Fund classification in accordance with Regulation (EU) 2019/2088 on sustainability-related disclosures in the financial services sector
The Disclosure Regulation (EU) 2019/2088 (also often referred to as "SFDR") requires financial market participants and financial advisors to disclose information on the approaches used to integrate or consider sustainability risks in investment decisions, the consideration of adverse impacts of investments on sustainability factors (PAI) and the design of products with regard to the pursuit of sustainable characteristics or objectives.
For Ampega, the systematic consideration of sustainability risks in investment decisions is an essential part of the strategic orientation and thus an integral component of the management of all investment assets.
Selected fund products also pursue sustainability criteria in the areas of environmental, social or good corporate governance or a combination of these (E=Environmental, S=Social, G=Governance). Such products classified as sustainable are divided into ESG strategy products (Art. 8) and ESG impact products (Art. 9). For an ESG strategy product, the environmental and/or social characteristics pursued must be specified and a description given of how these are to be achieved. For ESG impact products, a specific sustainability objective must be defined and the approach to achieving these objectives must be described.
In addition, the company is a signatory to the Principles for Responsible Investment (PRI) and is thus committed to expanding sustainable investments and complying with the six principles for responsible investment established by the UN.
Fund products that are disclosed in accordance with Article 9 of the SFDR have a high level of sustainability. This is demonstrated, among other things, by a significant proportion of sustainable investments and at least one sustainable objective that is specifically defined in the investment strategy and goes beyond economic gains. To this end, the fund invests in green, social or sustainability bonds. A bond can only be classified as a green, social or sustainability bond if it meets the recognized ICMA (International Capital Market Association) standards for green, social or sustainability bonds. The Green Bond Principles (GBP), together with the Social Bond Principles (SBP) and the Sustainability Bond Guidelines (SBG), are published under the auspices of the ICMA Principles. The Principles are a collection of voluntary guidelines with the mission and vision to support the international capital market in financing the transition towards greater sustainability. For the issuance of bonds for social and/or environmental projects, the Principles set out best practices based on global guidelines and recommendations to promote transparency and disclosure and support the integrity of the market.
The fund is also subject to a fundamental ESG strategy. This is achieved by limiting ESG-relevant risks and controversies as well as the determination of inadmissible assets by the ESG Committee. In addition to individual analyses, it also uses information from specialized external service providers. Relevant factors and information include ESG ratings, information on controversial weapons, human rights, labor standards, environmental concerns and corruption prevention (UN Global Compact criteria). Based on this information, exclusion lists and thresholds for permissible sustainability risks and corresponding controversies are defined for the various asset classes.
In addition, exclusion criteria based on "Principal Adverse Impacts" (PAIs) are applied in order to exclude from the outset issuers that do not take sufficient account of the principles of sustainability ("ESG"). See also section ESG strategy incl. MiFID II (Art. 8+).
- Ampega Global Green Bonds Fund
The ESG strategy is implemented by the ESG Committee in the form of limiting ESG-relevant risks and controversies and determining inadmissible assets. In addition to individual analyses, it also uses information from specialized external service providers. Relevant factors and information include ESG ratings, information on controversial weapons, human rights, labor standards, environmental concerns and corruption prevention (UN Global Compact criteria). Based on this information, exclusion lists and thresholds for permissible sustainability risks and corresponding controversies are defined for the various asset classes.
In a first step, the funds apply the so-called best-in-class approach to the selection of assets alongside other possible strategies. This means the relatively best performance of a company compared to its competitors. According to this principle, companies within a sector are compared directly with each other and checked for their sustainability. Preference is always given to the investment objects that best fulfill the sustainability criteria of environmental, social and governance ("ESG"), i.e. are "best in class". This means that the following ESG criteria, for example, are taken into account when selecting assets in addition to financial success:
Environment ("Environmental"): Avoiding climate transition risks, preserving flora and fauna, protecting natural resources and the atmosphere, limiting soil degradation and climate change, avoiding interference with ecosystems and biodiversity loss.
