When using this website, please note the following information ("Terms of Use").
Deutsche Oppenheim Family Office AG (hereinafter referred to as “Deutsche Oppenheim”) grants to natural persons visiting this website (hereinafter referred to as “user(s)”) revocable, non-exclusive, non-transferable and limited permission to access and use the website and the materials contained therein. This permission shall only apply to the extent that the user exclusively pursues the objectives outlined below and complies with the restrictions set out in these Terms of Use. The user is prohibited from disrupting or attempting to disrupt the operation of the website in any way.
2.1 Regional legal restrictions
This website contains general information about the type of products and services offered by Deutsche Oppenheim. This website is not directed at individuals in countries or jurisdictions where the publication or distribution of such information or information about products or services described on this website is prohibited, whether by reason of that person's nationality, place of residence or otherwise. Persons subject to such restrictions may not use this website.
2.2 Accuracy and reliability of information and functionalities
The website and its content are provided on an “as is” basis.
With the exception that liability cannot be limited under applicable law and except for liability for gross negligence and wilful misconduct, Deutsche Oppenheim, its respective licensors or other third parties that make information or functionality available on or through this website do not warrant that Deutsche Oppenheim, its respective licensors or any other third party will guarantee the
(i) timeliness, accuracy or completeness of the information provided on the website as intended, including all pricing information;
(ii) accuracy of the results obtained by the user or by any other third party using the website.
With the exception that liability cannot be limited under applicable law and except for liability for gross negligence and wilful misconduct, Deutsche Oppenheim makes no warranty whatsoever with respect to information provided by third parties on or through the website.
Any opinions or estimates expressed as Deutsche Oppenheim's opinions or estimates reflect only Deutsche Oppenheim's opinions or estimates at the time of publication and are subject to change without notice.
They might deviate from the opinions or assessments of other Deutsche Bank group companies.
To the extent required by applicable law, the contents of this website do not constitute any representation, expressed or implied, including – but not limited to – the merchantability of any products or securities displayed, the absence of third-party rights or the suitability for a particular purpose. Deutsche Oppenheim neither warrants that the website or any function or content thereof will be uninterrupted or error-free, that defects will be corrected or that the website or the server on which the website is hosted or any connected system are free of viruses or other harmful components.
2.3 References to other websites (Links)
This website may contain references to other websites (links), which in turn may reproduce content produced or made accessible by Deutsche Oppenheim's independent operators. Deutsche Oppenheim is not responsible for information on websites that can be accessed via links on this website and therefore assumes no liability for the content of third-party websites. This also applies to stock exchange, financial and other price-sensitive information that is transferred from systems of third-party providers to these websites online in real time or subject to a time delay.
Opinions or recommendations expressed on these independent websites are solely those of the providers or operators independent of Deutsche Oppenheim and do not represent the opinion or recommendation of Deutsche Oppenheim. The mere existence of a reference to such websites does not constitute a recommendation or any other form of confirmation by Deutsche Oppenheim in favour of such websites, their content or their operators.
2.4 Changes to the website
Deutsche Oppenheim reserves the right to change, suspend or completely cease operation of the website, including the services, information, features or functions offered on the website accessible within the scope of the intended website use at any time. Deutsche Oppenheim further reserves the right to limit the use of individual features, functions or services or to restrict access to parts or all of the website without prior notice.
Users visit the website at their own risk. Users bear the sole responsibility and the sole risk of loss arising from the downloading of, access to or use of the website and/or its content.
Apart from the exception that liability cannot be excluded under applicable law and apart from liability for own grossly negligent conduct or intent,
(i) Deutsche Oppenheim, its respective licensors or other third parties making information or functionalities available on or through the website shall not be liable for any damages whatsoever arising out of (1) the information published on the website or (2) errors in or omissions from the website;
(ii) Deutsche Oppenheim, its respective licensors or other third parties making information or functionalities available on or through the website accept no liability whatsoever for losses arising from orders, investment decisions or the acquisition of goods or services by third parties (including financial instruments and foreign exchange) based on information made available on this website;
(iii) and under no circumstances may Deutsche Oppenheim, its respective licensors or any other third party making information or functionality available on or through this website be held liable for any damages whatsoever, whether direct, indirect, punitive, atypical or consequential, which result from the use of the website or its inability to be used, even if Deutsche Oppenheim, its respective licensors or other third parties making information or functionalities accessible on or through the website have been made aware of the possibility of such damage occurring or if such damage was foreseeable.
