1. Introduction

This document fulfils the disclosure requirements under Articles 3, 4 and 5 of Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability‐related disclosures in the financial services sector (“the SFDR”) for W&W Investment Managers DAC (“W&W Investment Managers” / “the Firm”) as a financial market participant and financial advisor within the meaning of the SFDR and articulates the Firm's approach to the consideration of sustainability risks in the context of the Firm's activities.

In accordance with Article 3 of the SFDR, financial market participants and financial advisors, including investment firms authorised to perform portfolio management and provide investment advice, such as the Firm, are required to publish information on their websites regarding their strategies for integrating sustainability risks in their investment decision-making processes and investment advisory activities.

Where they do not take into account adverse effects of investment decisions on sustainability factors, financial market participants shall provide clear reasons why they do not do so in accordance with Article 4(1) of the SFDR. Financial advisors shall publish information in accordance with Article 4(5) of the SFDR as to why they do not take into account adverse effects on sustainability factors in their investment advice. W&W Investment Managers does not take into account the adverse effects on sustainability factors, within the meaning of the SFDR, when providing investment advice and prepares a summary explanation for this.

Furthermore, in accordance with Article 5(1)1 of the SFDR, financial market participants and financial advisors, such as the Firm, shall include in their remuneration policies information on how those policies are consistent with the integration of sustainability risks and shall publish that information on their website.

As part of the process of integrating Environmental, Social, and Corporate Governance (“ESG”) risks into the investment-decision making process and complying with the requirements around transparency regarding the integration of sustainability risks, Article 6 of the SFDR requires financial market participants and financial advisors to include, in pre‐contractual disclosures to its clients, a description of the manner in which sustainability risks are integrated into their investment decision-making process and investment advisory activities. Where financial market participants and financial advisors deem sustainability risks not to be relevant, the rationale behind this conclusion shall be communicated to their clients. W&W Investment Managers shall comply with these requirements in its communications with its clients, to the extent relevant.

2. Company Background

W&W Investment Managers has been operating from Ireland for 30 years and was the second ever Firm into the IFSC, the initial hub of the funds industry within Ireland.

W&W Investment Managers is a wholly owned subsidiary of W&W Asset Management GmbH, which is one of Germany’s largest asset managers that manage €44bn of assets on behalf of its parent, Wüstenrot & Württembergische AG ("the W&W Group"). The W&W Group is one of Germany’s oldest and largest financial services and insurance groups, employing 13,000 people with headquarters in Stuttgart Germany and listed on the German stock exchange. The W&W Group came into existence in 1999 as a result of the merger of the two long-standing companies Wüstenrot and Württembergische. Today, the W&W Group develops and provides the four components of modern financial planning: financial security, housing property, risk protection and savings and investment.

3. Investment services and activities

W&W Investment Managers is authorised and regulated by the Central Bank of Ireland as an investment firm, under the European Union (Markets in Financial Instruments) Regulations 2017, to provide investment services, including, portfolio management and investment advisory services under Directive (EU) 2014/65 ("MiFID II") to both Undertakings for the Collective Investment in Transferable Securities (“UCITS“) and Alternative Investment Funds (“AIF“).

W&W Investment Managers also provides investment advisory services to LBBW Asset Management Investmentgesellschaft mbH (“LBBW”), a large German investment management firm with €73.2b of assets under management and a subsidiary of LandesbankBaden-Württembergand bank.

4. W&W Group Strategies for Sustainability and ESG

The W&W Group conducts its business in an environmentally compatible, socially responsible, and economically successful manner in consideration of the interests of current and future generations, for whom the W&W Group considers it is responsible. As financial planning specialist in the areas of financial coverage, residential property, risk protection and savings and investment, the W&W Group generates sustainable growth that retains value. Not only is this a core part of the W&W Group business strategy, but it has also been explicitly made binding in the sustainability policy of the W&W Group, to which the Firm is subject. These policies cover such areas as resource use and procurement, employees, products and services and compliance with legal requirements as elements of the concept of sustainability.

In May 2020, the W&W Group signed the UN Principles for Responsible Investment (“UNPRI“), thereby undertaking to incorporate ESG issues into its analysis and decision-making processes in the investment area. The UNPRI is an international organization that works to promote the incorporation of ESG factors into investment decision-making. Launched in April 2006, with support from the United Nations (UN), the UNPRI has over 3,000 participating financial institutions, as of January 2021. These institutions participate by becoming signatories to the UNPRI’s six key principles and then filing regular reports on their progress. The six key principles for responsible investment to which companies that sign up to the UNPRI must agree to commit themselves are:

  1. We will incorporate ESG issues into investment analysis and decision-making processes.
  2. We will be active owners and incorporate ESG issues into our ownership policies and practices.
  3. We will seek appropriate disclosure on ESG issues by the entities in which we invest.
  4. We will promote acceptance and implementation of the Principles within the investment industry.
  5. We will work together to enhance our effectiveness in implementing the Principles.
  6. We will each report on our activities and progress towards implementing the Principles.

In August 2020, the W&W Group signed the United Nations Principles for Sustainable Insurance (“UNPSI“) further embedding ESG in its insurance business. With its signature, the W&W Group expressed its intent to enhance the company's economic, ecological, and social responsibility and its commitment to the following four principles for sustainable insurance:

  1. We will embed in our decision-making ESG issues relevant to our insurance business.
  2. We will work together with our clients and business partners to raise awareness of environmental, social and governance issues, manage risk and develop solutions.
  3. We will work together with governments, regulators, and other key stakeholders to promote widespread action across society on environmental, social and governance issues.
  4. We will demonstrate accountability and transparency by regularly disclosing publicly our progress in implementing the Principles.

