Sustainability Note

Asset Allocation AG is an independent, BaFin-licensed financial services company pursuant to Section 15 of the German Securities Trading Act (WpIG), whereby the company exclusively engages in activities subject to a fee pursuant to Section 2(2)(3) of the WpIG, specifically investment brokerage for suitable counterparties. Neither investment advice nor portfolio management is offered. Furthermore, the company falls under Article 17(1) of the Disclosure Regulation. Consequently, due to legal requirements (Art. 3 of the Disclosure Regulation), the company is not subject to sustainability-related disclosure obligations.

As a company, however, we are very much committed to contributing to a more sustainable, resource-efficient business model, with the goal of reducing, in particular, the risks and impacts of climate change. In addition to practicing sustainable business practices within our company, we also see it as our responsibility to raise our customers’ awareness of sustainability issues as we shape our business relationships with them.

Environmental conditions, social upheavals, and/or poor corporate governance can have negative effects on the value of our clients’ investments and assets in a number of ways. These so-called sustainability risks can have a direct impact on the financial position, financial performance, and profitability of the investment properties, as well as on their reputation.

However, de rAsset Allocation AG’s scope of action is severely limited: As an intermediary, it merely presents products to institutional clients but, as a general rule, does not provide investment advice.

FAILURE TO TAKE SUSTAINABILITY FACTORS INTO ACCOUNT

Investment decisions can have adverse effects on the environment (e.g., climate, water, biodiversity), on social issues—as well as on employee and stakeholder concerns—and can also hinder efforts to combat corruption and bribery.

We have a fundamental and significant interest in fulfilling our responsibilities as a financial services provider and in helping to prevent such impacts in connection with the products we offer. However, as things stand, compliance with the applicable legal requirements is unreasonable given the existing and impending bureaucratic constraints. Furthermore, key legal issues remain unresolved.

We are therefore compelled to state on our website that, for the time being and pending further clarification, we do not take into account adverse effects on sustainability factors (environmental issues, etc.) as defined by the Disclosure Regulation (Art. 4(1)(b) of the Disclosure Regulation and Art. 4(5)(b) of the Disclosure Regulation).