Grenzweg 5A, 26209 Hatten

Dr. Andreas Spiegel & Dr. Sven Abels

Commercial register:
Amtsgericht Oldenburg, HRB 277011


Legal information

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Sustainability disclosures
Disclosure requirements under Regulation (EU) 2019/2088 (“SFDR”).

Updated: 23.05.2023


Pursuant to Regulation (EU) 2019/2088 („SFDR“), there is an obligation for financial market participants and financial advisors to provide information on certain sustainability topics in terms of the SFDR. This information obligation is fulfilled in the following paragraphs. This information obligation is fulfilled in the following paragraphs.

Sustainability risks within the meaning of the SFDR are events or conditions in the environmental, social or corporate governance fields, the occurrence of which could actually or potentially have a material adverse effect on the value of the investment. Sustainability risks are part of the types of risks already known, such as market risk, liquidity risk, counterparty risk, and operational risk, and can affect the materiality of these risks.

Consideration of sustainability risks can have a material impact on the performance of an investment over the long term. Issuers with poor sustainability standards may be more susceptible to event, reputational, regulatory, litigation, and technology risks. These sustainability risks may impact, among other things, operations, brand or company value, and the continued existence of the company or investment. The occurrence of these risks may result in a negative valuation of the investment, which in turn may impact the funds’ return.


Information on strategies for incorporating sustainability risks into investment decision-making processes.
Art. 3 SFDR

A stand-alone sustainability strategy is not pursued. nvestment decisions are made at the Company on the basis of a fundamental research process. In principle, sustainability risks are taken into account in investment decisions, but they are not decisive for the investment decision. Anchoring of sustainability risks in investment decisions cannot be guaranteed in every case.


No consideration of negative sustainability impacts
Art. 4 SFDR

Sustainability factors include environmental, social and employee concerns, respect for human rights, and the fight against corruption and bribery.

We do not currently consider adverse impacts of investment decisions on sustainability factors. The relevant data required to identify and weight adverse impacts on sustainability factors are not yet available in the market to a sufficient extent or of the required quality.

We will regularly review the data situation and, if necessary, use this as a basis to decide again on the possibility of taking into account the most significant adverse effects of our investment decisions on sustainability factors as part of internal strategies.

Information on the compensation policy in connection with the consideration of sustainability risks
Art. 5 SFDR

The consideration of sustainability risks is not decisive for the evaluation of the work performance of our employees and remains without influence on future salary development. The compensation of the company’s employees and partners is not based on potential sustainability risks.