Sustainability

As an insurance broker and adviser on insurance matters, we are to be considered within the context of brokering insurance-based investment products in terms of Art 2 clause 17 of DIRECTIVE (EU) 2016/97 OF THE EUROPEAN PARLIAMENT AND COUNCIL dated 20 January 2016 concerning insurance sales (hereinafter IDD) as a financial adviser pursuant to Art 2 clause 11 in terms of Art 2 clause 12 of REGULATION (EU) 2019/2088 OF THE EUROPEAN PARLIAMENT AND COUNCIL dated 27 November 2019 concerning sustainability-related disclosure requirements (hereinafter Offenlegungs-VO).

I. Consideration of sustainability risks pursuant to Art 3 (2) Offenlegungs-VO

Since fulfilling our ecological and social responsibility is a particular concern to us, our insurance group made the decision pursuant to Art 3 (2) Offenlegungs-VO to take sustainability risks into account within the context of selecting and advising on financial products. The selection of an insurance-based investment product takes place after a price/performance comparison in consideration of the product sustainability risk in terms of Art 2 clause 22 Offenlegungs-VO. In order to be able to take sustainability risks into account within the context of advice, we need relevant information from the product developer (insurance company in terms of Art 2 clause 2 Offenlegungs-VO). If the insurance-based investment product does not take sustainability risks into account pursuant to Art 6 (1) Offenlegungs-VO, we will expressly point out this circumstance.

II. Consideration of adverse impacts of investment decisions on sustainability factors pursuant to Art 4 (5) Offenlegungs-VO

Furthermore, we also take the adverse impacts of investment decisions on sustainability factors into account for our insurance advisory activity. The product developers disclose to us whether and how their developed insurance-based investment products take adverse impacts of investment decisions on sustainability factors into account (Art 4 (1) lit a Offenlegungs-VO) or whether and why these impacts are not taken into account (Art 4 (1) lit b Offenlegungs-VO). We will expressly point out this circumstance within the context of brokering insurance-based investment products.

III. Impacts on our insurance advisory activity

As a result of our commercial status as an insurance broker and adviser on insurance matters and the resulting legal obligation to consider the wishes and needs of our clients when brokering insurance-based investment products, we will broker insurance-based investment products according to Art 6, 8 and 9 Offenlegungs-VO in the future. If an insurance-based investment product is not sufficiently classified by the product developer, we will expressly point out this circumstance to the client.

IV. Consideration of sustainability risks in connection with our remuneration policy according to Art 5 Offenlegungs-VO

We receive remuneration directly from the insurer for the successful brokerage of insurance-based investment products within the context of our work as an insurance broker. These remunerations are commissions according to § 30 of the Brokers Act, in the form of acquisition/ follow-up/ service/ turnover/ portfolio/ participation commissions or bonuses. We ensure that our remuneration structure does not favour excessive risk-taking in relation to sustainability risks. In particular, we take precautions to ensure that the remuneration or anything else does not create incentives for us or our employees to recommend a certain insurance-based investment product to a customer even though another product would better meet the needs of the customer. Our internal compliance management system ensures that neither we nor our employees are remunerated in a way that conflicts with our duty to act in the best interests of our customers.