Here you will find information on regulatory measures:

Estably Asset Management Ltd. (hereinafter referred to as the “Company”) falls under the term “asset manager” as defined in Art. 367a No. 3 of the Liechtenstein Persons and Companies Act (PGR) and must therefore describe its participation policy as defined in Art. 367h PGR.

The company does not exercise any shareholder rights within the meaning of Art. 367h para. 1 items 1 and 4 PGR based on participation in the companies in which the company has invested within the scope of asset management mandates. In particular, no rights related to the general meetings of public limited companies are exercised. The right to a share in profits and subscription rights are exercised in consultation with the clients.

The monitoring of important matters of the companies in the sense of art. 367h par. 1 fig. 2 PGR is carried out by taking note of the legally required reporting of the companies in financial reports as well as ad hoc announcements.

There is no exchange of opinions with the corporate bodies and stakeholders of the companies within the meaning of art. 367h par. 1 fig. 3 PGR.

There is no cooperation with other shareholders or other stakeholders within the meaning of art. 367h para. 1 items 5 and 6 PGR.

In the event of conflicts of interest within the meaning of Art. 367h Para. 1 Clause 7 PGR, disclosure to the parties concerned shall be made in accordance with the legal provisions and a clarification of the further procedure with the same shall be made.

An annual publication on the implementation of the participation policy within the meaning of Art. 367h para. 2 PGR does not take place because the corresponding rights are not exercised.

There is no publication of voting behaviour within the meaning of Art. 367h Para. 2 PGR because there is no participation in voting.

Status: December 2021

You have chosen a service from Estably Asset Management Ltd. We would like to thank you for your trust.

As it is very important for us that you are satisfied with our service, please inform us immediately if you should ever be dissatisfied with our service.

Please use the following form to make a complaint:

Download Complaint Form PDF

Send us this form by e-mail, fax, or post:

Estably Asset Management Ltd.
z. Attn: Management/Compliance
PO Box 765
Schaanerstrasse 29
9490 Vaduz

Your complaint will be registered by our Compliance and reported to the management. Your complaint will be investigated immediately and you will receive a written response within 20 working days.

The out-of-court conciliation body in the financial services sector at is also available to you as a neutral and free-of-charge mediation body for complaints.

1. General

Regulations (EU) 2019/2088 and (EU) 2020/852 require certain disclosures regarding the sustainability of financial market participants. With this document, Estably Asset Management Ltd (ESTABLY) complies with these disclosure requirements.

ESTABLY is a securities institution that provides the service of asset management to its clients. ESTABLY offers various investment strategies as part of its asset management services. Where necessary, a distinction is made between these different offerings in the following statements.

This document is provided to prospective clients as pre-contractual information in the context of contract initiation. As the contents of this document are adapted from time to time, in particular also to comply with legal or other regulatory requirements, the current version is always available on ESTABLY’s website.


2. Statement on the non-consideration of adverse effects on sustainability factors

Investment decisions may have adverse effects on the environment (e.g. climate, water, biodiversity), on social and labor concerns, and may also be detrimental to the fight against corruption and bribery. ESTABLY strives to fulfill its responsibilities as a securities institution and to help avoid such adverse effects at the corporate level.

As the relevant regulatory requirements (of which this Mandatory Disclosure is one of the subjects) have not yet been fully published at the time of writing, ESTABLY is also currently unable to make a binding statement to the effect that (and in what way) adverse effects of investment decisions on sustainability factors are taken into account.

Therefore, any adverse impact of investment decisions on Sustainability Factors will not be bindingly considered until further notice. As soon as the relevant regulatory guidance is fully published, ESTABLY will review this guidance and re-evaluate and, if necessary, adjust its position with respect to adverse impacts of investment decisions on sustainability factors.


3. Consideration of sustainability risks

As a company, we want to contribute to a more sustainable, resource-efficient economy with the aim of reducing the risks and impacts of climate change in particular.

In our investment process, we consider E (environmental), S (social) and G (governance) criteria. Sustainability risks resulting from the analysis of the ESG criteria are continuously analyzed with a view to their financial impact and the resulting findings on the sustainability risks of individual issuers are taken into account as part of the investment process when assessing the return and risk. Sustainability risks are environmental, social and governance (ESG) events or conditions, the occurrence of which may have an actual or potential material adverse effect on the value of investments. Sustainability risks can impact all known risk types and contribute as a factor to the materiality of these risk types. The affectedness, probability and severity of sustainability risks differ depending on the industry, business model and sustainability strategy of the issuer.

Sustainability risks are analyzed on the basis of publicly available information from the issuers (e.g. annual and sustainability reports) or internal research, as well as using data and ESG ratings from research or rating agencies. The company uses a Non-Financial Risk Committee as a control instrument, which continuously reviews the assessment of sustainability risks of individual issuers and provides concrete guidelines for the investment universe that can be invested in under sustainability risks. In addition to information at individual issuer level, this also includes assessments made on the basis of a global economic analysis (influence of ESG criteria on economic growth or the socio-demographic demand situation). Here, the way in which ESG criteria form macroeconomic trends is illuminated down to the sector level.