Social ("Social"): General human rights, prohibition of child and forced labor, compliance with the principles of equal treatment, fair working conditions and appropriate remuneration.
Governance: Compliance with corporate ethics and anti-corruption principles in accordance with the UN Global Compact, guiding principles of good corporate governance and regulations to prevent money laundering and terrorist financing.
This "best-in-class" approach promotes competition towards greater natural, social and cultural compatibility. The selection process is based on an assessment of ESG scores and a rating comparison. As a result, the investment universe comprises companies that demonstrate a leading ESG performance in an industry comparison and are particularly committed to sustainable development. This means that the capital management company does not acquire a fixed selection of assets within an industry or sector, taking into account the above criteria, but can overweight or underweight individual industries or sectors. This may result in individual industries or sectors not being considered in the selection of assets, while a large number of assets are selected from other industries or sectors if the capital management company makes a correspondingly positive assessment.
In addition, exclusion criteria based on "Principal Adverse Impacts" (PAIs) are applied in order to exclude from the outset issuers that do not take sufficient account of the principles of sustainability ("ESG"). This ensures that none of the environmental and social objectives specified in Art. 2 No. 17 of the Disclosure Regulation or in Art. 9 of Regulation (EU) 2020/852 ("Taxonomy Regulation") are significantly impaired.
In principle, PAIs are defined as material or potentially material adverse impacts on sustainability factors that result from, worsen or are directly related to investment decisions. Specifically, the PAIs include standard factors from the areas of environment, social affairs and corporate governance and provide information on the extent to which investment objects can have a negative impact on these components. The PAIs are 64 indicators defined by the EU for which the Disclosure Regulation provides both narrative and quantitative disclosure requirements for financial market participants. Of the total of 64 indicators, 18 are subject to reporting requirements and relate to greenhouse gas emissions, biodiversity, water, waste and social aspects with regard to companies, countries and real estate investments. Reporting on the remaining 46 indicators is voluntary, with 22 indicators covering additional climate and other environmental aspects and the remaining 24 indicators covering social and employee factors, respect for human rights and anti-corruption and bribery.
- Ampega AmerikaPlus Equity Fund I (a)
- Ampega AmerikaPlus Equity Fund P (a)
- Ampega BasisPlus Bond Fund I (a)
- Ampega BasisPlus Bond Fund P (a)
- Ampega Credit Opportunities Bond Fund I (a)
- Ampega Credit Opportunities Bond Fund P (a)
- Ampega Diversity Plus Equity Fund P (a)
- Ampega DividendePlus Equity Fund I (a)
- Ampega DividendePlus Equity Fund P (a)
- Ampega EurozonePlus Equity Fund I (a)
- Ampega EurozonePlus Equity Fund M (t)
- Ampega EurozonePlus Equity Fund P (a)
- Ampega Faktor StrategiePlus I (a)
- Ampega Faktor StrategiePlus P (a)
- Ampega ISP Dynamic
- Ampega ISP Comfort
- Ampega ISP Sprint
- Ampega Rendite Rentenfonds
- Ampega Reserve Bond Fund I (a)
- Ampega Reserve Bond Fund P (a)
- Ampega Corporate Bond Fund
- C-QUADRAT ARTS Total Return ESG H
- C-QUADRAT ARTS Total Return ESG I
- C-QUADRAT ARTS Total Return ESG IH
- C-QUADRAT ARTS Total Return ESG T
- Equity Risk Control AMI I (a)
- Equity Risk Control AMI S (a)
- Grönemeyer Health Fund Sustainable I (a)
- Grönemeyer Health Fund Sustainable P (a)
- terrAssisi Equities I AMI C (t)
- terrAssisi Shares I AMI I (a)
- terrAssisi Shares I AMI M (a)
- terrAssisi Shares I AMI P (a)
- terrAssisi Bonds I AMI
- terrAssisi Endowment Fund I AMI
- Value Intelligence ESG Fund AMI CH (a)
- Value Intelligence ESG Fund AMI I (a)
- Value Intelligence ESG Fund AMI P (a)
- Wagner & Florack Entrepreneur Fund AMI I (a)
- Wagner & Florack Entrepreneur Fund AMI P (a)
- Wagner & Florack Entrepreneur Fund flex C (a)
- Wagner & Florack Entrepreneur Fund flex I (a)
- Wagner & Florack Entrepreneur Fund flex P (a)
The funds apply exclusion criteria and also manage according to an ESG strategy (e.g. "best-in-class"):
The first step of operationalization takes the form of limiting ESG-relevant risks and controversies as well as the determination of inadmissible assets by the ESG Committee. In addition to individual analyses, it also uses information from specialized external service providers. Relevant factors and information include ESG ratings, information on controversial weapons, human rights, labor standards, environmental concerns and corruption prevention (UN Global Compact criteria). Based on this information, exclusion lists and thresholds for permissible sustainability risks and corresponding controversies are defined for the various asset classes.
