Legal matters
1) Principles of sustainability
At the FINVIA Group, we have adopted the following sustainability principles:
- Thinking and acting sustainably is a fundamental value for FINVIA Capital GmbH ("FINVIA Capital") and FINVIA Family Office GmbH ("FINVIA FO") (together "FINVIA"), and not just since the emergence of the sustainability debate on environmental, social and governance ("ESG") factors in the public domain. FINVIA considers all three areas of ESG perspectives to be equally important and interrelated in their impact.
- FINVIA's understanding of sustainability is characterized by the idea of intergenerational justice and the awareness that our actions today have consequences for the lives of future generations. This understanding corresponds to a definition of sustainable development as formulated by Gro Harlem Brundtland at the 42nd UN General Assembly in 1987: "Sustainable development is development that meets the needs of the present without compromising the ability of future generations to meet their own needs".
- FINVIA considers impact investing to be the most effective form of sustainable investment when it comes to implementing sustainability in asset management. We are of the opinion that impact investing can be implemented most effectively via private transactions ("private markets"), i.e. not via a public stock exchange or comparable trading venue.
- Impact investing aims to contribute to the transformation of society and the economy from a social and environmental perspective and to generate a positive return. Impact investments are characterized by the fact that they aim to achieve an explicit ecological and/or social impact (intentionality), their impact is demonstrably additive, i.e. the positive impact is attributable to the investment or has been significantly increased by the investment (additionality) and the impact is measured in as quantified a form as possible (measurability).
As an independent multi-family office, FINVIA FO's mission is to provide its clients with comprehensive, objective and needs-based advice on their strategic asset allocation (SAA) and wealth management . This applies above all in the area of sustainability. The client determines in what form and to what extent their individual sustainability preferences should be taken into account when investing their assets. When FINVIA Capital provides the client with investment advice or financial portfolio management services ("wealth management"), it takes into account the client's desired sustainability preferences in addition to returns, liquidity and security within the scope of its possibilities and in consultation with the client.
2) Mandatory publication on sustainability
In accordance with Articles 3 and 4 of Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability-related disclosures in the financial services sector (Regulation (EU) 20219/2088; Disclosure Regulation; "Disclosure Regulation"), FINVIA Capital GmbH ("FINVIA Capital"), including its contractually bound intermediary FINVIA Family Office GmbH ("FINVIA FO"), provides the following information:
As a company, we at FINVIA Capital and FINVIA FO want to contribute to a more sustainable, resource-efficient way of doing business in accordance with our sustainability principles, with the aim of reducing the risks and effects of climate change in particular. In addition to observing sustainability goals in our corporate organization itself, we also see it as our task to sensitize our customers to aspects of sustainability in the structure of their business relationship with us. As part of financial portfolio management ("wealth management") and investment advice - but not as part of the so-called non-advisory business when providing investment brokerage services - we inquire about their ideas, wishes and sustainability preferences and then implement these with external asset managers.
Investment decisions made by FINVIA Capital within the scope of its own wealth management may have a negative impact on the environment (e.g. climate, water, biodiversity), on social and employee issues and may also be detrimental to the fight against corruption and bribery. However, environmental conditions, social upheaval or poor corporate governance can also have a negative impact 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 wealth, financial and earnings position and also on the reputation of the investment properties.
At FINVIA Capital, we have a fundamental interest in fulfilling our responsibility as a securities institution and helping to take into account or avoid such effects in our investment decisions at wealth management and our recommendations in investment advice. As things stand at present, however, the implementation of the legal requirements specified for this is still difficult to compare due to the wide variety of methods used in practice to analyze and evaluate sustainability factors. The introduction of the existing and impending bureaucratic framework conditions is also currently disproportionate. Furthermore, key legal issues are still unresolved.
In order to avoid legal disadvantages, we are therefore currently prevented from making a public statement to the effect that and in what way we take into account the adverse effects on sustainability factors (such as environmental concerns, etc.) in our investment decisions in wealth management and recommendations in investment advice. We are therefore required to state on our website that we do not take these into account for the time being and until further clarification.
However, we expressly declare that this approach does not alter our willingness to contribute to a more sustainable, resource-efficient economy with the aim of reducing the risks and effects of climate change and other environmental or social grievances in particular. We attach particular importance to social responsibility in our own corporate management. Sustainable thinking and action are at the heart of our corporate identity and are also reflected in our internal remuneration policy.
Please note that FINVIA FO acts exclusively in the name, for the account and under the liability of FINVIA Capital when providing investment brokerage and investment advice. FINVIA FO provides these services as a contractually bound intermediary of FINVIA Capital in accordance with Section 3 (2) sentence 1 of the German Securities Institutions Act ("WplG").