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ESG SUSTAINABILITY

Environmental Social Governance

” What we do today determines what the world will look like tomorrow. “
Marie von Ebner Eschenbach

DISCLOSURE REGULATION

Information on financial products in accordance with Disclosure Regulation (EU) 2019/2088 of 27.11.2019

a) Summary

The financial product is the financial portfolio management or investment advice in the various investment strategies offered by us.

b) "No sustainable investment objective"

This financial product advertises ecological or social features, but does not aim to make sustainable investments.

c) "Environmental or social characteristics of the financial product"

In the sustainable mandates, the selection of financial instruments as part of the implementation of the agreed investment strategy is geared towards avoiding adverse consequences for environmental, social and employee concerns and contributing to respect for human dignity and the fight against corruption and bribery.

d) "Investment strategy"

We rely on the sustainability research of ISS ESG for the sustainability assessment of individual stocks. Further information can be found here.

We currently use the rating system of ISS ESG, one of the world’s leading sustainability research agencies, to determine the extent to which the above-mentioned sustainability issues are taken into account in the financial instruments we invest in. If we use investment funds as part of sustainable investment strategies, we select fund concepts that are classified as sustainable by the product providers (KVG). Components of the sustainability strategy include exclusion criteria for certain business areas and standards-based screening for the selection of companies, taking into account minimum standards for business activities (global standards and ESG controversies). Furthermore, the investment universe consists of companies that deliver the best sustainability performance within their sector or category and focus increasingly on ecological and ethical risk avoidance and opportunity exploitation (best-in-class). Based on this, we generally consider the adverse effects on sustainability issues to be sufficiently taken into account in a mandate.

e) "Allocation of investments"

See section “Pre-contractual product information in accordance with Article 14 Delegated Regulation (EU) 2022/1288 of 06.04.2022”

f) "Monitoring of environmental or social characteristics"

The environmental or social characteristics are monitored via the risk classification by the ISS ESG rating agency.

g) "Methods"

The financial product is classified according to our sustainability strategy. Further information can be found here.

h) "Data sources and processing"

a) The sustainability research of ISS ESG is used.

b) The methods used to collect the data are made available in a transparent manner.

c) The data is used for the financial product as part of our investment process.

d) No data is estimated by HRK Lunis.

i) "Restrictions on methods and data"

We are not currently aware of any restrictions.

j) "Duty of care"

The selection of financial instruments for the financial product includes exclusion criteria for certain business areas and standards-based screening for the selection of companies, taking into account minimum standards for business activities (global standards and ESG controversies). Furthermore, the investment universe consists of companies that deliver the best sustainability performance within their sector or category and focus increasingly on ecological and ethical risk avoidance and opportunity exploitation (best-in-class).

k) "Participation policy"

The selection of financial instruments for the financial product includes exclusion criteria for certain business areas and standards-based screening for the selection of companies, taking into account minimum standards for business activities (global standards and ESG controversies). Furthermore, the investment universe consists of companies that deliver the best sustainability performance within their sector or category and focus increasingly on ecological and ethical risk avoidance and opportunity exploitation (best-in-class).

l) "Specific reference value"

No reference value is used.

PRE-CONTRACTUAL INFORMATION

On the financial products referred to in Article 8(1), (2) and (2a) of Regulation (EU) 2019/2088 and Article 6(1) of Regulation (EU) 2020/852

Name of the product: Financial portfolio management or investment advice

Company identifier (LEI code): 529900TPGTVU8EHK2750

Ecological and/or social characteristics

What environmental and/or social features are advertised with this financial product?

The aim of the financial product is to limit the investment in terms of ESG risks. Environmental and social characteristics are also taken into account in the rating used. No reference value is used here. No specific environmental or social characteristics are advertised and no specific efforts are made to contribute to environmental or social objectives.

What sustainability indicators are used to measure the achievement of the individual environmental or social characteristics promoted by this financial product?

No individual sustainability indicators are used, but only a summarized ESG rating.