In a second step, the company has developed a comprehensive filter catalog from the combination of the aforementioned requirements, which is applied to the investments made. By consistently excluding negatively rated securities and assessing ESG scores, the permissible investment universe is defined and investments in securities with a high sustainability risk are prevented or limited.
In addition, investments with a sustainable focus are prioritized when selecting securities using a fund-specific ESG strategy (e.g. "best-in-class"). The assessment of the social and environmental characteristics of the investments is based on information from specialized external data providers as well as our own analyses carried out by internal analysts. The composition of the portfolio as well as the ESG scores, exclusions and other sustainability factors of the underlying assets are reviewed both at the time of the investment decision and on an ongoing basis.
- AEI Multi Asset Defensive I (a)
- Ampega Responsibility Fund
- C-QUADRAT ARTS Total Return BalancedH
- C-QUADRATARTS Total Return BalancedT
- C-QUADRATARTS Total Return Balanced T (CHF hedged)
- C-QUADRAT ARTS Total Return Balanced T (PLN)
- C-QUADRAT ARTS Total Return BalancedVT
- C-QUADRATARTS Total Return Balanced VT(CZKhedged)
- C-QUADRAT ARTS Total Return Balanced VT-Foreign (PLNhedged)
- C-QUADRAT ARTS Total Return BalancedVT-Domestic
- C-QUADRAT ARTS Total Return Bond A
- C-QUADRAT ARTS Total Return Bond H
- C-QUADRAT ARTS Total Return Bond T
- C-QUADRAT ARTS Total Return Bond VTA
- C-QUADRAT ARTS Total Return Bond VTA (CZK hedged)
- C-QUADRAT ARTS Total Return Bond VTA (PLN hedged)
- C-QUADRAT ARTS Total Return Bond VT-foreign (PLN)
- C-QUADRAT ARTS Total Return Bond VT-Inland
- C-QUADRATARTS Total Return Dynamic H
- C-QUADRAT ARTS Total Return Dynamic I
- C-QUADRAT ARTS Total Return Dynamic IH
- C-QUADRATARTS Total Return DynamicT
- C-QUADRATARTS Total Return Dynamic T(PLN)
- C-QUADRAT ARTS Total Return DynamicVT
- C-QUADRATARTS Total Return DynamicVT-Domestic
- DVAM More values AMI
- Global Equities Quant GetCapital I (a)
- I-AM ETFs-Portfolio Select CZK (t)
- I-AM ETFs-Portfolio Select EUR (d)
- I-AM ETFs-Portfolio Select EUR P1
- Long Term Value
- PRO change AMI I (a)
- SALytic Endowment Fund AMI I (a)
- SALytic Endowment Fund AMI SV (a)
- SALytic Residential Real Estate Europe Plus I (a)
- Endowment fund STS
- Endowment fund STU
- Tresides Phönix One I (a)
- Value Intelligence Fund AMI I (a)
- Value Intelligence Fund AMI P (a)
- Value Intelligence Fund AMI S (a)
- Value Intelligence Fund AMI W (a)
- Zantke Euro Corporate Bonds AMI I (a)
- Zantke Euro Corporate Bonds AMI P (a)
- Zantke Euro Corporate Bonds AMI S (a)
- Zantke Euro High Yield AMI I (a)
- Zantke Euro High Yield AMI P (a)
- Zantke Euro High Yield AMI S (a)
- Zantke Global Credit AMI I (a)
- Zantke Global Credit AMI P (a)
- Zantke Global Credit AMI S (a)
- Zantke Global Equity AMI I (a)
The funds apply a basic filter catalog, which is applied to all investments made. This includes the exclusion of controversial arms manufacturers and consideration of the UN Global Compact criteria. This filter catalog is used to evaluate securities with regard to sustainability risks as part of the investment decision and is therefore taken into account in the allocation decision, but not explicitly managed accordingly.
