Transparency

Mission Statement of the Pension & Insurance Division

As a forward-looking intermediary, responsible and sustainable support in insurance matters is part of our self-image and mission statement. One of our most important corporate goals is to offer customised insurance cover and to achieve a high level of customer satisfaction. The basis for a high level of customer satisfaction is comprehensive and good counselling. This includes offering and recommending suitable - and if our clients wish - also sustainable (in the sense of ESG criteria) insurance investment and pension products, as well as the consideration of sustainability risks in the insurance selection. For this purpose, we obtain offers from the broad market spectrum.

What are sustainability risks?

Sustainability risks (ESG risks) are events or conditions in the environmental, social and governance fields, which could have a negative impact on the value of the investment. These risks can affect individual companies as well as entire industries or regions.

What are the examples of sustainability risks in these three areas?

• Environment: As a result of climate change, increased extreme weather events could pose a risk. This risk is also called physical risk. An example of this would be an extreme dry period in a certain region. This could cause levels of transport routes such as rivers to drop to such an extent that the transport of goods is impaired.
• Social: In the social area, risks could arise from non-compliance with labour law standards or health protection, for example.
• Corporate governance: Risks in the area of corporate governance include non-compliance with tax codes or corruption.

Information on the inclusion of sustainability risks in advisory activities (Art. 3 TVO)

In order to include sustainability risks in our consultation, the information provided by providers (financial market participants) and their financial products is taken into account in the selection process. Providers who do not have a recognisable strategy for including sustainability risks in their investment decisions may not be offered, depending on the client's wishes. Within the scope of the consultation, it may be presented separately if the consideration of sustainability risks in the investment decision means recognisable advantages or disadvantages for the client. The respective provider provides information on the consideration of sustainability risks in investment decisions in its pre-contractual information. The customer can ask questions about this in the run-up to a possible conclusion. Already now, all insurers are basically obliged by regulatory requirements to take sustainability aspects into account in their investment decisions. We are observing the further development and assume that with a broader market offer in the future, even greater consideration will be given. In order to assess sustainability risks, we also use additional information from service providers, associations or organisations that specialise in assessing these risks. In principle, the broadest possible spread (diversification) of the investment in financial products or, if necessary, also within a financial product is also recommended with regard to sustainability risks. We also check that the advisors have comprehensive knowledge of and can assess the sustainable products they offer. Up-to-date product knowledge is imparted through a qualified training and further education programme that goes beyond the legal requirements.

Information on the consideration of adverse impacts on sustainability factors (Art. 4 TVO)

Within the scope of the consultation, the most important adverse effects of investment decisions on sustainability factors are taken into account. The consideration is based on the information provided by the providers on their sustainability and, if applicable, the sustainability of the respective financial product. However, the intermediary is not responsible for their accuracy. At present, a consideration can only be made to a limited extent by the providers due to information that is building up, but which may still be rudimentary at present. Insurers who recognizably do not include a strategy for incorporating sustainability risks in their investment decisions are not included in the recommendations, depending on the customer's wishes.

Information on the remuneration policy when taking sustainability risks into account (Art. 5 TVO)

The remuneration for the brokerage of financial products is in principle not influenced by sustainability risks. Should it occur in the future that providers remunerate the consideration of sustainability risks in investments at a higher rate, we will accept this as long as it does not contradict the client's interest. We already ensure on the basis of legal requirements within the framework of our remuneration policy that the performance and activities of our employees are not remunerated or evaluated in a way that conflicts with our duty to act in the best interests of the clients. In particular, remuneration does not incentivise staff to recommend an insurance or pension product that is less appropriate to the needs of clients. The remuneration we pay to our employees has no influence on the inclusion of sustainability risks.