of individual companies or entire regions can be impaired or destroyed, leading to production stoppages, rising costs to restore the production locations and higher insu­rance costs. Furthermore, extreme weather events as a consequence of climate change, such as long periods of low water during droughts, can impair the transport of goods or even make it impossible.
• There are also risks in connection with the changeover to a low-carbon economy (known as transition risks): for example, political measures can lead to fossil fuels becoming more expensive and/or scarcer (examples: fossil-fuel phase-out, CO₂ tax) or to high investment costs as a result of requirements to renovate buildings and plant. New technologies can displace familiar technologies (e.g. electric mobility), and changes in custo­mer preferences and expectations in society can endanger companies’ business models if they do not react in time and take counter measures (by adjusting their business model, for example).
• A substantial increase in physical risks would require a more abrupt changeover in the economy, which in turn would lead to higher transition risks.
• Social risks arise from aspects such as non-compliance with labour law standards (for example, child labour and forced labour) and compliance with occupational health and safety regulations.
• Examples of risks that arise within the scope of corporate management due to inadequate corporate gover­nance and that can lead to high fines include non-compliance with taxpayer honesty and corruption.

Sustainability risks affect the following traditional risks of investments in securities in particular, and if they occur, could have a significantly negative effect on the yields of an investment in securities:

• Sector risk
• Price change risk
• Issuer / Credit risk
• Dividend risk
• Liquidity risk
• Currency risk

Method of including sustainability risks for Financial Markets Participants and Financial Advisor

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Deutsche Oppenheim Family Office AG, 5299003G9CMV5CY1FU81

Summary

Deutsche Oppenheim Family Office AG, 5299003G9CMV5CY1FU81 considers principal adverse impacts of its investment decisions on sustainability factors. The present statement is the consolidated statement on principal adverse impacts on sustainability factors of Deutsche Oppenheim Family Office AG (Deutsche Oppenheim).

This statement on principal adverse impacts on sustainability factors covers the reference period from 1 January to 31 December 2024.

This statement is provided under the Sustainable Finance Disclosure Regulation (SFDR) – Regulation (EU) 2019/2088, which defines Financial Market Participants (FMPs) and in scope financial products. Therefore, this disclosure of principal adverse impacts applies to Deutsche Oppenheim to the extent it is an investment firm which provides portfolio management and investment decision making to EU clients.

Principal Adverse Impacts are defined by the European Commission as “negative, material, or likely to be material effects on sustainability factors that are caused, compounded by, or directly linked to investment decisions and advice performed by the legal entity”.

Since 10 March 2021, Deutsche Oppenheim makes data relating to selected PAIs transparent against the investment universe, enabling informed decisions in the selection process for the construction of relevant financial products. The focus is on making the data available within the processes for selection of underlying products for Deutsche Oppenheim managed portfolios. Deutsche Oppenheim leverages ISS STOXX ESG Research to gather the necessary indicators data and manage its investable product universe.

It is important that Deutsche Oppenheim, given its fiduciary capacity, makes all investment decisions in the best interests of its clients, while also considering financial and risk factors. Evaluating principal adverse impacts is an additional consideration for Deutsche Oppenheim portfolio managers during the investment decision-making process; however, it does not necessarily take precedence over other factors.

Deutsche Oppenheim performs quantitative reporting on all mandatory principal adverse impacts specified in the SFDR; however, as FMP, it focuses on prioritized principal adverse impact indicators within its investment process.

In Markets in Financial Instruments Directive (MiFID) applicable jurisdictions, clients must be asked about their investment objectives and financial circumstances which also includes their sustainability preferences. Within Deutsche Oppenheim, both ESG and non-ESG strategies are offered depending on the sustainability preferences of the client.

Deutsche Oppenheim incorporates PAI data into the security selection via ISS STOXX ESG Platform solutions, facilitating informed decision-making and consideration by portfolio managers during the security selection.