Unless otherwise agreed,
(i) the content on this website does not constitute advertising, a contract offer or financial or any other advice. Deutsche Oppenheim does not enter into any contractual relationship with the user by providing content on this website and/or by the user accessing it. This website is not a substitute for advice on financial or other matters. No content on this website is to be understood as a recommendation to enter into or refrain from certain transactions without first obtaining individual advice that takes into account the user’s needs and overall situation.
Accordingly, nothing on this website constitutes an offer that can be accepted by the user in such a way as to create contractual obligations for Deutsche Oppenheim without the need for Deutsche Oppenheim to add any further information (invitatio ad offerendum)
(ii) the provision of information or functionality on this website does not constitute or imply any advice (including, without limitation, any advice regarding the execution of any transaction or any legal, tax or accounting advice or advice regarding the suitability or profitability of any security, investment or transaction);
(iii) on this website Deutsche Oppenheim only makes available information and functionalities of a general nature which are not intended as financial, legal, tax or other advice and do not constitute an offer, a solicitation or recommendation of securities or other financial products or services. The information made available to users on this website may differ from that made available to other users or clients of Deutsche Oppenheim. The user should not solely rely on the information made available on this website and in any case seek additional independent professional advice, in particular as regards his financial, tax and / or legal needs, before making any investment decisions. The website does not necessarily include all criteria which are decisive for the purposes of the user or may not reflect important aspects for the user up to date. In addition to the products and services shown on this website, there are other products and services on the market which may be more suitable for the user's purposes.
5.1 Applicable law and jurisdiction
Unless otherwise stipulated in contractual agreements, these terms of use are governed by German law and shall be construed in accordance with the laws of the Federal Republic of Germany.
5.2 Investment performance, returns
Information on this website regarding investments is based on past experience, from which no information regarding future earnings can be derived. The value of investments may rise or fall and investors must expect not to recover the amount invested. Products presented on this website are neither insured nor guaranteed by government authorities.
5.3 Scope of application
These Terms of Use apply in favour of Deutsche Oppenheim and of the other members of the Deutsche Bank group and also extend to their respective legal successors as well as their respective assignees and agents. If any rights arise from these Terms of Use, Deutsche Oppenheim or any member of the Deutsche Bank group may transfer such rights to any other of the aforementioned or other third parties.
5.4 Transfer of tasks
Deutsche Oppenheim reserves the right to have functions associated with the operation of the website performed by third parties.
5.5 Changes to the Terms of Use
Deutsche Oppenheim reserves the right to change or amend these Terms of Use at their discretion. Users should read these Terms of Use at the beginning of each visit to this website in order to familiarise themselves with possible changes.
5.6 No implied waiver
The non-exercise or delayed exercise of any rights by Deutsche Oppenheim may in no event be construed as a waiver of that right. The partial exercise of any right shall not preclude the further exercise of that right. The waiver of any right does not constitute a waiver or modification of any other right.
5.7 Contractual agreements
If contractual agreements between Deutsche Oppenheim and the user deviate from these Terms of Use, the contractual agreements shall take precedence.
5.8 Severability clause
If any provision or part of any provision of these Terms of Use shall become illegal, invalid or unenforceable under the laws of any jurisdiction at any time, this shall not affect the legality, validity or enforceability of the remaining provisions of these Terms of Use in that jurisdiction or in any other jurisdiction.
This website is copyright-protected.
Deutsche Oppenheim and its respective suppliers, if any, reserve all rights to all data, text, images, software and other elements (including multimedia elements) displayed on, distributed through or made available for downloading from this website or required for the provision of a function on this website (hereinafter referred to as “content”).
