Disclosure according to Art. 3 REGULATION (EU) 2019/2088
In accordance with the European Union's understanding of sustainability, sustainability is not to be limited to environmental aspects alone, but should rather take into account the entire ESG spectrum (Environment, Social and Governance). Sustainability risks are ESG influencing factors, the occurrence of which can actually or potentially have a negative impact on the value of an investment. Basically, sustainability risks are divided into physical risks, transition risks and other sustainability risks (e.g. social and corporate governance).
We are aware of short-, medium- and long-term changes in our business environment due to sustainability risks. Therefore, relevant trends are recorded and observed, and conclusions are drawn from the analysis to better understand the impact of relevant sustainability factors. It should be noted that sustainability risks do not represent an independent risk category, but must be subsumed under the already existing, classic types of risk.
We limit all risks through a long-term strategy and subject the business and risk strategy to a comprehensive review and make adjustments where necessary.
According to our assessment, sustainability risks currently have no impact on the return of the financial products provided within the scope of asset management and on the return of the financial products that are the subject of investment advice. In addition, due to the current data situation and legal developments, there are uncertainties in the calculation and handling of sustainability risks.
For these reasons, sustainability risks are not included in investment decisions made for clients within the scope of asset management solutions. Likewise, sustainability risks are not taken into account in investment advice.
Statement on principal adverse impacts of investment decisions on sustainability factors
The consideration of adverse effects (so-called "Principal Adverse Impacts" =PAI's) is significantly dependent on the availability of relevant information on the market. There is a possibility that the required data is not available for all assets to a sufficient extent and/or in the required quality.
In addition, following the publication of the final technical regulatory standards of the European Commission (C(2022) 1931 final), there are still unresolved questions of detail with regard to the concrete requirements for the measurement and disclosure of PAIs. For these reasons, we have decided not to take into account the negative effects of investment decisions on sustainability factors in our investment advice and asset management for the time being.
Sustainability risks in the remuneration policy (Art. 5)
The company's remuneration system is aimed at risk-conscious behaviour, whereby the sustainability issue and the risks associated with it are also taken into account. This results for a market- and function-oriented fixed remuneration as well as a result-oriented variable remuneration
With this combination, the interests of the owners, the company and employees are equally taken into account and a sustainable and positive development of the bank is ensured. Due to the clear overweighting of the fixed remuneration compared to any variable remuneration, the responsible, sustainable and risk-conscious behaviour of the employees, which thus takes into account sustainability risks in addition to other risks, is promoted and disincentives are avoided.
The remuneration policy therefore does not incentivise the assumption of excessive risks (including sustainability risks) that would be inconsistent with the company's risk policy.