Sustainability Disclosures

ESG DBTCA Article 5 Remuneration Policy Disclaimer

 

DBTCA - Deutsche Bank Trust Company Americas (applicable solely to Germany-domiciled Discretionary Portfolio Management Clients)

 

Introduction

 

The Sustainable Finance Disclosure Regulation (SFDR)[1] came into effect on March 10, 2021. SFDR imposes transparency obligations (website disclosures, pre-contractual disclosures) and periodic reporting requirements on investment management firms at both a product and entity/manager level. This disclosure document relates to the “Website Disclosure” regulatory obligations arising out of SFDR Articles 3-10.
 

Definitions

 

For the purposes of this disclosure document, ‘Sustainability Risk’ means an environmental, social or governance event or condition that, if it occurs, could cause an actual or a potential material negative impact on the value of the investment.

For the purposes of this disclosure document, the following definitions apply:

 

(1) ‘Financial Market Participant’ means:

    (a)   an insurance undertaking which makes available an insurance‐based investment product (IBIP);

    (b)   an investment firm which provides portfolio management;

    (c)    an institution for occupational retirement provision (IORP);

    (d)   a manufacturer of a pension product;

    (e)   an alternative investment fund manager (AIFM);

    (f)    a pan‐European personal pension product (PEPP) provider;

    (g)   a manager of a qualifying venture capital fund registered in accordance with Article 14 of Regulation (EU)            No 345/2013;

    (h)   a manager of a qualifying social entrepreneurship fund registered in accordance with Article 15 of Regulation (EU) No 346/2013;

    (i)     a management company of an undertaking for collective investment in transferable securities (UCITS management company); or

    (j)     a credit institution which provides portfolio management.

 

(2) ‘Financial Product’ means:

    (a)   a portfolio managed in accordance with point (6) of this Article;

    (b)   an alternative investment fund (AIF);

    (c)   an IBIP;

    (d)   a pension product;

    (e)   a pension scheme;

    (f)   a UCITS; or

    (g)   a PEPP.
 

(3) ‘Sustainable Investment’ means an investment in an economic activity that contributes to an environmental objective, as measured, for example, by key resource efficiency indicators on the use of energy, renewable energy, raw materials, water and land, on the production of waste, and greenhouse gas emissions, or on its impact on biodiversity and the circular economy, or an investment in an economic activity that contributes to a social objective, in particular an investment that contributes to tackling inequality or that fosters social cohesion, social integration and labor relations, or an investment in human capital or economically or socially disadvantaged communities, provided that such investments do not significantly harm any of those objectives and that the investee companies follow good governance practices, in particular with respect to sound management structures, employee relations, remuneration of staff and tax compliance.

 

Sustainability related product disclosure

The information contained in this section is provided in accordance with Art. 10 of the REGULATION (EU) 2019/2088 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of November 27, 2019, on sustainability‐related disclosures in the financial services sector (the Disclosure Regulation).

 

Products with sustainable investment objective

 

DBTCA acts in the capacity of a Financial Market Participant and may offer Financial Products in scope of the SFDR. Currently DBTCA does not offer to Germany-domiciled clients any products that have a Sustainable Investment objective (Article 9). 

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