Please see the attached links for further information:

5. Strategies for Integration of Sustainability Risks

Sustainability risks

As per Article 2 of the SFDR, "sustainability risks" are events or conditions in the areas of environmental, social or corporate governance, the occurrence of which could actually or potentially have a material negative impact on the value of investments. Sustainability risks are often referred to as ESG risks (ESG: Environmental, Social, Governance).

Strategies for inclusion of sustainability risks in investment decision-making processes

In financial portfolio management, W&W Investment Managers does not have an independent strategy for integrating sustainability risks into investment decision-making processes. It implements sustainability risks in its investment decision-making processes in accordance with the specifications of the clients for whom it provides financial portfolio management services.

Since W&W Investment Managers currently provides financial portfolio management services for companies in the W&W Group, investment decision-making processes are always based on the W&W Group's Risk Policy. The W&W Group has an risk strategy both in Germany and its subsidiaries outside Germany that integrates ESG risks into all investment decisions taken by members of the W&W Group, including W&W Investment Managers.

With the "Leaflet on Dealing with Sustainability Risks" (last amended on 13 January 2020), the German regulator Federal Financial Supervisory Authority (BaFin) provides guidance on how to deal with sustainability risks. BaFin considers a strategic consideration of sustainability risks and a corresponding implementation in the companies it supervises to be necessary. In the W&W Group, sustainability risks were analysed in the light of this leaflet and a reference was made to the existing risk areas.

Sustainability risks are qualitatively determined within the framework of established processes. Due to the assignment to the already existing risk areas, they are not subject to independent quantification. The management of sustainability risks is done as part of the Firm's risk management framework and, where appropriate, risks are recorded and assessed in terms of their materiality. As part of the risk inventory, risks are quantified at the level of the existing risk areas in which the sustainability risks are integrated. Furthermore, the risk inventory determines the materiality of risks. Significant risks are actively managed in the risk management system, including any sustainability risks it may contain.

The limitation of sustainability risks in the area of capital investment is achieved by defining exclusion criteria for investments in certain economic activities related to coal, weapons, food and agricultural land, as well as in labour law controversies regarding child and forced labour.

The basis for the investment decision-making processes in the context of W&W Investment Managers' financial portfolio management for the respective companies of the W&W Group is the business strategy of the individual company in connection with its risk strategy. Here, the management of the respective company determines the risk content that it would like to take in the next financial year for the risk areas. The future investment portfolio is specified by means of an investment framework agreed with the respective client with regard to composition and diversification, either in the "Strategic Asset Allocation" or on the basis of an individually defined framework.

Strategies for inclusion of sustainability risks in investment advisory activities

The Firm has concluded contracts to advise the management of investment funds with LBBW Asset Management Investmentgesellschaft mbH (“LBBW”). These so-called advisory mandates constitute investment advice within the meaning of MiFID II.

As part of this investment advice, the Firm takes into account relevant risks that can potentially have a significant negative impact on the value of investments.

In investment advice, the same risk areas are considered as in financial portfolio management. Accordingly, sustainability risks are also linked to the existing risk areas and the risks are taken into account accordingly. In this regard, reference is made to the explanations on financial portfolio management (see above).

No consideration of adverse sustainability impacts

W&W Investment Managers does not currently independently take into account the adverse effects of its financial portfolio management and investment advisory activities on sustainability factors. Since W&W Investment Managers employs fewer than 500 people, there is no requirement for the Firm to develop an independent consideration of adverse sustainability impacts.

At this point, however, W&W Investment Managers explicitly states that this does not change its fundamental willingness to contribute to a more sustainable economy, in particular to reduce the risks and consequences of climate change and other ecological or social grievances.

The entire W&W Group has committed itself to taking sustainability aspects into account in its investments. W&W Investment Managers implements the specifications and aspects of sustainability specified by the companies of the W&W Group.

6. Shareholder Engagement

The Firm’s Shareholder Engagement Policy and annual required disclosures are published on its website.

7. Remuneration Policy

The Remuneration Policy, which includes information on how the Firm's remuneration framework is consistent with the integration of sustainability risks, is published on the W&W Investment Managers' website.

8. Code of Conduct

The employees of W&W Investment Managers are obliged to comply with the W&W Group Code of Conduct. This Code sets out the minimum standard for the Firm, which regulates the interaction of all members of the Firm (employees in the field and in the field, executives, members of the board) as well as in relation to customers, competitors, business partners, authorities, and our shareholders. This is not only about the practical implementation of existing laws and regulations, but also about ethically sound behaviour in our daily work.

9. Oversight of the policy

The Head of Compliance bears responsibility for the implementation, oversight and ongoing monitoring of the Policy. The Policy will also be subject to approval by the Board of the Firm.

10. Review of and Updates to Policy

This Policy will be subject to review on at least an annual basis, or upon the occurrence of a change to applicable law or the Firm's investment strategy, to ensure that it continues to comply with the SFDR and all other relevant applicable laws.

The Board will also review and note the current version of the W&W Group ESG policy on an annual basis.

11. Access to policy

A copy of this Policy is available to clients of the Firm and its employees and Board on the Firm's website (accessible via the following link: Sustainable Finance Disclosure | W&W Investment Managers (ww-im.com)). The Firm will ensure that all information contained in this Policy, as published, is maintained accurate and up to date.

Date of adoption: 15.06.2022

Last reviewed: 15.06.2022