Gerd Kommer Invest GmbH
No consideration of adverse effects of investment decisions on sustainability factors
Declaration on the non-consideration of adverse effects on sustainability factors (Art. 4 Disclosure Regulation)
Due to legal regulations (Art. 4 Para. 1 a Para. 2 Disclosure Regulation or Art. 4 Para. 5a Disclosure Regulation) we are obliged to provide the following information:
- Investment decisions can have adverse effects on the environment (e.g. climate, water, biodiversity), on social and employee issues and can also be detrimental to the fight against corruption and bribery.
- In principle, we have a significant interest in fulfilling our responsibility as a financial service provider and helping to avoid such effects as part of our investment decisions (or investment recommendations). However, as things currently stand, the implementation of the legal requirements for this is unreasonable due to the existing and impending bureaucratic framework. Furthermore, essential legal questions are still unresolved.
- In order to avoid legal disadvantages, we are therefore currently prevented from making a public statement to the effect that and in what manner we take into account the adverse effects on sustainability factors (environmental concerns, etc.) as part of our investment decisions (or investment recommendations). We are therefore obliged to declare on our website that we are not taking these into account for the time being and until further clarification is made (Art. 4 Para. 1b) Disclosure Regulation or Art. 4 Para. 5 b) Disclosure Regulation).
- However, we expressly declare that this handling does not change our willingness to contribute to a more sustainable, resource-efficient economy with the aim, in particular, of reducing the risks and effects of climate change and other ecological or social grievances.
Our strategies for incorporating sustainability risks (Art. 3 Disclosure Regulation)
Due to legal regulations (Art. 3 Disclosure Regulation) we are obliged to provide the following information. It is not intended to promote ecological or social characteristics in our investment strategies or for other specific financial instruments:
- As a company, we would like to contribute to a more sustainable, resource-efficient economy with the aim, in particular, of reducing the risks and impacts of climate change. In addition to observing sustainability goals in our corporate organization itself, we see it as our task to also sensitize our customers to aspects of sustainability in the design of their existing business relationship with us.
- Environmental conditions, social disruption and/or poor corporate governance can have a negative impact on the value of our customers' investments and assets in a number of ways. These so-called sustainability risks can have a direct impact on the asset, financial and earnings situation and also on the reputation of the investment properties. Since such risks cannot ultimately be completely ruled out, we have developed specific strategies for the financial services we offer in order to be able to identify and limit sustainability risks.
- Through the predominant use of funds (especially ETFs), the investments are diversified so broadly that possible sustainability risks that can arise from individual companies only make up a marginal part of the overall portfolio and thus possible sustainability risks are limited. The equity portion of our customer portfolios typically includes over 5,000 different companies through the use of ETFs and other funds.
- To limit sustainability risks, we try to identify and, if possible, exclude investments in companies that have an increased risk potential. With specific exclusion criteria, we see ourselves in a position to align investment decisions (or investment recommendations) with environmental, social or corporate values. For this purpose, we generally use valuation methods recognized in the market.
- The identification of suitable investments can consist, on the one hand, in investing in (or recommending) investment funds whose investment policy is already equipped with a suitable and recognized sustainability filter to reduce 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). The specific details result from the individual agreements.
- Our company's strategies for incorporating sustainability risks are also incorporated into the company's internal organizational guidelines. Compliance with these guidelines is crucial for evaluating the work performance of our employees and thus has a significant influence on future salary development. In this respect, the remuneration policy is in line with our strategies for incorporating sustainability risks (Art. 5 Disclosure Regulation).
Gerd Kommer Capital
You can find the sustainability-related disclosure of the asset manager as part of GKC (Scalable Capital GmbH). here.
