Gerd Kommer Invest GmbH
Statement on the Non-Consideration of Adverse Impacts on Sustainability Factors (Art. 4 SFDR)
Due to statutory requirements (Art. 4 (1) (a) and (2) SFDR or Art. 4 (5a) SFDR), we are obliged to provide the following information:
- Investment decisions may have adverse impacts on the environment (e.g. climate, water, biodiversity), on social and employee matters, and may also be detrimental to the fight against corruption and bribery.
- As a financial services provider, we are fundamentally very interested in fulfilling our responsibility and helping to avoid such impacts in the context of our investment decisions (or investment recommendations). However, based on the current situation, the implementation of the legal requirements prescribed for this purpose is unreasonable due to the existing and foreseeable bureaucratic framework conditions. In addition, essential legal questions remain unresolved.
- To avoid legal disadvantages, we are therefore currently prevented from issuing a public statement explaining whether and how we consider adverse impacts of our investment decisions (or investment recommendations) on sustainability factors (environmental matters, etc.). We are therefore required to state on our website that we do not consider these impacts for the time being and until further clarification (Art. 4 (1) (b) SFDR or Art. 4 (5) (b) SFDR).
- However, we expressly state that this approach does not change our willingness to contribute to more sustainable and resource-efficient economic activity, with the aim of reducing the risks and impacts of climate change and other ecological or social issues.
Our strategies for the integration of sustainability risks (Art. 3 SFDR)
Due to statutory requirements (Art. 3 SFDR), we are obliged to provide the following information. We do not intend to promote environmental or social characteristics in our investment strategies or for other specific financial instruments:
- As a company, we aim to contribute to more sustainable and resource-efficient economic activity, with the objective of mitigating, in particular, the risks and impacts of climate change. In addition to observing sustainability goals within our own corporate organisation, we consider it part of our responsibility to raise awareness among our clients regarding sustainability aspects within the scope of our business relationship.
- Environmental conditions, social distortions and/or poor corporate governance can negatively affect the value of our clients’ investments and assets in various ways. These so-called sustainability risks may have direct consequences on the financial position, financial performance and reputation of investment assets. As such risks cannot be completely excluded, we have developed specific strategies for the financial services we offer in order to identify and limit sustainability risks.
- By predominantly using funds (in particular ETFs), investments are broadly diversified so that potential sustainability risks arising from individual companies represent only a marginal portion of the overall portfolio, thereby limiting possible sustainability risks. In the equity portion of our clients’ portfolios, over 5,000 companies are typically represented through the use of ETFs and other funds.
- To limit sustainability risks, we seek to identify and, where possible, exclude investments in companies that exhibit an increased risk profile. Using specific exclusion criteria, we believe we are able to align investment decisions (or investment recommendations) with environmental, social or governance-related values. For this purpose, we generally rely on recognised assessment methods available on the market.
- The identification of suitable investments may consist in investing in (or recommending) investment funds whose investment policy already incorporates an appropriate and recognised sustainability filter to reduce sustainability risks. Suitable investments may also be identified by relying on recognised rating agencies for the product selection in asset management (or for recommendations in investment advisory services). The specific details result from the individual agreements.
- Our company’s strategies for the integration of sustainability risks are also incorporated into internal organisational guidelines. Compliance with these guidelines is essential for the assessment of our employees’ performance and thus significantly influences future salary development. As such, the remuneration policy is consistent with our strategies for the integration of sustainability risks (Art. 5 SFDR).