The prioritized PAIs are integrated into the investment processes for Deutsche Oppenheim in-house ESG managed portfolios, that follow Deutsche Oppenheim ESG minimum criteria. These are part of the security universe lists provided by ISS STOXX ESG to enable informed decision making and consideration by portfolio managers during security selection. These prioritized PAIs are as follows:

• Greenhouse gas (GHG) emissions

  • Exposure to fossil fuels

    Industries that derive revenues from the exploration, mining, extraction, distribution or refinement of solid, liquid or gaseous fuels (i.e., coal, oil, natural gas)

  • Carbon emissions

    The carbon dioxide equivalents released by a company, measured by volume and intensity




• Social and employee matters

  • Compliance with United Nations Global Compact principles

    At a minimum, companies need to fulfil fundamental responsibilities in the areas of human rights, labour, the environment and anti-corruption

  • Exposure to controversial weapons

    Countries that have an industry tie to anti-personnel mines, cluster munitions, chemical weapons and biological weapons. An industriy tie includes ownership, manufacture or investment

Description of the principal adverse impacts on sustainability factors

Deutsche Oppenheim discloses data related to 18 PAI indicators (16 mandatory and 2 optional) on sustainability factors for products where it acts as a FMP and in scope of the SFDR. The investment universe includes all assets including investee companies, sovereign issuers, indirect investments (Funds), derivatives, commodities, and cash. The calculation for the impact value is based on principal adverse impact data for investee companies and sovereigns and indirect investment products (Funds) sourced from ISS STOXX ESG Research, assessed against four snapshots of the assets managed during the reference period (31 March / 30 June / 30 September / 31 December).

Actions taken, and actions planned, and targets set for the next reference period

Deutsche Oppenheim has opted to defer actions and target setting for the next reference period to await outcomes of potential new regulations currently under discussion - including the implementation clarity on timelines affecting Final Report on draft RTS on the review of PAIs and financial product disclosures in the SFDR released on 04 December 2023; and an ongoing review by the European Commission (EU) call for evidence on SFDR.

Furthermore, ESG data concerning the PAIs is still developing due to various data limitations. Some of these limitations include (inter alia) - limited ESG data availability across asset-classes, delays in data, and gaps in coverage that affect data quality, reliance on estimated data, differing proprietary methods for evaluating specific PAIs, and a wide array of ESG perspectives, approaches, methodologies, and disclosure standards contributing to this ongoing development. This requires a need for consistent reporting standards, improved sustainability methodologies, and efforts by market participants to enhance data accessibility.

Deutsche Oppenheim will review its current approach on an annual basis.

Adverse sustainability indicator – Impact Value and Explanation

The calculation for the impact value is based on principal adverse impact data per consolidated investment holdings of Deutsche Oppenheim, including sub-entities, assessed against quarterly data during the 2024 reference period (31 March / 30 June / 30 September / 31 December). These PAI impact values are updated annually showing previous year’s numbers by way of comparison (up to 5 years), in this case, PAI values for 2024, 2023 and 2022 investments.

The investment universe for which Deutsche Oppenheim acts as a financial market participant includes all assets including investee companies, sovereign issuers, indirect investments (funds), derivatives, commodities, and cash. Last year – compared to FY 2022, following a forward -looking approach with an aim to continuously evolve our internal procedures and enhancements of data analytics capabilities, Deutsche Oppenheim has updated its approach to calculating adverse impacts and, for this reporting period, includes all investments held in the portfolio for the calculation of individual PAIs. This change in methodology means that the figures are not directly comparable year on year. To facilitate this comparison, additional "Memo" values have been included in the table. These corresponding approximate values for 2022 are based on the updated methodology to enable a more consistent year on year comparison. Further information is also included in the explanation column for each adverse impact, where necessary.

The data used for the disclosure of sustainability indicators is provided by ISS STOXX ESG. This includes information on corporate, sovereign, and supranational issuers, covering both mandatory and additional Principal Adverse Impact (PAI) indicators as defined by the SFDR.

The underlying methodology is based on a range of ISS STOXX ESG research products. In cases where reported company data is not available, ISS STOXX ESG applies modelled estimates and well-founded proxies. Portfolio-level metrics are calculated in accordance with the Regulatory Technical Standards (RTS) issued by the European Commission, as well as further guidance published by the European Supervisory Authorities (ESAs).

In line with ESAs recommendations, the PAI indicators are calculated using the total value of all investments in the portfolio as the denominator. This includes positions for which the respective PAI indicator may not be applicable or for which data is unavailable. This approach effectively imputes a value of zero for missing data, which may result in lower reported PAI values compared to a calculation method that only includes investments with available and relevant data.

