1. Information under the EU Disclosure Regulation
(Regulation (EU) 2010/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability‐related disclosures in the financial services sector)
We are obliged by law to give the following information.
We have no intention to promote ecological or social characteristics in our investment strategies or for other specific financial instruments.
Our attitude towards sustainability in asset investment
As part of its social responsibility, BPM desires to make a contribution to doing business in a more sustainable, resource-efficient manner, with the particular goal of reducing the risks and impacts of climate change. Besides keeping sustainability goals within our own organisation, we see it as our responsibility to make BPM's customers aware of aspects of sustainability. Therefore, as part of our asset management we ask our customers for their thoughts and wishes concerning sustainability, which we then implement.
Impacts of sustainability risks
Environmental conditions, social unrest and/or poor business management can have negative impacts in many respects on the value of the investments and assets in the portfolios BPM manages. The condition of assets, finance and yield as well as the reputation of individual investments can be directed impacted by these sustainability risks, as they are known. Since such risks can never be completely ruled out, we have developed specific strategies for the financial services we offer so that we can recognise and limit sustainability risks.
How we deal with sustainability risks
To limit risk we try as best we can to identify and rule out investments related to companies that have an increased potential for sustainability risks. By using specific criteria, we are able to orientate investment decisions according to environmental, social and company values. For this we typically implement valuation methods that are recognised on the market.
Identifying suitable investments means that we invest in funds whose policy already includes a recognised and suitable sustainability filter for reducing sustainability risks. Identifying suitable investments and limiting sustainability risks also means that we draw on the valuations of recognised ratings agencies for selecting the products for asset management. Specific details on these can be found in individual customer agreements.
BPM's strategies for including sustainability risks also inform our internal company guidelines. Following these guidelines is critical in evaluating our employees' work and critically influences the future development of their salary. In this way our wages policy accords with our strategies for considering sustainability risks.
No consideration of adverse impacts on sustainability factors
Investment decisions can have adverse impacts on the environment (e.g., the climate, water, biodiversity), on social topics and employees' concerns and also have a detrimental effect on controlling graft and corruption.
BPM takes great interest in taking its responsibility as a financial services provider seriously and to making a contribution to preventing these kinds of impacts when making investment decisions for asset management. However, based on the current circumstances brought about by the existing bureaucratic framework and that which is expected to follow, implementing the statutory provisions to regulate this puts an unreasonable demand on us as an owner-managed mid-sized company. Moreover, fundamental legal questions are still not clear.
So as not to put ourselves at a legal disadvantage, we cannot currently make a public declaration to confirm that we consider the adverse impacts on sustainability factors (environmental concerns, social concerns, etc.) when making decisions about investments or how we go about this. We are therefore obliged to point out on our website that for the time-being we do not consider the adverse impacts on sustainability factors and will not do so until further clarification is forthcoming.
However, we expressly declare that this action does not alter our readiness to make a contribution to doing business in a more sustainable, resource-efficient manner, with the particular goal of reducing the risks and impacts of climate change and other ecological and social problems.
2. Shareholder engagement policy
Description and publication of the shareholder engagement policy
of BPM - Berlin Portfolio Management GmbH in accordance with Section 134b of the German Stock Corporation Act (AktG)
BPM - Berlin Portfolio Management GmbH - hereinafter referred to as "institution" - is as an asset management company within the meaning of Section 134a (1) No. 2 of the German Stock Corporation Act (AktG) subject to the provisions set out in Sections 134b and 134c AktG and is, therefore, required to describe and publish its shareholder engagement policy within the meaning of Section 134b (1) AktG.
The institution does not engage in exercising shareholder rights of its clients. It does not attend shareholders' meetings or exercise voting rights on behalf of its clients. The institution only takes note of communications and notifications from public investee companies in the context of mandatory notifications, and it does not engage in active communications with the investee companies or their shareholders.
Having regard to the aforesaid, the institution's shareholder engagement policy is as follows:
- The institution does not engage in exercising shareholder rights within the meaning of Section 134b (1) No. 1 AktG with respect to investee companies. In particular, it does not exercise any rights related to general meetings of public limited companies. Rights to a share in profits within the meaning of Section 60 et seq. AktG and subscription rights are exercised in consultation with clients.
- Important matters concerning the investee companies within the meaning of Section 134b (1) No. 2 AktG are monitored by taking note of the financial statements and ad-hoc reports the investee companies are required to disclose by law.
- The institution does not engage in any exchange of views with corporate bodies and/or stakeholders within the meaning of Section 134b (1) No. 3 AktG.
- The institution does not cooperate with other shareholders within the meaning of Section 134b (1) No. 4 AktG.
- If there are conflicts of interest within the meaning of Section 134b (1) No. 5 AktG, these will be disclosed to those affected in accordance with the statutory requirements and further steps will be clarified with them.
- The institution does not disclose information annually on the implementation of the shareholder engagement policy within the meaning of Section 134b (2) AktG, because it does not engage in exercising the relevant shareholder rights.
- The institution does not disclose information about its voting behaviour within the meaning of Section 134b (3) AktG, because it does not engage in exercising voting rights.