- Ampega Balanced 3 I (a)
- Ampega Balanced 3 P (a)
- Ampega Real Estate Plus
- BAGUS Global Balanced I (a)
- BAGUS Global Balanced P (a)
- BAGUS Global Balanced S (a)
- ComfortInvest Substance
- CorvusFund
- C-QUADRAT ARTS Best Momentum H
- C-QUADRAT ARTS Best Momentum T
- C-QUADRAT ARTS Best Momentum T (PLN)
- C-QUADRAT ARTS Best Momentum VT
- C-QUADRAT ARTS Best Momentum VT-foreign (PLN hedged)
- C-QUADRAT ARTS Total Return Defensive A
- C-QUADRAT ARTS Total Return Defensive H
- C-QUADRAT ARTS Total Return Defensive T
- C-QUADRAT ARTS Total Return Defensive VT
- C-QUADRAT ARTS Total Return Global AMI H (t)
- C-QUADRAT ARTS Total Return Global AMI P (a)
- C-QUADRAT ARTS Total Return Value Invest Protect H
- C-QUADRAT ARTS Total Return Value Invest Protect VT
- C-QUADRAT ARTS Total Return Vorsorge §14 EStG A
- C-QUADRAT ARTS Total Return Vorsorge §14 EStG H
- C-QUADRAT ARTS Totall Return Vorsorge §14 EStG T
- CT World Portfolio AMI CT (a)
- CT Welt Portfolio AMI GG (a)
- CT World Portfolio AMI PT (a)
- ENRAK
- ENRAK I (a)
- ENRAK P (a)
- ENRAK Capital Investment I (a)
- ENRAK Capital Investment P (a)
- FAROS Global Equity
- FAROS Listed Real Assets AMI A (a)
- FAROS Listed Real Assets AMI C (a)
- FS Colibri Event Driven Bonds I (a)
- FS Colibri Event Driven Bonds S (a)
- FS Colibri Event Driven Bonds X (t)
- FVV Select AMI
- Global Emerging Markets Opportunities Conservative
- Global Equity Core AMI
- Global Equity Opportunities AMI
- Global Fixed Income AMI
- GlobalManagement Chance 100 P (t)
- GlobalManagement Classic 50 P (t)
- H&S Global Allocation
- LI MULTI LEADERS FUND
- LOYS Global MH A (t)
- LOYS Global MH B (t)
- LOYS Global MH C (t)
- MARTAGON Solid Plus
- Mayerhofer Strategy AMI I (a)
- Mayerhofer Strategy AMI P (a)
- MultiManager Fund 3
- Orbis Fund AMI I (a)
- Orbis Fund AMI P (a)
- Quant IP Global Patent Leaders I (a)
- Quant IP Global Patent Leaders P (a)
- S&H Smaller Companies EMU I (a)
- S&H Smaller Companies EMU P (a)
- S&H Net Asset Value I (a)
- S&H Substanzwerte P (a)
- Syntelligence Growth Funds P (a)
- Syntelligence Growth Funds S (a)
- T3 Global Allocation A (a)
- Tresides Balanced Return AMI A (a)
- Tresides Balanced Return AMI B (a)
- Tresides Commodity One A (a)
- Tresides Commodity One B (a)
- Tresides Dividend & Growth AMI A (a)
- Value Intelligence Gold Company Fund AMI I (a)
- Value Intelligence Gold Company Fund AMI P (a)
- Value Intelligence Gold Company Fund AMI S (a)
- WertArt Capital Fund AMI
- Values & Security - Sustainable Innovations I (a)
- Values & Security - Sustainable Innovations P (a)
- WKR Capital Accumulation Fund AMI
PAI - Principal Adverse Impacts
In addition, exclusion criteria based on "Principal Adverse Impacts" (PAI) are applied in order to exclude from the outset issuers that do not take sufficient account of the principles of sustainability ("ESG"). This ensures that none of the environmental and social objectives listed in Art. 2 No. 17 of the Disclosure Regulation or in Art. 9 of Regulation (EU) 2020/852 ("Taxonomy Regulation") are significantly impaired.