The “coverage” metric indicates the percentage of portfolio positions for which data is available per PAI indicator, relative to the total portfolio. According to the ISS ESG Corporate Rating methodology, certain PAI indicators are only material for specific industries. Accordingly, data coverage may be lower for these indicators, as disclosure typically occurs only within relevant sectors. Where applicable, an additional industry-adjusted coverage rate is provided, focusing only on corporate assets within sectors for which the metric is considered material.

Most quantitative indicators are sourced directly from company disclosures. However, for selected indicators—such as greenhouse gas emissions or non-renewable energy production—data may be estimated or modelled where no reliable company-reported figures are available.

The PAI indicators shown in this report reflect either point-in-time assessments (e.g., the share of investee companies with certain characteristics) or performance over a specified period (e.g., average emission intensity over a fiscal year).

For the current reference period, Deutsche Oppenheim includes information on the coverage¹, which is determined from ISS STOXX ESG solution.

¹ Coverage is included as voluntary additional information. It is determined from the results of the SUSTAINABLE FINANCE DISCLOSURE REGULATION PORTFOLIO REPORT by ISS STOXX. These results are based on the issuer's inclusion in the coverage universes established by the provider, along with the available data and estimates. For more comprehensive information, please refer to the publicly available ISS STOXX methodology documentation available on their website.

² Coverage is included as voluntary additional information. It is determined from the results of the SUSTAINABLE FINANCE DISCLOSURE REGULATION PORTFOLIO REPORT by ISS STOXX. These results are based on the issuer's inclusion in the coverage universes established by ISS STOXX, along with the available data and estimates. For more comprehensive information, please refer to the publicly available ISS STOXX methodology documentation available on their website.

³ Explanation has been consolidated across all adverse impacts to highlight the general changes in data that need to be considered when considering year on year comparisons

⁴ For its current quantitative reporting Deutsche Oppenheim Family Office AG will not include planned actions or apply thresholds for the following reference period, due to data limitations and regulatory evolution.

⁵ Due to the significant methodology changes in the calculation of adverse impacts, additional “memo” values have been included for Y2022 in order to show a more comparable year on year change. These have been calculated based on 2022 holdings, but against 2023 adverse impact data, therefore should not be considered as an exact representation of Y2022 and only a guide.

Description of policies to identify and prioritize principal adverse impacts on sustainability factors

Sustainability has been a strategic priority for Deutsche Oppenheim as being part of Deutsche Bank Group since the Deutsche Bank AG announced its “Compete to Win” strategy in July 2019. In reference year 2024, Deutsche Bank AG continued to focus on the four pillars of its sustainability strategy – Sustainable Finance, Policies & Commitments, People & Own Operations, and Thought Leadership & Stakeholder Engagement.

Governance

The Management Board of Deutsche Bank has delegated sustainability-related decisions to the Group Sustainability Committee, one of the bank’s eight Management Board Committees. It was established as a decision-making body for sustainability-related matters across Deutsche Bank Group (excluding DWS). It manages its tasks on Group level, oversees and aligns the bank’s sustainability strategy holistically across business segments. The Group Sustainability Committee is chaired by the Chief Executive Officer with the Chief Sustainability Officer acting as deputy. Deutsche Bank AG maintains a Chief Sustainability Office, whose head reports into the Chief Executive Officer of Deutsche Bank AG. It centrally drives sustainability and ensures consistency across Deutsche Bank.

Principal Adverse Impacts (“PAI”) Policy

Within Deutsche Bank Private Bank, of which Deutsche Oppenheim is being a part of, Deutsche Bank’s PAI policy describes how Deutsche Bank prioritizes PAIs on sustainability factors and considers them in investment decision-making across processes and product offering for managed portfolios. The PAI Policy is managed by the Global ESG Solutions team within the Private Bank, and it received approval from the Global Head of ESG Solutions on June 12, 2025. The policy also applies to Deutsche Oppenheim as being part of Private Bank of Deutsche Bank Group.

The prioritized principal adverse impacts are as follows:

1. Greenhouse gas (GHG) emissions
   • Exposure to fossil fuels: Industries that derive revenues from the exploration, mining, extraction, distribution or refinement of solid, liquid or gaseous fuels (i.e., coal, oil, natural gas)
   • Carbon emissions: The carbon dioxide equivalents released by a company, measured by volume and intensity
2. Social and employee matters
   • Compliance with United Nations Global Compact principles: At a minimum, companies need to fulfil fundamental responsibilities in the areas of human rights, labour, the environment and anti-corruption
   • Exposure to controversial weapons: Companies that have an industry tie to landmines, cluster munitions, chemical or biological weapons. An industry tie includes ownership, manufacture or investment.

