Publication pursuant to Regulation (EU 2019/2088) on sustainability‐related disclosures in the financial services sector (Disclosure Regulation)

The Disclosure Regulation obliges financial market participants and financial advisors to publish written strategies for the inclusion of sustainability risks.

As one of the first signatories of the UN PRI in Austria, C-QUADRAT Asset Management GmbH stands by the six "Principles for Responsible Investment" (UN PRI) and, as a licensed investment firm pursuant to Section 3 WAG (Austrian Securities Supervision Act) 2018 in accordance with the provisions of the Disclosure Regulation, it is both a financial market participant and a financial advisor.

C-QUADRAT Asset Management GmbH pursues the goal of including the main adverse effects of investment decisions on sustainability factors within the meaning of the Disclosure Regulation. However, since the financial instruments required for this purpose, which fully comply with the strict provisions of the Disclosure Regulation with regard to information to be disclosed, are currently only available to a limited extent and it is therefore not possible to always provide the service of portfolio management or investment advice in a sustainable manner within the meaning of the Disclosure Regulation, not 100% of the C-QUADRAT investment funds or the services offered by C-QUADRAT Asset Management GmbH meet the requirement of the Disclosure Regulation.

What are sustainability risks?

According to the Disclosure Regulation, sustainability risk is defined as an event or condition 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. In addition to sustainability risks, sustainability factors can also play a role in an investment. The Disclosure Regulation defines sustainability factors as environmental, social and employee concerns, respect for human rights and the fight against corruption and bribery.

Dealing with sustainability risks

The Company has currently not identified any potentially material adverse effects of sustainability risks on its investment activities or on its net assets, financial position, results of operations and/or reputation.

The company monitors actual or potential material negative impacts of sustainability risks on its investment activities as well as on the assets, financial and earnings position and the reputation of the company on an ongoing basis as part of its usual risk management strategy and is able to react promptly to any potential risks that may arise.

Information on the strategies for dealing with sustainability risks and on the most important adverse effects of investment decisions on sustainability factors of the investment funds and services offered by C-QUADRAT Asset Management GmbH can be found here:

General Information
https://www.cq-am.com/en/asset-management/sustainability/

Description Investment process
https://www.cq-am.com/fileadmin/redakteure/Documents/CQ_ESG_Product_Family_Investment_Process_EN.pdf

Consideration of sustainability risks in the remuneration policy

C-QUADRAT Asset Management GmbH has currently not explicitly stipulated the effects of sustainability risks as part of its remuneration policy. In principle, only a small part of the remuneration of the employees is variable, whereby qualitative criteria are the focus of the assessment. However, sustainability risks of the investment do not influence the remuneration either positively or negatively.

The remuneration policy does not create any incentives to use, broker or hold investment products that do not correspond to the client's investment strategy. As a result, our remuneration structure does not encourage excessive risk-taking with regard to the brokerage of investment products with high sustainability risks.

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