Information on sustainability

INTEGRATION OF SUSTAINABILITY RISKS IN INVESTMENT DECISION-MAKING PROCESSES

“Sustainability risks are events or conditions related to environmental, social or corporate governance issues that may have actually or potentially material negative consequences for our company and/or the value or return on the investments we manage. Sustainability risks can also influence other risk type and are a factor in the materiality of these risk types. In our risk management system, we consider sustainability risks a partial factor in other risk types, primarily market, counterparty and reputational risks.”

HANSAINVEST has outsourced portfolio and asset management for its funds to various external portfolio and asset managers as permitted by law. The portfolio managers exercise discretion when making investment decisions in line with the fund’s investment terms and conditions. This also applies to investment decisions made by the asset manager. Whether and to what extent sustainability risks are taken into account here essentially depends on the investment strategy for the individual fund. HANSAINVEST has no influence over this. However, prior to outsourcing or commissioning (and then on an ongoing basis) it will assess whether a business partner faces sustainability risks in the form of governance or compliance shortcomings. In particular, this allows it to prevent reputational risks that could arise if HANSAINVEST and/or one of its funds was linked to questionable or even criminal practices at one of its partners. It asks its (future) portfolio and asset managers what procedures they have in place to account for sustainability aspects. In addition, HANSAINVEST is responsible for ensuring that its funds, including the investment decisions, are managed in line with applicable legal and contractual frameworks, in particular in terms of considering and disclosing sustainability risks.

INTEGRATION OF SUSTAINABILITY RISKS IN THE REMUNERATION POLICY

In accordance with Article 5 of Regulation (EU) 2019/2088, HANSAINVEST must explain how its remuneration policy is consistent with the integration of sustainability risks. Issues related, for example, to reducing sustainability risks at company level or for individual funds and mandates are not taken into account separately in the remuneration system. These aspects can only indirectly influence remuneration policy and practice as part of the general risk strategy or as part of individual target agreements.

NO CONSIDERATION OF ADVERSE SUSTAINIBILITY IMPACTS

Our company does not currently comprehensively and systematically consider any adverse effects of investment decisions on sustainability factors when managing investments. By sustainability factors, we mean in this context environmental, social and employee concerns, respect for human rights, and the fight against corruption and bribery. The legal requirements for this are new and very detailed. Their careful implementation requires considerable effort on our part. In addition, the relevant data currently available on the market for determining and weighting these issues is not sufficient.