PAIs are reviewed within relevant Deutsche Bank forums and prioritized in line with:

Deutsche Bank´s Sustainability Strategy One of the key commitments is the target to achieve net-zero emissions which is outlined in the bank’s initial transition plan (published in October 2023) and in the bank’s Sustainability Statement in the 2024 Annual report. Deutsche Bank has also integrated social aspects into its strategy. This includes the social dimension of sustainable finance, adherence to human rights, the promotion of a diverse and qualified workforce, adequate working conditions, and a strong focus on client centricity.

1. Overall process integration
   1. Sustainability preferences: Clients must be asked for their sustainability preferences on a regular basis, under MiFID applicable jurisdictions. If clients wish to take their sustainability preferences into account, further details on the customer’s sustainability preferences are requested. If clients have a preference for investments in financial instruments that consider PAIs on sustainability factors in accordance with the Disclosure Regulation, clients can choose families of PAIs (e.g. greenhouse gas emissions, biodiversity, social and employee matters etc.)
      
      For clients with sustainability preferences, Deutsche Oppenheim provides products and investment strategies that correspond to these preferences, where they are available.
   2. Investment processes: Deutsche Oppenheim incorporates PAI data into the security selection via ISS STOXX ESG Platform solutions, facilitating informed decision-making and consideration by portfolio managers during the security selection. Portfolio managers consider this information alongside other financial and non-financial information before making informed decisions as a fiduciary on behalf of clients.
      
      Deutsche Oppenheim does not engage directly with investee companies and therefore does not influence their business activities or risks.
2. ESG-specific process integration

   In-house ESG managed portfolios:Prioritized PAIs are considered in Deutsche Oppenheim´s ESG solutions.
   
   The PAIs are covered via DB ESG minimum criteria for Deutsche Oppenheim ESG mandates, which mandates the restrictions on and exclusions of certain sectors (e.g. thermal coal) and norm violations (e.g. UN Global Compact Principals, OECD Guidelines, controversial weapons).
   
   Deutsche Oppenheim also prioritizes investments in securities which show better overall management of ESG risks than peers by having a minimum ESG rating (e.g. minimum ISS STOXX ESG Rating of “C-”). The applicable criteria are described in the Deutsche Bank ESG Investments Framework.
   
   Additional due diligence of ESG criteria might be undertaken by portfolio managers for a deeper analysis of the ESG risks and opportunities that could affect portfolio performance.

Engagement policies

Where Deutsche Oppenheim acts as a financial market participant for financial products within the scope of the Disclosure Regulation, it does not currently engage directly with investee companies and therefore does not influence their business activities or risks.

References to international standards

Deutsche Oppenheim is embedding sustainability into its policies, processes, and products, focusing on the four dimensions of Deutsche Oppenheim´s Sustainability Strategy: Sustainable Finance, Policies and Commitments, People and Operations as well as Thought Leadership and Stakeholder Engagement. Making progress in these dimensions will enable Deutsche Bank to maximize its contribution to the achievement of the Paris Climate Agreement’s targets and the United Nations (UN) Sustainable Development Goals.

To underpin Deutsche Oppenheim´s long-standing commitment to sustainability, it follows internationally recognized principles for sustainable business and banking conduct such as:

• the 10 principles of the UN Global Compact,
• the Principles for Responsible Banking convened by the United Nations Environment Programme Finance Initiative
• the UN Guiding Principles on Business and Human Rights

By taking into account certain internationally recognized standards, such as the Principles of the United Nations Global Compact Principles, setting a maximum involvement within certain sectors, e.g. thermal coal and/or unconventional oil/gas and by excluding activities in connection to e.g. controversial weapons such as landmines, cluster munitions, biological and chemical weapons, Deutsche Oppenheim where acting as a Financial Market Participant, indirectly aligns its portfolio management that considers ESG criteria to certain principal adverse impacts.

Within portfolio management services, Deutsche Oppenheim collaborates with third-party data providers for data related to sustainability factors of investee companies for direct as well as indirect investments. For portfolio management that considers ESG criteria this includes, but is not limited to, assessing whether the investee universe has exposure to UN Global Compact or OECD Violations (PAI 10), and Controversial weapons (PAI 14).