Use of and permission to use the site and its content does not grant any rights in the site or to the content the user. The user may copy or print these Terms of Use or other parts of the content solely for private, non-commercial purposes.
All such copies shall be subject to the limitations set forth in these Terms of Use and must include a copy of Deutsche Oppenheim's copyright notice.
Users may not download, display, reproduce, create derivative works from, transfer, sell, distribute, rent, lease, sublicense, loan or transfer the site or its content except as expressly permitted in these Terms of Use.
Users are prohibited from,
(i) using the website (including, without limitation, any third-party software, if any, which is used) to provide services to any third party;
(ii) modifying or removing Deutsche Oppenheim's or any of its suppliers' copyright notices;
(iii) using any trademarks, service or product names, domain names, logos or other identifying marks of Deutsche Oppenheim or any third party without the prior written consent of Deutsche Oppenheim or such third party;
(iv) except for the usual intermediate storage when viewing the relevant page, copy, download or store market information (such as securities prices, company news, stock exchange indices), distribute or permit access to this market information, or use this market data to generate an index, provided that this index can be used as a tradable instrument in the sense of a security.
Published by Deutsche Oppenheim Family Office AG,
Deutsche Oppenheim Family Office AG, Cologne.
All rights reserved.
Deutsche Oppenheim Family Office AG (the “Institute”) participates in the following consumer arbitration schemes:
The consumer arbitration office of Deutsche Bundesbank (P.O. Box 11 12 32, 60047 Frankfurt, www.bundesbank.de/de/service/schlichtungsstelle) shall deal with any disputes between consumers and the Institute concerning the provisions of the Civil Code on financial services distance contracts (asset management, investment advice, acquisition and/or investment brokerage) or concerning Sections 655a to 655d of the Civil Code and Art. 247a Section 1 of the Introductory Act to the Civil Code (brokerage of consumer loan agreements and funding for a fee).
The consumer arbitration board "Ombudsman for Private Banks" (www.bankenombudsmann.de) is responsible for settling a dispute with the bank in an out-of-court dispute settlement procedure. There, the consumer has the opportunity to call the ombudsman for private banks to settle a dispute with the bank. If the subject of the complaint relates to a dispute about a payment service contract (§675f BGB of the German Civil Code), customers who are not consumers can also call the ombudsman for private banks. The "Code of Procedure for the Settlement of Customer Complaints in the German Banking Industry" regulates further details, which are available on request or can be called up on the Internet at www.bankenverband.de.
The complaint must be submitted in text form (e.g. by letter, fax or e-mail) to the customer complaints office, office of the ombudsman for private banks at the Bundesverband deutscher Banken e. V., Postfach 04 03 07, 10062 Berlin, Fax: +49 (030) 1663 3169, Email: schlichtung@bdb.de.
The consumer arbitration office of the Federal Financial Supervisory Authority (Graurheindorfer Straße 108, 53117 Bonn, www.bafin.de) shall deal with any disputes between consumers and the Institute concerning other provisions in connection with financial services agreements (asset management, investment advice, acquisition and/or investment brokerage) or provisions of the German Investment Code.
Otherwise, the Institute is neither willing nor obliged to participate in an arbitration procedure before another consumer arbitration board.
European Online Dispute Resolution Platform:
The Online Dispute Resolution Platform of the European Commission is available at
https://webgate.ec.europa.eu/odr/.
Deutsche Oppenheim Family Office AG participates in the Deposit Protection Fund of the Association of German Banks (Bundesverband Deutscher Banken) Pursuant to its statute, the Deposit Protection Fund protects deposits of bank clients which the bank is required to repay under current law.
The protection does not extend to deposits which form part of a bank’s own capital or to liabilities from bearer or registered bonds.
Deposits held by creditors other than individuals or foundations having legal capacity are protected only if (i) the deposit is not a liability resulting from a registered bond or borrower’s note loan and (ii) the term of the deposit is 18 months at most.
