Sustainability-related disclosures
Status: January 1, 2024
Article 3: Transparency of sustainability risk policies
Investment process: Since 2010, we at ACATIS have been intensively involved with sustainable investments and developed the "Fair Value Investment Process", which combines sustainability and value investing. This sustainability approach is not only consistently implemented and further developed in the ACATIS Fair Value funds, but also in client-specific mandates. In addition to ESG criteria, SDG targets and CO2 emissions of companies are increasingly considered.
As part of risk management, sustainability risks, which are increasing due to climate change, for example, are also taken into account by ACATIS.
The EU Disclosure Regulation requires companies to take sustainability risks into account.
ACATIS has decided on the following five implementation methods:
1) Transparency: For all ACATIS funds, a sustainability bar has been displayed on the monthly reports since the beginning of 2020, transparently showing what percentage of the portfolio is sustainable according to our ACATIS Fair Value criteria. A monthly sustainability investment report additionally specifically addresses sustainability issues.
2) Compliance with minimum standards: Since 2021, ACATIS has been implementing sustainable exclusion criteria for a portion of its funds in accordance with BVI requirements to ensure the ESG impact standard in accordance with the Disclosure Regulation. These are for the investments: Arms including outlawed weapons, tobacco production, coal as well as serious violations of UN Global Compact and for sovereign issuers insufficient scoring according to Freedom House Index.
3) Good governance is the key to sustainable investments. If the right standards are applied, a company will adapt to the latest findings on sustainability and thus act sustainably and prudently. Empirical studies confirm this. Since 2020, ACATIS has been using analysis and voting recommendations from ISS Institutional Shareholder Services with a sustainable strategy in mind. When voting at general meetings, ACATIS places particular emphasis on good corporate governance. In several cases, for example, we have already voted against the proposals of the management board for the appointment of supervisory board members or auditors when possible dependencies, conflicts of interest or accumulations of mandates were identified. In individual cases, poor governance leads to liquidation (example Wirecard) or to dialog with the Management Board and Supervisory Board (examples LPKF or Grenke).
4) Emphasis on goal achievement. The Sustainable Development Goals indicate universally accepted targets without being too narrowly focused on specific measures. By investing in companies that strive for these goals, offer products in these subject areas or are suppliers for them, it is possible to invest in future-oriented companies free of ideologies. For example, starting in 2019, the UN's 17 Sustainable Development Goals were introduced as an active filter in the sustainability process of ACATIS Fair Value funds.
5) In addition, most ESG goals are a reflection of world views. ACATIS tries to capture these goals through client surveys and to reflect them in the investment process. World views are subject to change and need to be updated regularly. In the ACATIS Fair Value funds, these ESG world views are implemented in a purist form.
Fund advisors: ACATIS also sees itself as an investment boutique, which - in addition to a team of in-house portfolio managers - also works with external fund advisors. Only those fund advisors are selected for cooperation who enjoy an impeccable reputation, are close to our investment philosophy and have significant years of experience in their respective segment.
__________
Article 4: Statement on principal adverse impacts of investment decisions on sustainability factors
ACATIS considers the transparency of adverse sustainability impacts at entity level in accordance with Annex 1, Table 1 of Delegated Regulation (EU) 2022/1288.
2023_Artikel 4_DE
2023_Article 4_EN
2023_Artículo 4_ES
2023_Article 4_FR
2023_Articolo 4_IT
2023_Artikel 4_NL
2023_Artikkel 4_NO
2023_Artigo 4_PT
2023_Artikel 4_SE
__________
Article 5: Transparency of remuneration policies in relation to the integration of sustainability risks
The most important financial performance indicator for ACATIS is the net margin on inventory-dependent income (excluding performance-fee remuneration). As a result of the income margin and the income generated by it, employees receive fixed and variable remuneration in accordance with the remuneration policy. The performance fee is generally not fixed as it cannot be forecast.
Sustainability risk is defined as an event or condition in the environmental, social or corporate governance area, the occurrence of which could have a significant negative impact on the value of the investment and therefore on the profit margin of ACATIS. Sustainability risks can therefore lead to a significant deterioration of the financial profile, liquidity, profitability or reputation of the underlying investment. This may also have a negative impact on the financial situation of ACATIS.
ACATIS distinguishes sustainability risks in remuneration with internal and external factors.
Internal factor: We refer to the sustainability guideline of ACATIS - travel activity. In order to reduce CO2 to protect the climate, we use conferencing systems to limit business travel to what is absolutely necessary. Our employees are encouraged to travel by train. A free Bahncard is available for this purpose. ACATIS employees do not receive a company car in addition to their fixed and variable compensation. The use of public transportation is encouraged and facilitated by the central location of the office (S-Bahn, U-Bahn and bus stops are in the immediate vicinity of the office).
External factor: As part of the selection of assets for the investment funds, the influence of risk indicators, including sustainability risks, are assessed in addition to the objectives and investment strategies.
The risk quantification assessment includes aspects of sustainability risks and relates them to other factors (esp. price and expected return) in the investment decision.
In general, risks (including sustainability risks) are already taken into account in the investment evaluation process (price indication) based on the potential material impact of risks on the return of the investment asset. ACATIS works with positive and negative lists for Article 8 and Article 9 funds respectively. Therefore, it is not possible to artificially maximize the return margin for ACATIS through investments with high returns but poor ESG ratings or high sustainability risks with the aim of increasing the variable compensation in the short term.
__________
ACATIS Investment Kapitalverwaltungsgesellschaft mbH has decided to classify the funds offered or distributed by our company in accordance with the Disclosure Regulation (Regulation (EU) 2019/2088) as follows:
In Article 6 (level Comply or Basic) are classified:
- ACATIS Asia Pacific Plus Fonds
- ACATIS Datini Valueflex Fonds
- ACATIS IfK Value Renten
- ACATIS QILIN Marco Polo Asien Fonds
- ACATIS Value Performer.
__________
Article 7: Transparency of adverse sustainability impacts at financial product level
The consideration of adverse sustainability impacts at financial product level according to Annex 1, Table 1 of Delegated Regulation (EU) 2022/1288 is carried out as part of the investment decisions for the investment fund through binding exclusion criteria and the Controversy Risk Assessment.
Since 2023, information on the principal adverse impacts on sustainability factors has been included in the annual reports of the investment funds for Article 8 and Article 9 funds.
__________
In Article 8 (application of environmental or social characteristics) are classified:
- ACATIS Aktien Global Fonds
- ACATIS Aktien Global Value Fonds
- ACATIS AI US Equities
- ACATIS AI Global Equities
- ACATIS Global Value Total Return
- ACATIS Value Event Fonds
- ACATIS Value und Dividende.
The challenge here lay in the precise screening of the criteria and the analysis of what consequences the classification in Article 8 has for the investable universe of equities and fixed-income securities for the funds concerned. The pre-contractual information was updated accordingly.
__________
In Article 9 (Sustainable investments), the following are classified:
- ACATIS Fair Value Aktien Global
- ACATIS Fair Value Deutschland ELM
- ACATIS Fair Value Modulor Vermögensverwaltungsfonds
Only companies that meet high standards in terms of environmental and social criteria and good corporate governance and contribute to the UN's 17 Sustainable Development Goals are selected for these funds. The pre-contractual information has been updated accordingly.
For the most part, the classifications have already come into effect as of March 10, 2021 with the corresponding adjustment of the respective sales prospectus and the key investor information documents (KID). The sales prospectuses and key investor information documents (KID) are published on our website www.acatis.de under the heading Investment Funds.
Sustainable Finance Disclosure Regulation as pdf.
__________
Article 10: Sustainability-related disclosures: