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 10 06 02, 60006 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 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.
The Deutsche Oppenheim Family Office AG is a member of the Compensation Sheme for Securities Trading Companies (Entschädigungseinrichtung für Wertpapierhandelsunternehmen - EdW) in 10865 Berlin: Office: Charlottenstraße 33/33a, 10117 Berlin-Mitte.
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 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
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.
Date: 2023-05-16
Deutsche Oppenheim Family Office AG 5299003G9CMV5CY1FU81
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 2023.
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”. The principal adverse impacts, including their identification, prioritisation, and any action to be taken to manage exposure to them, will be reviewed by Deutsche Oppenheim Family Office AG annually in accordance with the Group Sustainability Council (GSC) of Deutsche Bank AG. Currently, Deutsche Bank AG follows a principle-based approach. As the regulatory requirements and associated data change on an ongoing basis, Deutsche Bank AG is fully committed to integrating a more thorough and exhaustive principal adverse impact framework into its discretionary portfolio management services in alignment with such developments.
Since 10 March 2021, Deutsche Oppenheim makes factors relating to select principal adverse impacts transparent against the investment universe, enabling informed decisions in the selection process for the construction of relevant financial products. The focus will be on making the data available within the processes for selection of underlying products for Deutsche Oppenheim managed portfolios. It is of the utmost importance that Deutsche Oppenheim, given its fiduciary capacity, makes all investment decisions in the best interests of its clients and, in doing so, takes all financial and risk factors into account. Considering these principal adverse impacts is therefore an additional aspect to be reviewed by Deutsche Oppenheim portfolio managers when making investment decisions but will not automatically outweigh other relevant factors. Deutsche Oppenheim works with third-party data providers to help it to obtain the required data and monitor its investable product universe. This enables it to include information on the principal adverse impacts across the applicable universe on a monthly basis.
While Deutsche Oppenheim carries out quantitative reporting in respect of all mandatory principal adverse impacts set out in the SFDR, it considers – in its role as a financial market participant – selected principal adverse impact indicators within its investment process. Indicators are selected on the basis of data availability, alignment with adverse activities on which the Deutsche Bank Group is particularly focused and the ESG Investment Classification Criteria, which set out the standards to be met in the manufacturing of ESG investment products. The investment process must allow for robust asset allocation across different regions, asset classes and sectors, which means that principal adverse impacts are not always applicable, or data is not readily available for all of the securities invested in.
The prioritised principal adverse impacts are as follows:
Industries that derive revenues from the exploration, mining, extraction, distribution or refinement of solid, liquid or gaseous fuels (i.e., coal, oil, natural gas)
The carbon dioxide equivalents released by a company, measured by volume and intensity
At a minimum, companies need to fulfil fundamental responsibilities in the areas of human rights, labour, the environment and anti-corruption
Countries that have an industry tie to anti-personnel mines, cluster munitions, chemical weapons and biological weapons. An industriy tie includes ownership, manufacture or distribution.
Deutsche Oppenheim will continue to monitor its exposure to adverse sustainability indicators and where applicable may adapt its strategy in accordance with publication of each annual quantitative statement.
As standards regarding the consideration of sustainability criteria are still emerging and reporting frameworks have partly not yet come into force, data is currently not always available from the investee companies, the bank’s issuers or third-party data providers, especially with regard to the adverse impacts on sustainability factors.
Deutsche Oppenheim discloses data related to principal adverse impact (PAI) on sustainability factors for products where it acts as a Financial Market Participant and in scope of the SFDR. The following disclosure is an aggregation of all in scope assets of Deutsche Oppenheim. The data is relevant for the reference period 1 January to 31 December 2023.
At this point of time data availability and data quality for principle adverse impact on sustainability factors of the financial investment universe is still evolving. This is due to various factors including but not limited to, alignment and applicability of reporting standards for investee companies and sovereign issuers, evolving methodologies for calculation of sustainability indicators and ongoing efforts in the market and data providers to make data accessible and standardized. Deutsche Oppenheim considers the data is not yet sufficient to derive well-founded decisions regarding actions to be taken. It is possible that as data availability and quality improve the impact on principal adverse impacts could increase organically and beyond the control of Deutsche Oppenheim.
Additionally, following the targeted consultation of the SFDR regulation in September 2023 there is potential for further changes to the regulation that may invalidate any actions set. Therefore, for its current quantitative reporting Deutsche Oppenheim will continue to disclose and monitor its principal adverse impacts of its investment decisions on sustainability factors but without deriving any planned actions or applying thresholds for the following reference period to avoid or reduce the main negative impacts on sustainability factors.
Deutsche Oppenheim will review its current approach on an annual basis.
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. In accordance with the evolving guidelines, 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.
For the current reference period, Deutsche Opppenheim includes information on the coverage, which is represented as a percentage share of total investments for which adverse impact data to individual PAIs were available. The coverage values also reflect the methodology change, with coverage for the year 2022 shown as a percentage of investments applicable to each PAI. However, for 2023, the percentage for coverage is represented as a proportion of all investments. This circumstance results in a generally lower coverage rate for the values of 2023.
The calculation is based on principal adverse impact data for direct investments into investee companies and sovereigns and indirect investment products (Funds) sourced from a third-party data provider assessed against four snapshots of the assets managed during the reference period (31 March / 30 June / 30 September / 31 December).
1) Coverage is included as voluntary additional information. It is based on the percentage of the applicable investment universe for which data was available for the adverse impact indicator. The investment universe includes all assets including investee companies, sovereign issuers, indirect investments (Funds), derivatives, commodities, and cash.
