SUSTAINABLE FINANCE DISCLOSURE REGULATION (SFDR) STATEMENT/SUSTAINABILITY-RELATED DISCLOSURE REQUIREMENT
FM Verwaltung GmbH (FM) is a capital management company within the meaning of the German Investment Code (Kapitalanlagegesetzbuch, KAGB). It publishes the following information on its website in accordance with Regulation (EU) 2019/2088 on sustainability-related disclosure requirements in the financial services sector (the “SFDR”).
Unless information is explicitly provided in relation to a specific fund managed by FM, the following refers to FM’s management and investment decision-making processes in general.
I. DEALING WITH SUSTAINABILITY RISKS IN THE INVESTMENT PROCESS
FM supports the European Union’s efforts to increase transparency on sustainability issues and considers sustainability risks as part of the investment decision-making process and due diligence prior to any investment. “Sustainability Risk” means an environmental, social or governance event or condition, the occurrence of which could have an actual or potential material adverse effect on the value of the investment.
The FM reserves the right, after due consideration, to decide not to invest or to invest despite sustainability risks, in which case the FM may take measures to reduce or mitigate any sustainability risks. The yardstick for a decision by the FM in dealing with sustainability risks is the principle of proportionality. This means that the effort should always be proportionate to the size and nature of the investment, as well as the transactional context and related scope.
We regularly review our strategy to ensure that it takes into account new risks as well as investor concerns.
II. DEALING WITH ADVERSE SUSTAINABILITY IMPACTS
FM, by its very nature, considers adverse impacts of investment decisions on sustainability factors.
“Key adverse impacts on sustainability factors” are those impacts of investment decisions that have adverse impacts on sustainability factors.
“Sustainability factors” are environmental, social and labor concerns, respect for human rights, and anti-corruption and anti-bribery.
A concept is currently being developed to integrate sustainability indicators into the due diligence process in an even more structured and measurable way prior to investment receipt. Work is also being carried out on implementing controlling with regard to sustainability factors for ongoing portfolio management in order to ensure continuous monitoring of the investments. If adverse effects on sustainability factors become known, FM enters into a mitigation process with the management of the respective investment, whereby the principle of proportionality also applies here. FM has set itself the goal of anchoring sustainability goals in the strategic orientation of its own organization and the portfolio companies. FM’s long-term goal is for its awareness of sustainability to be reflected in the strategies, business organization and risk management of the supervised companies.