SFDR – Sustainable Finance Disclosure Regulation Disclosure Obligation

In line with the European Union’s understanding of sustainability, sustainability is not limited to environmental aspects but should encompass the full ESG spectrum – Environment, Social, and Governance. Reuss Private Access AG is subject to disclosure obligations under the Sustainable Finance Disclosure Regulation (SFDR), Articles 5 to 8 of the Taxonomy Regulation, and Delegated Regulation (EU) 2022/1288. In compliance with these obligations, we provide the following information:

Sustainability Strategy (Art. 3 SFDR)

Sustainability risks can have a direct impact on the value of investments by amplifying other relevant risks such as market risk, credit and counterparty risk, liquidity risk, legal risk, reputational risk, or operational risk. These risks can lead to significant deterioration in a company’s financial profile, profitability, or reputation, thereby substantially reducing its value. Disregarding sustainability factors in investment management can have negative effects on the environment (e.g. climate, water, biodiversity), on social concerns and employee interests, and may hinder the fight against corruption and bribery. Although certain sustainability principles inherently influence corporate governance and business strategy, Reuss Private Access AG explicitly declares that sustainability criteria are not taken into account within the scope of its business activities, to avoid legal disadvantages and in accordance with its strategic alignment.

The business model of Reuss Private Access AG is based on contractually agreed fixed remuneration for specific services relating to certain financial instruments. The company exclusively provides the reception and transmission of orders involving one or more financial instruments (investment brokerage) and, to a very limited extent, investment advice exclusively to investment funds. These services are provided solely to professional clients. „[…] This client group is presumed to "[...] have the necessary experience, knowledge, and expertise to make their own investment decisions and properly assess the risks involved.”

Performance-related remuneration based on investment decisions that take sustainability factors or risks into account has no influence on the company's success.

Considering the business strategy, taking sustainability criteria into account would neither be appropriate nor practical and would unnecessarily limit the range of products to which the company provides services.

Therefore, Reuss Private Access AG does not consider sustainability impacts as defined in Art. 4 para. 1(b) and para. 5(b) SFDR, and this is not planned under the current business strategy.

Sustainability Risks in Relation to the Remuneration Policy

The remuneration policy of Reuss Private Access AG aligns with the company’s philosophy, strategy, values, objectives, and long-term interests. The inclusion of sustainability risks has no impact on the structure or application of the remuneration policy.

The policy is designed to avoid incentives for excessive risk-taking. Employees are compensated solely through their fixed salary as defined in their employment contracts. The payment of variable remuneration in the form of bonuses is not envisaged. Likewise, there are no plans for employees to receive variable or additional compensation for achieving specific targets (e.g. sales goals). If performance-related remuneration were to be introduced for certain employees in the future, the employee’s role would be evaluated on a case-by-case basis (in particular, whether and to what extent the individual performs control functions). In such cases, any performance criteria that trigger such remuneration would be designed with a long-term perspective. Furthermore, an appropriate balance between fixed and variable remuneration would be ensured, whereby the fixed component must always constitute the majority of the total compensation. 

Regardless of its strategic stance on sustainability criteria, the remuneration policy inherently supports the appropriate management of sustainability risks. It is designed to ensure that no incentives exist to take on excessive risk. The policy is structured in such a way that clients’ interests are always respected. There are also no incentives to engage in frequent buying and selling of financial instruments. The overall remuneration system is designed to avoid conflicts of interest, including those related to sustainability risks. The system is neutral with regard to sustainability – meaning it does not create incentives to either take on or avoid specific sustainability risks.

Transparency in the Consideration of Sustainability Risks (Pre-contractual Information and Disclosures):

Since the company’s business model does not involve an investment process, and neither the company nor its clients make direct investment decisions in connection with the services provided, and since the company does not conduct performance assessments of financial products or their return potential, sustainability aspects are not taken into account either pre-contractually or beyond. In view of the aforementioned professional client base, it can be assumed that such clients are capable of adequately assessing any related risks.

The company does not provide insurance advisory services. In individual cases, it may provide investment advice – however, this is exclusively directed at investment funds or external financial portfolio managers. These entities must be able to assess potential sustainability risks on their own, based on their investment policies, risk management measures, and the professional expertise of their portfolio management. Moreover, in such cases, sustainability criteria are not the focus of the advisory activity. Upon request, the company is happy to provide clients with additional details regarding sustainability and the disclosures outlined above.

Transparency Regarding Adverse Sustainability Impacts at Financial Product Level:

The company does not issue financial products and does not offer portfolio management or client advisory services in the context of discretionary asset management. Furthermore, the financial products covered by the company's services are generally not authorised for retail clients, and are only approved for distribution in specific markets. Disclosing how these products promote environmental or social characteristics (if applicable), how they meet these characteristics, and whether or how they reference an index would conflict with the core distribution principles under MiFID II. Therefore, Reuss Private Access AG refrains from providing such disclosures, in order to avoid potential legal disadvantages related to regulatory distribution rules for specific financial products not approved for public offering.

In general, it should be noted that sustainability components of a financial product are not of material relevance to either the company or its clients in the context of service provision. Information in accordance with Articles 8 and 9 SFDR relating to specific financial instruments can be obtained by professional clients at any time from the relevant prospectus or issuer information. These clients are also capable of determining whether a financial product falls under the scope of Articles 8 or 9 SFDR.

Accordingly, Reuss Private Access AG does not take into account adverse impacts of investment decisions on sustainability factors (Articles 4 SFDR and Articles 12 and 13 of Delegated Regulation (EU) 2022/1288).

The above information is kept up to date in accordance with Article 12 SFDR.

 As of November 2024

Disclaimer: This English version is a non-binding translation of the original German text. It is provided for convenience only. In the event of any discrepancies or legal interpretation, only the German version shall be legally binding and authoritative.