Estably Vermögensverwaltung AG (hereinafter referred to as the “company”) falls under the term “asset manager” according to Art. 367a No. 3 of the Liechtenstein Persons and Companies Act (PGR) and must therefore describe its participation policy within the meaning of 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 of the profits as well as subscription rights is 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 between 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 no. 7 PGR, disclosure to the parties concerned shall be made in accordance with the legal provisions, and clarification of the further course of action shall be made with them.

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

Status: December 2022

You have chosen a service from Estably Vermögensverwaltung AG. We would like to thank you for your trust.

Since it is very important to 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
P.O. Box 765
Schaanerstrasse 29
9490 Vaduz
Liechtenstein

Tel +423 220 29 70
E-mail [email protected]

Your complaint will be registered by our Compliance and reported to the Executive Board. Your complaint will be investigated immediately and you will receive written feedback within 20 working days.

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

You can find our current document set here.

1. General

Regulations (EU) 2019/2088 and (EU) 2020/852 require certain disclosures on 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 for 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.

The present document is provided to interested parties as pre-contractual information within the framework of the contract initiation. As the contents of this document are amended from time to time, in particular, 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 labour concerns and may also be detrimental to the fight against corruption and bribery. ESTABLY strives to fulfil its responsibilities as a securities institution and to help avoid such adverse effects at the level of the company.

As the relevant regulatory requirements (of which this Mandatory Disclosure is one) have not been fully published at the time of writing, ESTABLY is not yet in a position to make a binding statement as to whether (and in what way) adverse effects of investment decisions on sustainability factors will be taken into account.

Therefore, ESTABLY declares not to take into account the adverse effects of investment decisions on sustainability factors in a binding manner until further notice. Once the relevant regulatory guidance is published in full, ESTABLY will review this guidance and reassess and, if necessary, adjust its position on the adverse impact 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.

Our investment process considers E (environmental), S (social) and G (governance) criteria (ESG criteria). Sustainability risks resulting from the analysis of the ESG criteria are continuously analysed with regard to their financial impact and the resulting findings on the sustainability risks of individual issuers are taken into account within the framework of the investment process when evaluating the return and risk assessment. 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 the investments. Sustainability risks can affect 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.

Furthermore, the company’s employees regularly receive comprehensive training and further 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 can lead to a significant deterioration in the issuer’s financial position, profitability or reputation and 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.

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 within the meaning of Regulation (EU) 2019/2088 and the EU criteria for environmentally sustainable economic activities, nor any minimum proportions of such investments.

The analysis of sustainability risks is carried out on the basis of publicly available information from issuers (e.g. annual and sustainability reports) or internal research as well as using data and ESG ratings from research or rating agencies.

MSCI calculates so-called ESG ratings, which assess the extent to which companies take into account the stated sustainability indicators in the areas of environment, social affairs and corporate governance. These ESG ratings are used by ESTABLY to take sustainability risks into account. To prevent greenwashing, the external MSCI ESG ratings are used for the consideration of sustainability risks.

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

No, these investment strategies do not currently take into account any material adverse impacts on sustainability risks.

Methods for measuring the promotion of environmental and social characteristics

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

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

Data sources and Data processing

ESTABLY uses one of the world’s leading providers of sustainability data: MSCI ESG Research. This data allows us to integrate our responsible approach into investment selection. This involves analysing publicly available company documents and data from alternative sources, including those from governments, authorities and non-governmental organizations. In addition, MSCI ESG Research LLC accesses more than 3,400 media outlets to gather data. These ratings are critically reviewed for plausibility by the Investment Committee, which meets regularly.

Due Diligence

ESTABLY obtains ESG ratings from the provider MSCI.

Reference benchmark

Estably has not set its own benchmark with dedicated environmental or social characteristics.

Sustainable investment strategy

ESTABLY’s Value Green strategy considers companies that meet certain ESG standards.

The way in which sustainability risks are included

The Value Green strategy, therefore, promotes environmental, social, and governance sustainability, but does not seek to achieve a sustainability target as defined in Regulation (EU) 2019/2088 and the EU criteria for environmentally sustainable business activities, nor a minimum proportion of such investments.

Which environmental and/or social features are promoted by the investment strategy?

When selecting companies, the three aspects of sustainability (environmental, social and corporate governance) are taken into account in addition to the selection criteria in the non-sustainable investment strategies. 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 energy extraction from coal; and
• Exclusion of companies involved in the extraction of oil from oil sands or the mining of oil sands.

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
• Adherence to high standards of occupational health and safety.

Corporate governance(Governance)

• Compliance with the principles (including compliance with human rights) of the UN Global Compact; and
• Consideration of violations of competition rules and corruption laws.

MSCI analyses controversial business areas, which assess the extent to which the companies take the above indicators into account.

This rating is used by ESTABLY when selecting companies for the Value Green strategy.

Transparency of the remuneration policy in connection with the consideration of sustainability risks

Our company’s strategies for incorporating sustainability risks also flow into the company’s internal organisational guidelines. The 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 remuneration policy is in line with our strategies for the inclusion of sustainability risks.

Stand: Februar 2023

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