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For us, more sustainability means fewer risks. We consider non-financial aspects* as risk factors and work with specialists to adequately integrate a suitable process for evaluating the ESG guidelines of companies and issuers into our investment process.

We support the UN Global Compact Pillars in the areas of human rights, labor standards, the environment and the prevention of corruption.

Exclusion criteria and process integration

At least 75% of the assets of the BlackPoint Evolution Fund are invested in securities whose issuers have been selected on the basis of ecological and social criteria as well as characteristics of responsible corporate management.

To check the sustainability of corporate / covered bonds and stocks, individual issuers are rated on the basis of sustainability criteria that include ecological and social aspects as well as responsible corporate management (governance). Our proprietary screening and the evaluation of ESG company data and analyzes were designed with the help of ISS DataDesk, where ISS ESG sustainability filters are generally used. ISS ESG has internationally recognized expertise in all areas of sustainable and responsible investments. These include topics such as climate change, UN SDGs, biodiversity, human rights, labor standards, corruption, controversial weapons and much more.

In a first step, filters are used to take into account predefined exclusion criteria for issuers. Violations of internationally recognized standards such as the UN Global Compact Pillars and activities in controversial business areas are excluded. In addition, upper sales limits may not be exceeded in critical business areas. Issuers with the lowest rating according to the ISS ESG logic are generally not investable.

In the second step, the sustainability of the remaining possible investments is then checked. The ISS ESG Performance Score is used for this. This score evaluates companies based on their environmental, social and corporate governance (ESG) data. Only if a company has not been excluded via the aforementioned exclusion criteria and achieves a minimum value in the ESG Performance Score is it classified as sustainable.

A multi-stage process is used to check the sustainability of issuers of government bonds. Bond issues from unfree states, states with high levels of corruption and states that hinder the free practice of religion are excluded. In addition, the states are subjected to an ESG minimum score review.

In the first step, non-free states are excluded using the aggregate score of the Freedom House “Freedom in the World” list. In a second step, states with a high level of corruption, measured by the “Corruption Perceptions Index” of Transparency International, and in a third step, states that prevent the free exercise of religion, are excluded using the “Government Restriction Index” of the Pew Forum. In the last step, the sustainability of the remaining possible investments is then checked using an ESG minimum score. This evaluates the states on the basis of their environmental, social and control or administrative (ESG) data. Only if a country has not been excluded via the aforementioned exclusion criteria and achieves a minimum value in the ESG Performance Score is it classified as sustainable.

* When making an investment decision, not only sustainability aspects have to be taken into account, but also all the characteristics/goals mentioned in the sales documents.

> Sustainability-related disclosures (German), BlackPoint Evolution Fund

Influence on general meetings (Voting)

When investing, compliance with ESG criteria is passive towards the company: We are concerned with actively confronting violations of compliance with ESG criteria. Through the cooperation of the fund administration company of our mutual fund (BlackPoint Evolution Fund) with IVOX Glass Lewis we can exert influence on company general meetings.

IVOX Glass Lewis is a subsidiary of Glass, Lewis & Co., the leading independent governance analysis and proxy voting company with a global client base of more than 1,200 institutions who collectively manage more than $ 25 trillion in assets. Glass Lewis empowers institutional investors to make informed voting decisions at more than 22,000 meetings per year by identifying and assessing governance, business, legal, political and accounting risks at issuers based in 100 countries.

> IVOX Glass Lewis 2022 Policy Guidelines

* When making an investment decision, not only sustainability aspects have to be taken into account, but also all the characteristics/goals mentioned in the sales documents.

> Sustainability-related disclosures (German), BlackPoint Evolution Fund

Principal Adverse Impact Statement

The Sustainable Finance Disclosure Regulation (SFDR) defines sustainability factors in the form of environmental, social and employee concerns, respect for human rights and the fight against corruption and bribery. Principal Adverse Impact is generally understood to mean the negative impact that an investment decision has on these factors. This statement describes how we consider the Principal Adverse Impact (PAI) of our investment decisions on sustainability factors in accordance with Article 4 of the SFDR.

Almost all types of economic activities have the potential to affect various sustainability indicators both positively and negatively. The PAI indicators can be used to measure whether and to what extent investments are made in sustainability factors.

We try to manage the risk of negative impacts on sustainability factors through various means. These include exclusion criteria, the monitoring of norm violations and minimum requirements for issuers with regard to their ESG rating. In addition, we specifically monitor and assess a number of PAI indicators.