Furthermore, the company’s employees regularly receive comprehensive training and continuing education on the topic of sustainability.

Sustainability risks can have a negative impact on the return of the investment strategy in the investment process. In particular, they may lead to a material deterioration in the financial position, profitability or reputation of issuers and may have a significant impact on the valuation level of the investment. The investment strategies offered by ESTABLY do not take into account the EU criteria for environmentally sustainable economic activities.

The performance of the investment strategy may be affected by sustainability risks. Sustainability risks, as defined in Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability-related disclosure requirements in the financial services sector, are environmental, social or governance events or conditions, the occurrence of which could have an actual or potential material adverse effect on the value of the Portfolios’ investment. Sustainability risks can impact all known risk types and contribute as a factor to the materiality of those risk types. Examples include the following risk types: market risk, liquidity risk, counterparty risk and operational risk.


3.1. How sustainability risks are taken into account

ESTABLY considers sustainability risks in the investment process.

However, there is neither an application of environmental or social characteristics nor an effort to comply with sustainability objectives as defined in Regulation (EU) 2019/2088 and the EU criteria for environmentally sustainable business activities, nor minimum proportions of such investments.

So-called ESG ratings are calculated by MSCI, which assess the extent to which companies take into account the aforementioned sustainability indicators in the areas of environmental, social and corporate governance. These ESG ratings are used by ESTABLY to consider the sustainability risks. To prevent greenwashing, the external MSCI ESG ratings are used to consider sustainability risks.

Do these investment strategies take into account considerable adverse impacts on sustainability factors?

No, these investment strategies do not currently consider material adverse impacts on sustainability risks.

Methods used to measure the promotion of environmental and social characteristics

In ESTABLY’s investment universe, companies are selected with respect to a variety of quantitative and qualitative criteria. Companies are excluded that produce landmines, cluster munitions and nuclear weapons or that violate the so-called United Nations Global Compact.

In addition, ESTABLY evaluates the investments based on their ESG score. The approach used in calculating the ESG Quality Score is a rules-based methodology to measure companies’ resilience to long-term environmental, social and governance risks. Companies are rated on a scale from “AAA” to “CCC” depending on the respective ESG risks relevant to the industry and the ability of companies to manage these risks compared to competitors. The higher the ESG Quality Score, the better for the environment.

ESG Score Estably EN


Data sources and data processing

ESTABLY works with one of the world’s leading sustainability data providers: MSCI ESG Research via This data allows us to integrate our responsible approach into ETF selection. We use publicly available company documents and data from alternative sources, including governments, regulators and non-governmental organizations. In addition, MSCI ESG Research LLC accesses over 3,400 media outlets for data sourcing. These ratings are critically reviewed for plausibility by the Investment Committee, which meets regularly.

Due diligence

ESTABLY sources ESG ratings from the provider MSCI via

Reference benchmark

ESTABLY has set the following benchmark for the Value green strategy: 63% MSCI World ESG, 27% Euro Stoxx 50 ESG, 10% Cash


3.2. Sustainable investment strategy

ESTABLY’s “Value green” strategy considers companies that meet certain ESG standards.

3.2.1. Method of incorporating sustainability risks

The strategy “Value green” therefore promotes sustainability in the areas of environment (Environment), Social (Social) and Governance, but does not strive for a sustainability target as defined in Regulation (EU) 2019/2088 and the EU criteria for environmentally sustainable economic activities, nor any minimum proportions of such investments.

Which environmental and/or social characteristics are being advertised?

When selecting companies, in addition to the selection criteria in the non-sustainable investment strategies, the three aspects of sustainability (environmental, social and corporate governance) are taken into account. In doing so, ESTABLY primarily selects companies from the investment universe on which the classic ESTABLY strategies are based, whose composition takes certain ESG standards into account.

As a rule, the following indicators, among others, can be taken into account:

Environment (Environmental)

– Exclusion of companies whose main source of income is coal-fired power generation; and

– Exclusion of companies involved in the extraction of oil from oil sands or the mining of oil sands.

Social (Social)

– Exclusion of companies whose main source of income is the sale or distribution of tobacco products; and

– Exclusion of companies involved in business with civilian and socially controversial weapons or nuclear weapons; and

– Maintaining high standards of occupational health and safety.


– Compliance with the principles (including human rights) of the UN Global Compact; and

– Consideration of violations of competition rules and corruption laws.

MSCI analyzes controversial business areas, evaluating the extent to which the companies take into account the above indicators. This rating is used by ESTABLY when selecting companies for the Value green strategy.


3.3. Transparency of the remuneration policy in relation to the consideration of sustainability risks

Our company’s strategies for incorporating sustainability risks are also incorporated into the company’s internal organizational guidelines. Observance of these guidelines is decisive for the evaluation of our employees’ work performance and thus has a significant influence on future salary development. In this respect, the compensation policy is in line with our strategies for incorporating sustainability risks.