In principle, PAIs are defined as material or potentially material adverse impacts on sustainability factors that result from, worsen or are directly related to investment decisions. Specifically, the PAIs include standard factors from the areas of environment, social affairs and corporate governance and provide information on the extent to which investment objects can have a negative impact on these components. The PAIs are 64 indicators defined by the EU for which the Disclosure Regulation provides both narrative and quantitative disclosure requirements for financial market participants. Of the total of 64 indicators, 18 are subject to reporting requirements and relate to greenhouse gas emissions, biodiversity, water, waste and social aspects with regard to companies, countries and real estate investments. Reporting on the remaining 46 indicators is voluntary, with 22 indicators covering additional climate and other environmental aspects and the remaining 24 indicators covering social and employee factors, respect for human rights and anti-corruption and bribery.
Criteria for sustainable investment
As at 31.03.2022
On the one hand, the Group aims to avoid possible negative effects in its investments, for example by not investing in certain countries or business areas. On the other hand, the Group wants to promote positive impacts overall. To this end, we developed an ESG screening process in 2016.
We systematically developed our sustainability strategy in many areas in 2019. The Talanx Group and Ampega have signed the Principles for Responsible Investment (PRI) supported by the United Nations, thereby joining a framework for sustainable investment. At the same time, the decision was made to operate in a climate-neutral manner in Germany from this year onwards. The topic of engagement and participation was also strengthened with a new engagement policy and, in particular, the issue of exercising voting rights at Annual General Meetings was addressed.
We have been analyzing securities investments across the Group for compliance with ESG criteria for some time now. The screening is based on the ten principles of the UN Global Compact. The principles of responsible action serve as the basis for a broad filter catalog. In addition to these ten universal principles, which relate to human rights, labor standards, the environment and corruption prevention, the filter catalog also includes the exclusion of controversial weapons such as anti-personnel mines and the exclusion of coal (sales/production share >25 %). At the end of 2019, the filter catalog was expanded to include the criterion of oil sands.
In its business with institutional clients, Ampega offers individual ESG solutions based on a differentiated approach. To this end, ESG integration in the various asset classes was further advanced and cooperation with various sustainability data vendors was further intensified. Customers can now be offered more different exclusions, best-in-class approaches or impact strategies.
Ampega has been offering dedicated ESG focus products with different risk profiles for mutual funds for many years: The special funds terrAssisi Renten I AMI, terrAssisi Aktien I AMI and the terrAssisi Stiftungsfonds I AMI invest in companies and issuers that permanently incorporate environmental and social criteria into their corporate strategy in addition to economic criteria and are among the pioneers in terms of responsibility for the future. The classification is determined by the independent research agency ISS-ESG.