The term limit will not apply to deposits which existed already before 1 January 2020. From 31 December 2019, this grandfathering provision will cease to apply as soon as the relevant deposit matures, can be cancelled or reclaimed in any other way or if the deposit is transferred by individual or universal succession.
Any bank liabilities existing before 1 October 2017 are subject to the provisions of the statute of the Deposit Protection Fund valid up to 1 October 2017. This grandfathering provision will cease to apply as soon as the relevant deposit matures, can be cancelled or reclaimed in any other way or if the deposit is transferred by individual or universal succession.
The protection limit is calculated on the basis of the bank’s capital as determined in the framework of the deposit protection scheme. The protection limit per creditor shall be equivalent to 20% of a bank’s capital (within the meaning of Art. 72 of Regulation (EU) 575/2013) until 31 December 2019, to 15% of a bank’s capital until 31 December 2024 and to 8.75% of a bank’s capital from 1 January 2025. These dates apply to all deposits established or extended after 31 December 2011. For deposits established before 31 December 2011 the former protection limits will apply until the maturity or until the next possible calling date of the deposit.
We will provide information on the current protection limit on request. Alternatively, it is available at www.bankenverband.de.
Please see Section 6 of the statute of the Deposit Protection Fund for more details of the protection scheme; we will provide the document at your request.
Based on lessons learned from the financial crisis of 2008, many countries have adopted rules for how banks at risk of default can be resolved in an orderly manner without involving taxpayers. Under these procedures, shareholders and creditors of a bank in distress may be r equired to bear a portion of the losses. The objective is to ensure that the bank can be resolved without the use
of public funds. You can find more information in the attached document.
Deutsche Oppenheim Family Office AG is an asset manager as defined in Section 134a subs. 1 no. 1 of the German Stock Corporation Act (“Aktiengesetz”, “AktG”), which means that it has to describe the rules for its engagement in portfolio companies (“engagement policy”) pursuant to Section 134b subs. 1 and 2 AktG and disclose and justify any deviations from this engagement policy pursuant to Section 134b subs. 4 AktG.
Deutsche Oppenheim Family Office AG does not exercise any shareholder rights within the meaning of Section 134 b subs. 1 no. 1 AktG based on engagement in the company. In particular, it does not exercise any rights related to general shareholder meetings. Rights to shares in the company profits within the meaning of Section 60 et seq. AktG and to subscription rights are exercised in consultation with the clients.
The monitoring of relevant company matters within the meaning of Section 134b subs. 1 no. 2 AktG is ensured by taking notice of the legally required company reports, i.e. financial reports and ad-hoc notifications.
There will be no exchange of opinions with the company bodies or company stakeholders within the meaning of Section 134b subs. 1 no. 3 AktG.
There will be no cooperation with other shareholders within the meaning of Section 134 b subs. 1 no. 4 AktG.
Any conflicts of interest within the meaning of Section 134 b subs. 1 no. 5 AktG shall be disclosed to the affected parties pursuant to law, and the procedure shall be determined in consultation with the affected parties.
There will be no annual disclosure of the implementation of the engagement policy within the meaning of Section 134 b subs. 2 AktG because the relevant rights will not be exercised.
There will be no disclosure of the voting behaviour within the meaning of Section 134 b subs. 3 AktG because the voting rights will not be exercised.
Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability-related disclosures – also known as the Disclosure Regulation – prescribes new transparency obligations with a view to sustainability criteria and sustainability risks. It requires, among other things, disclosures on participants' websites regarding products that consider e.g. environmental or social characteristics, and also regarding the company. The following publications relate to the disclosures on websites prescribed by law in accordance with the Disclosure Regulation.
Introduction / Summery
On 10 March 2021, Regulation (EU) 2019/2088 of 27 November 2019 on sustainability-related disclosures in the financial services sector (Sustainable Finance Disclosure Regulation, SFDR) entered into force. It aims to promote 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 in investment decision-making procedures and in investment advice. The approach pursued by Deutsche Oppenheim will be explained in more detail below.
