Sustainability Disclosure

With REGULATION 2019/2088 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of November 27, 2019, on sustainability-related disclosure requirements in the financial services sector, the EU has required financial market participants and financial advisors, with effect from March 10, 2021, to provide information in accordance with Articles 3, 4 and 5 on the integration of sustainability risks, the consideration of adverse impacts on sustainability factors in the investment decision-making process and investment advice, and on the alignment of remuneration policies and sustainability risks.

Please find below the statements of Wydler Asset Management (Deutschland) GmbH in this regard.

Transparency in the strategies for dealing with sustainability risks (Article 3)

Sustainability is a fundamental attitude at Wydler Asset Management and a long-standing component of our investment culture. Our investment decisions are made within the framework of an ESG analysis (with regard to environmental, social and responsible corporate governance) integrated into the investment process*. Our in-house analysis is supported by data and ESG ratings from external research and rating agencies. Regular contact with companies and their governing bodies such as management boards and IR officers is an important part of our internal analysis. Discussions on social and environmental aspects as well as on general governance topics are part of the standard of our investor meetings.

The investment process we have implemented consists of observing exclusion criteria (so-called negative selection) in combination with the integrated ESG approach. We exclude direct investments in securities of companies that violate key standards. In the ESG approach, we consider ESG risks and opportunities based on systematic processes.

Transparency of adverse sustainability impacts at the corporate level (Article 4)

Systematic and comprehensive consideration of sustainability issues is provided by integrating an ESG approach into our investment decisions. If, in the course of monitoring investment decisions or existing positions, we determine that certain thresholds are exceeded, this may lead to a negative decision (i.e. non-investment) or even an exclusion (sale) of the investment object in question. Irrespective of this, direct investments in securities of companies that violate important standards are excluded from the outset.

We thus ensure that investments are not made in forms of investment that would have particularly high negative sustainability effects. In addition to our own analyses, we also determine these adverse sustainability effects by consulting data and ESG ratings from external research and rating agencies.

Transparency of the remuneration policy in connection with the consideration of sustainability risks (Article 5)

Not only is compliance with sustainability criteria important to us when making investment decisions, we also pay attention to sustainable corporate governance within Wydler Asset Management. Even though we do not carry out any significant business activities that are harmful to the environment, we attach great importance to the sensitive handling of working materials, consumables and energy in our offices. Responsible conduct, compliance with the legal framework but also with internal guidelines, respectful treatment of colleagues and customers alike, and clear and honest communication are our hallmarks.

Our remuneration policy ensures that the trust our customers place in us is absolutely justified. Our actions are determined by the highest degree of integrity, always with the interests of our customers in mind. It goes without saying that our remuneration policy complies with regulatory requirements and we will continue to develop it in this spirit.

*The Wydler Global Bond Fund primarily takes into account traditional financial criteria due to the investment policy used or the investment objective in the fund management. However, the impact of sustainability risks on the fund’s return is considered in the investment process as part of the overall risk/return considerations. At present, ecological/social criteria are not explicitly taken into account or sustainable investments are not explicitly targeted.