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Strategies for dealing with sustainability risks
Due to legal requirements (Art. 3 to 5 Disclosure Regulation) we are obliged to provide the following information. This is not intended to be an advertisement of environmental or social features in our investment strategies or for specific financial instruments. Within the company, we want to contribute to a more sustainable, resource-efficient economy with the aim of reducing the risks and impacts of climate change in particular. In addition to observing sustainability goals in our corporate organization itself, we also see it as our task to sensitize our customers to aspects of sustainability when structuring the business relationship they have with us. Environmental conditions, social dislocation and/or poor corporate governance can have a negative impact on the value of our customers’ investments and assets in several ways. These so-called sustainability risks can have a direct impact on the net assets, financial position and results of operations and also on the public valuation of investments. Although such risks can never be completely ruled out, we have developed strategies for the financial services we offer to enable us to identify sustainability risks in advance. In order to limit sustainability risks, we try to identify investments in those companies and markets that show an increased risk potential for sustainability. Identifying suitable investments may involve, among other things, investing in or recommending investment funds whose investment policy already features a suitable and recognized strategy for reducing sustainability risks. Identifying suitable investments to limit sustainability risks can also involve using recognized rating agencies for product selection in asset management or for recommendations in investment advice. Further details result from individual agreements. In doing so, we ensure that our compensation policy does not conflict with the inclusion of sustainability risks, in particular through fixed compensation.

Statement on the non-consideration of adverse effects on
Sustainability factors
Investment decisions can have adverse impacts on the environment (e.g., climate, water, biodiversity) and on social issues. They can also hinder the fight against corruption. As a matter of principle, we are interested in helping to avoid such effects in the context of our investment decisions or investment recommendations, in line with our responsibility as a financial market participant. However, according to the current state of affairs, the requirements for a corresponding public declaration have not yet been met in a legally reasonable manner. Significant legal issues are still unresolved. Furthermore, a direct (evaluative) consideration of sustainability criteria in the investment decision would not be easily compatible with a purely algorithm-based trading. We are therefore unable to make a public statement at this time as to whether and how we consider adverse impacts on sustainability factors in the context of our investment decisions or recommendations. Therefore, we declare that we will not consider them until further notice.