Definition of sustainability risks
Sustainability risks (“ESG risks”) are designated as incidents or conditions in the areas of the Environment, Social or Corporate Governance, whose occurrence could have actual or potential significantly negative effects on the value of the investment. These risks can occur both separately and cumulatively; they can affect individual companies or also entire sectors/branches or regions and can have very different characteristics.
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
In order to evaluate sustainability risks, Deutsche Oppenheim uses information such as that from external service providers that have specialised in the qualitative evaluation of ESG factors.
Because sustainability risks can have different effects on individual companies, sectors, investment regions, currencies and investment classes (for example, equities or bonds), when recommending financial instruments in the Deutsche Oppenheim follows the approach of diversifying investments as broadly as possible in order to reduce the effects of the occurrence of sustainability risks on the client´s portfolio. The Deutsche Oppenheim generally recommends distribution across a variety of investment classes in order to establish an individual client opportunity/risk profile. In addition, investment advice pursues a policy of a broad spread of investment classes in a variety of branches/sectors, investment regions and currencies.
In addition to diversification, sustainability risks are taken into account at various points in the investment process when making investment decisions within the framework of financial portfolio management. Sustainability risks are taken into account during the macro-economic consideration and development of market opinion, when allocating assets to individual investment strategies and when selecting individual financial instruments.
On March 10, 2021 the Regulation (EU) 2019/2088 of November 27, 2019 on sustainability-related disclosures in the financial sector (Disclosure Regulation) has entered into force. This regulation aims to support sustainable investments by requiring Financial Market Participants (FMPs) and Financial Advisers (FAs) to disclose information regarding sustainability risks and adverse sustainability impacts to investors and clients.
This is the adverse sustainability impact statement for Deutsche Oppenheim in our capacity as Financial Market Participant, to disclose the Deutsche Oppenheim approach on the consideration of principal adverse impacts of investment decisions on sustainability factors. Principal adverse impacts on sustainability factors are referred to in Article 4 of the Disclosure Regulation. They are further defined in implementing legislation, which at the time of publication of this statement has not entered into force, but are meant to cover negative effects of investments regarded as material from a sustainability perspective. This statement is made for all financial products as defined by the Disclosure Regulation (portfolio management, alternative investment fund (AIF), insurance-based investment products (IBIP), a pension product, a pension scheme, an undertaking for collective investments in transferable securities (UCITS), pan-european personal pension product (PEPP)*).
Since March 10, 2021, Deutsche Oppenheim considers principal adverse impacts (PAIs) of its investment decisions on sustainability factors, as described in more detail in the full statement, and will disclose the extent of these impacts in future statements.
As described in the full statement below, although there currently is no formal policy to this effect, Deutsche Oppenheim will take four specific impacts into account in relevant investment decisions. For this purpose, factors relating to the aforementioned principal adverse impacts will be made transparent against the investment universe. The consideration of these adverse impacts will be an additional factor for review in making investment decisions, but will not automatically outweigh other relevant factors. Deutsche Oppenheim does not engage directly with investee companies and so do not influence business activity or risks, and follows certain internationally recognized principles for sustainable business and banking conduct, as specified in the full statement.
*Not all of these products are currently in scope of Deutsche Oppenheim Family Office AG as Financial Market Participant
Description of principal adverse sustainability impacts
The principal adverse impacts, including the identification, prioritisation and any designated action to be taken to manage exposure to these, will be reviewed by Deutsche Oppenheim on an annual basis.
The Principal Adverse Impacts that Deutsche Oppenheim will take into account this reference period are:
⦁ Exposure to Fossil Fuels
Industries that derive revenues from the exploration, mining, extraction, distribution or refining of hard, liquid or gaseous fuels (i.e. coal, oil, natural gas)
⦁ Carbon emissions
The level of carbon dioxide equivalent that is released by a company, measured in volume and intensity
⦁ Compliance with United Nations Global Compact principles
Observing that companies at a minimum, meet fundamental responsibilities in the areas of human rights, labour, environment and anti-corruption.