Summary
Ampega considers the main adverse impacts of investment decisions on sustainability factors. Sustainability factors include environmental, social and employee matters, respect for human rights, and anti-corruption and anti-bribery.
Strategy for identifying and weighting the main adverse sustainability impacts and sustainability indicators
Ampega has set up an ESG Committee, which implements the operationalization of the Group's sustainability strategy in capital investment and is also dedicated to the ESG investment concerns of external customers. Ampega has developed a comprehensive filter catalog that is applied to potential and actual investments to ensure that investments in companies that have a significant negative impact on environmental or social factors or a company that has violated human rights and labor standards, for example, are excluded. The defined adverse sustainability impacts considered are equally weighted and the indicators are selected based on market availability and the reliability of the data. The ESG Committee assesses the filter results of the ESG screening and derives alternative courses of action.
The main adverse sustainability impacts and measures taken in this context
The consideration of sustainability factors, including the impact of issuers on sustainability factors, is an integral part of the investment analysis. The company has established an ESG screening process for all liquid portfolios managed by Ampega. Across the Group, Ampega no longer invests in companies whose revenue and production share is more than 25% coal-based. In addition, this filter catalog has been expanded to include oil sands. Companies with more than 25% of their turnover from oil sands are affected by this exclusion. Information on human rights, labor standards, environmental issues and the prevention of corruption (UN Global Compact criteria) is also taken into account. The exclusion of manufacturers of controversial weapons such as anti-personnel mines was also included in the filter catalog. Based on this information, exclusion lists and threshold values for permissible sustainability risks and corresponding controversies are defined for the various asset classes in order to avoid or reduce adverse sustainability impacts. Whether a financial product is managed according to the principal adverse impact of investment decisions on sustainability factors (principal adverse impact) in addition to the exclusions mentioned depends on the SFDR fund classification on the one hand and on the individual investment strategy on the other. For Article 6 and 8 funds, for example, investment management can be based on exclusions. In the case of Article 8+ funds, the Principals Adverse Impact is predominantly also taken into account.
More detailed information on the extent to which a financial product takes principal adverse impacts into account can be found in the pre-contractual information for the individual financial products.
A full review of the investments made is carried out every six months to ensure compliance with the defined criteria with the support of external data providers.
As Ampega has been aiming to reduce the carbon intensity of its investment portfolio since 2021, CO2 emissions from issuers are also taken into account in its own investment decisions.
In addition to the raw data, Ampega regularly obtains information on changes in sustainability factors, the ESG scores of issuers and controversies via external data providers.
The ESG Committee determines criteria and individual considerations with regard to holding or reducing holdings. In addition to individual analyses, it also uses information from external and specialized service providers. In addition to the ESG Committee, there is also the Responsible Investment Committee (RIC) at Group level, which acts as an escalation body for breaches of predefined thresholds.
Adverse sustainability impacts are reduced or avoided through the consistent exclusion of negatively rated securities and an assessment of ESG scores.
Participation policy
The Group has also integrated sustainability factors into the engagement process and thus influences corporate governance and the orientation of the invested companies in order to reduce the main adverse impacts on sustainability factors and promote sustainability.
The company would like to point out that the engagement and voting process described below is currently only applied to the Group's own portfolios.
At present, voting rights are only exercised for holdings in German portfolio companies that are held in custody by Ampega's central custodians and whose shareholding in the portfolio company exceeds a threshold of 1% of the shares in circulation across all Group funds and holdings, which is subject to regular review.
The Talanx Investment Group strives to maintain a dialog with portfolio companies in the interests of its investors, but explicitly takes into account the size of its holdings in the portfolio companies in order to be able to weigh up the effect of an active exchange with the company.
At Group level, there is an internal committee to review and make decisions on the exercise of voting rights in all significant portfolio companies. External and specialized data providers are also used to analyse the documents for the Annual General Meetings. The company's engagement policy can be found here.