For portfolio management services, Deutsche Oppenheim is engaged in developing net-zero aligned forward-looking climate scenarios, which are aligned to the Paris Climate Agreement. However, currently Deutsche Oppenheim AG does not consider climate-scenarios in the investment decision process.

Historical Comparison

Please refer to the 'Description of the principal adverse impacts on sustainability factors' to review the comparison of the PAI values for the last three years: 2024 PAI values compared to 2023 PAI values and 2022 PAI values. The overall PAI data coverage from underlying securities increased Year-over-Year (YoY) most likely due to changes in portfolio composition and ISS STOXX updated methodology. These methodology updates impacted the majority of PAIs for the 2024 and 2023 reference periods, unlike the 2022 reference period. As a result, the comparisons may not be fully comparable. The individual PAI metrics, and YoY variation are disclosed in the table above. Deutsche Oppenheim currently uses the PAI data included in this statement for regulatory disclosure purposes only.

Deutsche Oppenheim Family Office AG When providing investment, Deutsche Oppenheim Family Office AG (‘Deutsche Oppenheim’) considers the principal adverse impacts on sustainability factors, which are explained below. The principal adverse impacts on sustainability factors are dealt with in Article 4 of Regulation (EU) 2019/2088 of 27 November 2019 on sustainability-related disclosures in the financial services sector (Sustainable Finance Disclosure Regulation – SFDR). These principal adverse impacts on sustainability factors are specified in more detail in Article 11 of Delegated Regulation (EU) 2022/1288 of 6 April 2022.
In its capacity as an investment and insurance advisor, Deutsche Oppenheim takes the following principal adverse impacts on sustainability factors into account for all finance products managed by EU legal entities within the meaning of the SFDR managed portfolios, alternative investment funds (AIF), insurance-based investment products (IBIP), pension products, pension schemes, undertakings for collective investments in transferable securities (UCITS), pan-European
personal pension products (PEPP):

• Exposure to fossil fuels
  Industries that derive revenues from the exploration,
  mining, extraction, distribution or refinement of solid,
  liquid or gaseous fuels (i.e. coal, oil, natural gas)
• Carbon emissions
  The carbon dioxide equivalents released by a company,
  measured by volume and intensity
• Complinace with United Nations Global Compact
  principles
  At a minimum, companies need to fulfil fundamental
  responsibilities in the areas of human rights, labour, the
  environment and anti-corruption
• Exposure to controversial weapons
  Industries that derive revenues from the manufacture or
  sale of controversial weapons (i.e. anti-personnel mines,
  cluster munitions, chemical, biological, radiological and
  nuclear weapons)

EU managers or manufacturers of managed financial products (financial market participants as defined by the SFDR) that, at the reporting date, meet the criterion of having on average more than 500 employees during the financial year are required to publish a statement on their strategy for considering and addressing the principal adverse impacts. 

As part of our advisory due diligence process, we will review the principal adverse impact statements published by financial market participants and note where their actions and strategies to consider adverse impacts on sustainability factors align with those of Deutsche Oppenheim. If, in the opinion of Deutsche Oppenheim, a statement contains significant departures from the requirements laid down by Deutsche Oppenheim, this may lead to us excluding the relevant manufacturer’s products from Deutsche Oppenheim’s investment advice. Where managers or manufacturers of managed financial products publish indicators of adverse sustainability factors for their financial products from 30 June 2023 onwards, we will incorporate these into our overall qualitative assessment of these financial products. We have not defined any thresholds, rankings or weightings for the indicators in this regard. A key issue for consideration in the assessment processes is whether the indicators for a financial product improve over time. The enhanced due diligence process provides the basis for more clarity and transparency regarding the principal adverse impacts that financial market participants consider in their investment decisions. This enables us to identify products that do not meet our quality requirements and can result in us not recommending those financial products.

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The consideration of sustainability and sustainability risks is an integral part of the performance-based determination of variable compensation at Deutsche Bank Group, both for employees and the Management Board. Where appropriate, we have set sustainability-related targets which include financial and nonfinancial targets such as sustainable financing and investment volumes as well as culture and conduct. Furthermore, we expect all employees of Deutsche Oppenheim Family Office AG to adhere to the sustainability principles stipulated in our code of conduct, which aim to generate sustainable value for our clients, employees, investors and society at a large. The code of conduct is embedded in our governance,
policies, processes, and control systems.

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