⦁ Exposure to controversial weapons
Industries that derive revenues from the manufacture or selling of controversial weapons (i.e. anti-personnel landmines, cluster munitions, chemical, biological, radiological and nuclear weapons).
Description of actions to address principal adverse sustainability impacts
Since March 10, 2021, Deutsche Oppenheim will make factors relating to the aforementioned principal adverse impacts transparent against the investment universe, enabling informed decisions in the selection process for construction of relevant financial products.
The focus will be on making the data available within the processes for selection of underlying products for our managed funds and portfolios. As a fiduciary, it is of the utmost importance that we make all investment decisions in the best interest of the clients, considering all financial and risk factors. Therefore, the consideration of these adverse impacts will be an additional factor for review by our portfolio managers in making investment decisions, but will not automatically outweigh other relevant factors.
To support with obtaining required details, and monitoring our investable product universe, Deutsche Oppenheim partners with third party data providers to include information on the business involvements and controversies across the universe on a monthly basis.
Engagement policies
Where Deutsche Oppenheim acts as Financial Market Participant for financial products in scope of the Disclosure Regulation, we do not engage directly with investee companies and so do not influence business activity or risks.
References to international standards
The Deutsche Oppenheim follows internationally recognized principles for sustainable business and banking conduct, such as the 10 principles of the UN Global Compact, the UN Principles for Responsible Investments, the UN Principles for Responsible Banking and the UN Guiding Principles on Business and Human Rights.
Financial market participants adverse sustainability impacts statement for Deutsche Oppenheim
When providing paticipation in the financial market, Deutsche Oppenheim takes principal adverse impacts on sustainability factors into account, as described in more detail in the following. Principal adverse impacts on sustainability factors are referred to in Article 4 of Regulation (EU) 2019/2088 of November 27, 2019 on sustainability‐related disclosures in the financial services sector (the “Disclosure Regulation”). They are further defined in implementing legislation, which at the time of publication of this statement has not entered into force, but are meant to cover negative effects of investments regarded as material from a sustainability perspective.
At this point in time, Deutsche Oppenheim in the capacity as financial market participants will take the following principal adverse impacts, as defined by draft implementing legislation, into account, for all financial products as defined by the Disclosure Regulation (portfolio management, alternative investment fund (AIF), insurance-based investment products (IBIP), a pension product, a pension scheme, an undertaking for collective investments in transferable securities (UCITS), pan-European personal pension product (PEPP)*) managed by EU entities:
⦁ Exposure to Fossil Fuels
Industries that derive revenues from the exploration, mining, extraction, distribution or refining of hard, liquid or gaseous fuels (i.e. coal, oil, natural gas)
⦁ Carbon emissions
The level of carbon dioxide equivalent that is released by a company, measured in volume and intensity
⦁ Compliance with United Nations Global Compact principles
Observing that companies at a minimum, meet fundamental responsibilities in the areas of human rights, labour, environment and anti-corruption.
⦁ Exposure to controversial weapons
Industries that derive revenues from the manufacture or selling of controversial weapons (i.e. Anti-Personnel Landmines, Cluster Munitions, Chemical, Biological, Radiological and Nuclear weapons)
*Not all of these products are currently in scope of the advisory business.
Overall the positive and negative impact of investments have become increasingly available to measure. The majority of the harmful impacts companies or real assets can have on the environment, their employees or communities they operate in, may result in direct or indirect financial risks, the risk of losing the license to operate, competitive disadvantages or the loss of customer or community support. In other words, they constitute an “ESG” – Environmental, Social or Governance- or “sustainability risk”.
Since March 10, but by June 30, 2021 latest, EU managers or manufacturers of managed financial products (under the Disclosure Regulation, “Financial Market Participants”) exceeding on their balance sheet the criterion of the average number of 500 employees during the financial year, will be required to publish a statement on how they address and consider principal adverse impacts. We expect the first statement of Financial Market Participants to be a qualitative statement on how they consider principle adverse impacts in their investment decision making processes. The first quantitative assessment on the indicators are expected to be disclosed by June 30, 2022. After that date we expect that more and more data will become available to investors and financial market participants.