Corporate governance and international standards
Ampega designs its processes in accordance with its understanding of responsible investment. Responsible precautions are taken that incorporate the principles of responsible investment anchored in various standards into the investment processes to an appropriate extent. The Group's responsible corporate governance, which is geared towards sustainable value creation, is based on the German Corporate Governance Code.
Ampega is a signatory to the Principles for Responsible Investment (PRI) and is thus committed to expanding sustainable investments and complying with the six principles for responsible investment established by the UN. Ampega also supports the UN Global Compact, the world's largest initiative for responsible corporate governance.
As a full member of the Bundesverband Investment und Asset Management e.V. ("BVI"), Ampega is guided by the BVI's rules of conduct and assumes social responsibility in environmental and social matters as well as good corporate governance.
At Group level, the company has taken into account the recommendations of the Task Force on Climate-Related Financial Disclosures (TCFD) since 2020
Ampega is currently developing a climate strategy for Group portfolios. The company is aiming to achieve a low-carbon portfolio. The current goal is to reduce the CO2 intensity of the liquid portfolio (corporate bonds and equities) by 30% by 2025 compared to the beginning of 2020 and thus make an important contribution to achieving the goals of the Paris Climate Agreement.
For Ampega, the systematic consideration of sustainability risks in investment decisions is an essential part of its strategic orientation.
Sustainability risks are events or conditions in the environmental, social or corporate governance areas whose occurrence may have an actual or potential significant negative impact on the net assets, financial position and results of operations as well as on the reputation of the investments and whose market value may be affected as a result.
Ampega considers sustainability risks to be a supplementary type of risk that affects already known and established types of risk, such as market price risk, credit default risk, reputational risk or operational risk.
Ampega has developed its efforts in line with the Group strategy in order to include sustainability risks in the decision-making process and reduce the risks for investors. A basic filter catalog has been developed for all portfolios managed by Ampega Investment GmbH and Ampega Asset Management GmbH, which is applied to all investments made. This includes the exclusion of controversial weapons manufacturers and consideration of the UN Global Compact criteria. This approach means that investments are evaluated and taken into account with regard to sustainability risks as part of the allocation decision. The permissible investment universe is thus defined and investments with a high sustainability risk are limited.
Ampega is a signatory to the Principles for Responsible Investment (PRI) and is thus committed to expanding sustainable investments and complying with the six principles for responsible investment established by the UN.
Operationalization in the form of limiting ESG-relevant risks and controversies as well as the definition of inadmissible assets is carried out by the ESG Committee.
In addition to the ESG Committee, there is also the Responsible Investment Committee (RIC) at Group level, which is responsible for Group-wide issues and acts as an escalation body.
Consideration of sustainability risks in the investment process and the impact of sustainability risks on returns
Sustainability risks are included in the investment process and generally have an impact on all existing risk maps. Sustainability risks can impair the performance of the fund and the assets held in the fund and thus have a negative impact on the unit value and the capital invested by the investor. The company has developed a basic filter catalog that is applied to all investments made. This includes the exclusion of controversial arms manufacturers and consideration of the UN Global Compact criteria. This filter catalog is used to evaluate securities in terms of sustainability risks as part of the investment decision.
Further information on the way in which sustainability risks are included in the investment process and on the possible extent of the impact of sustainability risks on returns can be found on the website of the external asset manager can be found
Participation policy of Ampega - Engagement Policy
Engagement Policy 2024
In calendar year 2023, Ampega exercised the voting rights in its largest German portfolio companies at central custodian banks, as announced in its engagement policy. In addition, the voting rights of a special fund whose portfolio management is carried out by an external asset management company were exercised. Voting rights were also exercised on holdings whose threshold value exceeded 1% of the shares in circulation. In addition, voting rights were not exercised as this appeared justified in view of the high effort involved and the low voting weight