ESG Policy

Regulation 2019/2088 on sustainability-related disclosures in the financial services sector requires financial market participants engaged in asset management, such as QCM, to publish on the website, in accordance with Articles 3 and 4 of this Regulation, information on their strategies in incorporating sustainability risks and in considering the main adverse impacts on sustainability factors in their investment decision-making processes.

Sustainability risks are environmental, social or governance events or conditions, the occurrence of which may have an actual or potential adverse impact on the value of investments. These sustainability risks are taken into account in all our business activities and receive constant attention.

Conditions from the areas of “environment, social and corporate governance (so-called ESG factors), respect for human rights and the fight against corruption and bribery” are regarded as “sustainability factors”.

We consider the most significant negative impacts on sustainability factors when performing financial services. To identify and weight the most significant sustainability impacts, QCM will consider issuers’ reporting of non-financial risks. In doing so, the Institute may also use third-party evaluation of the respective issuers.

With regard to the content, methods and presentation of sustainability indicators for adverse aspects, the institute will be guided by the publications of the relevant supervisory authorities.

QCM does not promote environmental or social features or any combination of these features with its financial products. Similarly, the financial portfolio management services we offer do not aim to be sustainable investments. Nevertheless, ESG criteria are an important issue for us in the context of this regulation, as sustainability risks can have a more or less negative impact on the return of an investment.

In this respect, we consider the United Nations-sponsored Principles for Responsible Investment (PRI), which were launched with the aim of developing principles for responsible securities management, to be a meaningful initiative that we follow. This means:

1. We will incorporate ESG issues into the analysis and decision-making processes in asset management and, where appropriate, investment advice.
2. We will be an active shareholder as part of our participation policy and consider ESG issues in our investment policies and practices.
3. As part of our engagement policy, we will encourage companies and entities in which we invest or recommend acquisition for our clients to provide appropriate disclosure on ESG issues.
4. We will drive acceptance and implementation of the Principles in the investment industry.
5. We will work together to increase our effectiveness in implementing the Principles.
6. We will report on our activities and progress in implementing the Principles as part of our reporting obligations.

With regard to the Principles for Responsible Corporate Governance, QCM will follow the recommendations of the German Corporate Governance Code applicable to listed companies to the greatest extent possible.

The Institute’s remuneration policy is consistent with the inclusion of sustainability risks. The principles of our remuneration policy ensure that QCM employees are remunerated in a manner that does not conflict with our duty to act in the best interests of customers. There are no incentives under our compensation policy to recommend, broker, or act on behalf of our clients in the management of financial instruments that are not consistent with the client’s investment strategy. Our compensation structure does not incentivize inappropriate risk-taking in investment or advisory activities for our clients.