2) 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
3) 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.
4) Due to significant methodological changes in calculating adverse impacts, additional so-called "Memo" values for the year 2022 have been included to facilitate comparison of previous year's values to the new ones. These Memo values were calculated based on the 2022 holdings but taking into account the calculation method and data foundation used for 2023, and therefore should not be considered an exact representation of the year 2022 but rather as a reference point.
Deutsche Bank Group has established a robust governance, helping to manage, measure, and monitor sustainability activities across the bank. This governance structure includes a number of forums devoted entirely to sustainability. The most senior is the Group Sustainability Committee, which was created in 2020. Chaired by the Chief Executive Officer and the Chief Sustainability Office (Vice-Chair), it consists of Management Board members, the heads of Deutsche Bank AG’s business divisions and certain infrastructure functions.
Deutsche Bank Group applies an overarching approach to the management of sustainability, which is set out in various group level policies and procedures.
As the regulatory requirements and data change on an ongoing basis, Deutsche Oppenheim as a subsidiary of Deutsche Bank AG - where it acts as a Financial Market Participant - does not have a single defined policy relating to principal adverse impacts. Where relevant, however, they are covered by existing procedure documents. Deutsche Oppenheim is fully committed to integrating a more thorough and exhaustive principal adverse impact framework into its discretionary portfolio management services in alignment with such developments.
Frameworks for Deutsche Oppenheim where it acts as a Financial Market Participant describe the core processes, responsibilities, governance structures and monitoring environment. These stipulate that portfolio managers are provided with selected principal adverse impact information alongside the investment universe, enabling them to make informed decisions in the selection process for the construction of relevant managed portfolios. The focus is on making the data available within the processes for the selection of underlying products for Deutsche Oppenheim managed portfolios. It is of the utmost importance that Deutsche Oppenheim, given its fiduciary capacity, makes all investment decisions in the best interests of its clients and, in doing so, takes all financial and risk factors into account. Considering these principal adverse impacts is therefore an additional aspect to be reviewed by Deutsche Oppenheim portfolio managers when making investment decisions but will not automatically outweigh other relevant factors.
For financial products that follow an ESG investing approach, Deutsche Bank AG has additionally specified a ESG Classification Criteria Procedure (published 2021) that has to be adhered to Deutsche Oppenheim too. Deutsche Oppenheim in its role as a Financial Market Participant uses third-party data providers to exclude or set threshold limits on exposure to industries or practices that are aligned to select adverse sustainability indicators.
Deutsche Oppenheim in its role as a Financial Market Participant identifies and prioritizes selected principal adverse impact indicators within its investment process. The selection of indicators is determined via data availability, alignment to adverse activities in focus by Deutsche Bank Group, and the ESG Investment Classification Criteria which sets out standards to be met for portfolio management that considers ESG criteria. The investment process must allow for a robust allocation across different regions, asset classes and sectors, and as such principal adverse impacts are not always applicable or data is not readily available for all securities invested in. Deutsche Oppenheim will continue to monitor its exposure to adverse sustainability indicators and where applicable may adapt its strategy in accordance with the publication of each annual quantitative statement.
Deutsche Oppenheim also regularly performs an assessment to determine the materiality of non-financial topics for the bank and its stakeholders. As part of this assessment, Deutsche Oppenheim assesses actual and potential positive and negative impacts as well as actual and potential risks and opportunities for environmental, social and governance topics in terms of Deutsche Oppenheim business activities, business relations, and products and services.
For the assessment of principal adverse impacts on sustainability factors, Deutsche Oppenheim relies on data provided by by third-party data providers. These previously mentioned providers expose data as reported by investee companies, or investment fund managers. If no data from the investee company or investment fund company is available, the third-party data provider may provide estimated data which can be used.
Deutsche Oppenheim does not guarantee that this information is correct or complete. Furthermore, Deutsche Oppenheim cannot guarantee the correctness of the third-party data provider’s assessment. Deutsche Oppenheim also has no influence on any disruptions to the third-party data provider’s analysis and research preparation.
As the standards and the regulatory framework regarding the consideration of sustainability criteria are still evolving, data on the consideration of principal adverse impacts is not always available and there may still be restrictions on the consideration of the principal adverse impacts.
To minimise these restrictions, Deutsche Bank AG has carefully selected its third-party data provider and maintains close contact with regard to changes in the quality of the data.
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.
Deutsche Oppenheim is embedding sustainability into its policies, processes, and products, focusing on four dimensions: Sustainable Finance, Policies and Commitments, People and Operations as well as Thought Leadership and Stakeholder Engagement. Making progress in these dimensions will enable Deutsche Oppenheim to maximize its contribution to the achievement of the Paris Climate Agreement’s targets and the United Nations (UN) Sustainable Development Goals.
To underpin its long-standing commitment to sustainability, Deutsche Oppenheim follows internationally recognized principles for sustainable business and banking conduct and formally endorses universal sustainability frameworks and initiatives such as:
By adhering to certain internationally recognized standards, such as the conventions 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 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 services, Deutsche Oppenheim is invested in developing net-zero aligned forward-looking climate scenarios, which are aligned to the Paris Climate Agreement. However, currently Deutsche Bank AG does not consider climate-scenarios in the investment making decision process.
Stand: 2024-06-30
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):
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.
Date: 2023-05-16
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.
Date: 2023-05-16
Published by Deutsche Oppenheim Family Office AG,
© Deutsche Oppenheim Family Office AG, Köln.