What are the objectives of the sustainable investments that this financial product is partly intended to achieve and how does the sustainable investment contribute to these objectives?

No sustainable investments are being sought.

To what extent will the sustainable investments, some of which are to be made with the financial product, not significantly harm any of the environmental or social sustainable investment objectives?

No sustainable investments are being sought.

How were the indicators for adverse impacts on sustainability factors taken into account?

The main adverse impacts according to Annex 1 of Delegated Regulation (EU) 2022/1288 on sustainability factors according to Article 2 No. 24 Regulation 2019/2088 are not taken into account in the investment decision.

How are sustainable investments in line with the OECD Guidelines for Multinational Enterprises and the United Nations Guiding Principles on Business and Human Rights? Further information:

No sustainable investments are being sought.

How are sustainable investments in line with the OECD Guidelines for Multinational Enterprises and the United Nations Guiding Principles on Business and Human Rights? Further information:

No sustainable investments are being sought.

Does this financial product take into account the main adverse impacts on sustainability factors?

No

What investment strategy is pursued with this financial product?

The sustainable investment strategy is formed from a combination of the “best-in-class approach”, which aims to ensure that no company is excluded per se due to its business activities and that controversial issues are taken into account, as well as our own negative and exclusion criteria.

What are the binding elements of the investment strategy used to select investments to meet the advertised environmental or social objectives?

Components of the sustainability strategy include exclusion criteria for certain business areas and standards-based screening for the selection of companies, taking into account minimum standards for business activities (global standards and ESG controversies). Furthermore, the investment universe consists of companies that deliver the best sustainability performance within their sector or category and focus increasingly on ecological and ethical risk avoidance and opportunity exploitation (best-in-class). Based on this, we generally consider the adverse effects on sustainability issues to be sufficiently taken into account in a mandate.

By what minimum rate is the size of the investment considered before applying this investment strategy reduced?

./.

How are the good corporate governance practices of the companies in which investments are made assessed?

The assessment of good corporate governance practices is carried out in the mapping of the ESG rating.

What asset allocation is planned for this financial product?

Investments are to be made in liquid financial products via individual investments, ETFs and funds. No sustainable investments are sought.

To what extent does the use of derivatives achieve the environmental or social characteristics advertised with the financial product?

Derivatives are used to hedge the portfolio.

To what minimum extent are sustainable investments with an environmental objective compliant with the EU taxonomy?

No sustainable investments are being sought.

Does the financial product invest in EU taxonomy-compliant activities in the fossil gas and/or nuclear energy sector?

No sustainable investments are being sought.

What is the minimum proportion of investment in transition and enabling activities?

No sustainable investments are being sought.

What is the minimum proportion of sustainable investments with an environmental objective that do not comply with the EU taxonomy?

No sustainable investments are being sought.

Which investments fall under "#2 Other investments", what is their investment purpose and is there a minimum level of environmental or social protection?

The selection of financial instruments as part of the implementation of the agreed investment strategy should be geared towards avoiding adverse consequences for environmental, social and employee concerns and contributing to respect for human dignity and the fight against corruption and bribery.

Where can I find more product-specific information on the Internet?

Further product-specific information is available at: www.hrklunis.de

SUSTAINABLE EFFECTS

No consideration of sustainable
Effects on sustainability factors

Sustainability and the preservation of ecological resources, including fair living conditions, is a key issue for us with a high priority. Long-term, sustainable returns can only be achieved if the basis of life is preserved for future generations. As part of the financial sector, we see ourselves as having a special responsibility to actively promote climate protection goals with the means of investment and thus contribute to a more sustainable economy overall.

In accordance with Art. 6 of the EU Taxonomy Regulation, we are obliged to inform you that the principle to avoid significant adverse effects only applies to those investments underlying the financial product that take into account the EU criteria for environmentally sustainable economic activities.

The investments underlying the remaining part of this financial product do not take into account the EU criteria for environmentally sustainable economic activities.

Further information can be found in the following documents:

CONTACT

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