As part of our advisory due diligence process we will review the relevant principal adverse impact statements published by the Financial Market Participants, and also note where they consider principal adverse impacts that align with our own. The enhanced due diligence process will ensure that we have clarity and transparency on the relevant adverse impacts taken into account by the Financial Market Participants, and enables us to identify products that do not fulfil our qualitative requirements and therefore may result in us not recommending the respective financial products.
The consideration of Sustainability and Sustainability Risks is an integral part of the performance-based determination of variable compensation at DB group, both for employees and the Management Board.
Where appropriate, we have set sustainability related targets which include financial and non-financial targets such as sustainable financing and investment volumes as well as culture and conduct.
Furthermore, we expect all employees of DB 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.
Deutsche Oppenheim discretionary portfolio management with sustainable investments
Description of environmental or social characteristics
Deutsche Oppenheim Family Office AG (hereinafter the “Deutsche Oppenheim”) considers environmental and social characteristics in selecting bonds and shares as part of Deutsche Oppenheim discretionary portfolio management. However, discretionary portfolio management does not aim for sustainable investment or contribute to achieving an environmental or social objective.
The minimum requirement for an investment in bonds and shares as part of discretionaryl portfolio management with sustainable investments is that, according to information from Institutional Shareholder Services Germany AG (“ISS”) (formerly: oekom research AG), issuers do not meet any exclusion criterion in relation to selected sustainability criteria as regards Deutsche Oppenheim discretionary portfolio management with sustainable investments. Private companies and groups of companies should be excluded if their revenue in controversial business areas is higher than the defined tolerance threshold (target) set for each business area, or if they engage in controversial business practices. Governments that engage in controversial social and environmental practices should also be ruled out.
Methods used to measure and monitor environmental or social characteristics
In order to assess whether bonds or shares meet the sustainability criteria, the Deutsche Oppenheim relies exclusively on the positive lists that are prepared and regularly updated by ISS. These are prepared in accordance with the Deutsche Oppenheim’s instructions regarding sustainability criteria for the exclusion of issuers.
The Deutsche Oppenheim does not monitor ISS's compliance with the sustainability criteria for the exclusion of issuers. The Deutsche Oppenheim cannot guarantee the accuracy of ISS's assessment or the accuracy and completeness of the positive list generated by ISS, but will use information from ISS as a basis. Nor does the Deutsche Oppenheim have any influence on any disruptions to ISS's analysis and preparation for research.
ISS makes regularly updated positive lists available to the Deutsche Oppenheim. The Deutsche Oppenheim's selection of bonds and shares is based on the latest updated positive lists. As soon as an investment instrument ceases to meet the sustainability criteria, the Deutsche Oppenheim will aim to sell such investment instrument, while protecting the interests of the client.
Data sources and criteria for assessment of the underlying assets in terms of environmental or social characteristics
In the context of discretionary portfolio management, the Deutsche Oppenheim will preferentially invest in bonds and shares that meet certain sustainability criteria. In order to assess whether a bond or share meets the sustainability criteria, the Deutsche Oppenheim uses the assessments of ISS.
The minimum requirement for an investment in bonds and shares as part of discretionary portfolio management with sustainable investments is that, according to information from ISS, issuers do not meet any exclusion criterion in relation to selected sustainability criteria as regards Deutsche Oppenheim discretionary portfolio management with sustainable investments. Private companies and groups of companies should be excluded if their revenue in controversial business areas is higher than the defined tolerance threshold (target) set for each business area, or if they engage in controversial business practices. Governments that engage in controversial social and environmental practices should also be ruled out.
Disclosure on the inclusion of environmental or social characteristics in pre-contractual information
Published by Deutsche Oppenheim Family Office AG,
© Deutsche Oppenheim Family Office AG, Köln.