> Current PAI indicators monitored and scored by BlackPoint Asset Management

Description of actions taken to identify and address the main negative sustainability impacts

Subject to data availability, our portfolio management monitors the selected PAI indicators for all investments involved on an ongoing basis. For this purpose, data is determined and analyzed with the help of specialized third-party providers who meet the highest international standards and/or internal analyses. Issuers that show a high negative impact on certain indicators or groups of indicators are identified on the basis of this data and further analysis is analyzed. The results flow into our internal ESG assessment method and are taken into account in our investment process.

Measures to reduce negative sustainability impacts

Following standards

With the help of our multi-stage ESG process, we ensure that in the area of ​​sustainability, predefined minimum standards apply to the portfolio as a whole and to individual investments. Standard-based filters, exclusion criteria and minimum ratings are used for this. When analyzing individual investments, more factors are involved in the decisions.

PAI monitoring

Our PAI monitoring system applies a risk-based approach. First, the influence of an issuer on the individual PAI indicators is evaluated. The issuers are then evaluated based on this rating, both for individual indicators and at an overall level. The result feeds into an overall rating that indicates the performance of each issuer. Issuers that perform particularly poorly on individual indicators or overall are analyzed further by our portfolio management. These further analyzes can already contribute to solving the problem, for example if additional information from other sources leads to different results.

Possible outcome actions

If the further analyzes confirm the critical results of an issuer with regard to the PAI, a decision will be made on suitable measures. The spectrum includes the following possible measures:

  • No Action: The issuer's PAI indicator score IS deemed acceptable or established as not reflecting actual company performance.
  • Commitment: The issuer is asked to improve its performance in the areas concerned or to provide further data.
  • Foreclosure: The issuer is deemed unsuitable for investment in the portfolios that we influence and will be disqualified from investing.
    influencing companies

In addition to direct exchange with companies, we attach great importance to pursuing and promoting our ESG goals by exercising voting rights at annual general meetings. As soon as company shares have been acquired by us, a vote is taken within the framework of the participation policy we have set and in this way influence is exerted on companies and their management (unless there are important reasons against exercising voting rights). In order to be able to exercise the voting rights in a timely manner and in accordance with our participation policy, we have commissioned the leading independent provider of global governance services, IVOX Glass Lewis, with the execution.

Our participation policy includes extensive goals in the areas of the environment, social affairs and good corporate governance and is particularly applicable in the areas of management composition, reporting, remuneration structures and proposals from shareholders or management. For example, we not only vote against inefficiently structured management, excessive compensation in upper management or inadequate standards in reporting, but also vote for strategy adjustments with the aim of reducing environmental risks or improving the social impact of business activities.
With the help of our service provider, every voting point is carefully weighed in line with the participation policy, so that the exercise of our voting rights does not counteract our (ESG) goals as a whole.

Consideration of international standards

Our ESG policy, which includes this PAI statement, is based on the United Nations Principles for Responsible Investment and other relevant international conventions and standards, including:

  • United Nations Global Compact
  • OECD Principles of Corporate Governance
  • OECD Guidelines for Multinational Enterprises
  • United Nations Universal Declaration of Human Rights
  • United Nations Guiding Principles on Business and Human Rights
  • Rio Declaration on Environment and Development
  • United Nations Convention against Corruption
  • Convention on Cluster Munitions

We aim to respect these international standards and to promote compliance within our influence.

Data Used

Various data sources, which are supplied by different data providers, can be used throughout the process described. Should there be different data points on the same factors, the source considered to be the most appropriate is selected. The importance of each indicator is ranked using parameters that are reviewed and maintained by our portfolio management.

* When making an investment decision, not only sustainability aspects have to be taken into account, but also all the characteristics/goals mentioned in the sales documents.

> Sustainability-related disclosures (German), BlackPoint Evolution Fund

Data integration and risk measurement

Through data integration and constant screening of our investments for ESG-relevant topics and the associated transparent reporting, we are able to justify individual investment decisions as well as to report in detail for the entire portfolio on a consolidated basis. This enables us to continuously optimize our portfolio.

For example, we provide information about the effects of a company's product and service portfolio on the United Nations Sustainable Development Goals (SDGs). The reports reflect the proportion of portfolio holdings whose portfolio of products and services either contributes to the SDGs, hinders them or has no influence on them. Score applies to corporate securities only.

The Carbon Risk Rating (CRR) enables us to assess the impact on climate risks and opportunities and whether these are managed in such a way that opportunities are exploited and risks avoided or reduced. The reports show the positioning of our portfolio in terms of risk share and management.

* When making an investment decision, not only sustainability aspects have to be taken into account, but also all the characteristics/goals mentioned in the sales documents.

> Sustainability-related disclosures (German), BlackPoint Evolution Fund

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