ESG Declaration
Dear customers,
"Sustainability concerns us all. It is the awareness of preserving the natural foundations of life, such as clean water and healthy air, and limiting climate change as quickly and as far as possible. All actions must be holistically aligned with these goals in order to protect current and future generations from harm and to offer them or leave them a world worth living in.
Not only communities of states and individual states as well as their governments, institutions and citizens must contribute to achieving the goals, but also companies from all economic and service sectors.
The European Union has issued the so-called Disclosure Regulation and the Taxonomy Regulation for its member states on the subject of sustainability, among other things, which also affect us as investment advisors. These specify three central areas of responsibility under the abbreviation "ESG": Environmental protection, social sustainability and sustainable corporate governance.
I take the issue of sustainability very seriously and will fulfill these legal obligations in close cooperation with my liability umbrella FinanzAdmin Wertpapierdienstleistungen GmbH as of 02.08.2022.
In the course of each advisory and/or brokerage process, I will ascertain whether or not sustainability criteria should be taken into account in the financial instruments. If the consideration of sustainable financial instruments is desired, a variety of financial instruments with different orientations are available:
These financial instruments, which take sustainability aspects into account, are divided into 3 categories:
Category A: investing in environmentally sustainable financial instruments (according to the Taxonomy Regulation).
This means that the economic activity of such a financial instrument serves at least one environmental objective and makes a significant contribution to achieving this objective, the economic activity does not at the same time lead to a significant impairment of one or more environmental objectives, the economic activity is carried out in compliance with the defined minimum level of protection (concerns human and employee rights, guiding principles in corporate governance, etc.), and the relevant technical requirements measured by key figures are met in the process (e.g. threshold values for emissions or CO2 footprint).
In addition, the Taxonomy Regulation identifies 6 environmental objectives, namely.
- the climate protection
- adaptation to climate change
- the sustainable use and protection of water and marine resources
- the transition to a circular economy
- the prevention and reduction of environmental pollution
- the protection and restoration of species diversity (biodiversity) and ecosystems
Category B: investing in environmentally sustainable financial instruments (according to the Disclosure Regulation).
Within category B, i.e. for financial instruments according to the Disclosure Regulation, a distinction must be made between products according to
- Art 8 (also called "light green") and
- Art 9 (also called "dark green").
For Art 8 products, these environmental and social criteria are taken into account, and for Art 9, investments are made in companies that explicitly pursue these sustainability goals.
These sustainability aspects can be considered for an individual financial instrument, but also in relation to the entire portfolio.
However, it should be borne in mind that no financial instrument complies 100% with the requirements of Art 8 or Art 9, but only to a certain minimum percentage.
Category C: investing in environmentally sustainable financial instruments that do not correspond to categories A and B, but which take into account various adverse effects on sustainability factors.
Since we rely exclusively on the information provided by the product manufacturers and external software suppliers for the labels, it is not possible for us to verify this information ourselves on the basis of our own research.
These sustainability aspects can be taken into account for an individual financial instrument, but also in relation to the entire portfolio. In the course of consulting, I always take these preferences into account in relation to the entire portfolio.
It is therefore possible for an individual financial instrument in Cat. A and B, for example, to request a minimum percentage share in each case, but when taking the overall portfolio into account, only a lower percentage weighting will be possible.
In the case of financial instruments classified as Cat. C are not considered in percentage minimum values, but only whether a financial instrument takes these targets into account or not.
If you do not state any sustainability preferences, we will classify you as "sustainability neutral". This means that we include your other investment preferences (e.g. risk tolerance, experience and knowledge, financial circumstances) in the suitability assessment or in the selection of those financial instruments that we may recommend to you. However, sustainability is then not a selection or exclusion criterion.
Remuneration for brokering financial products is generally not influenced by potential sustainability risks
