Sustainable Finance

As an insurance broker and advisor in insurance matters, we are, within the scope of brokering insurance investment products within the meaning of Art. 2 (17) of DIRECTIVE (EU) 2016/97 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 20 January 2016 on insurance distribution (hereinafter IDD), a financial advisor pursuant to Art. 2 (11) within the meaning of Art. 2 (12) of REGULATION (EU) 2019/2088 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 November 2019 on sustainability-related disclosure requirements (hereinafter referred to as the Disclosure Regulation).

1) Consideration of sustainability risks in accordance with Art 3 (2) Disclosure Regulation

As we are particularly committed to fulfilling our environmental and social responsibilities, our group of companies has decided to take sustainability risks into account when selecting and advising on financial products in accordance with Art. 3 (2) Disclosure Regulation. Insurance investment products are selected on the basis of a price/performance comparison, taking into account the sustainability risk of the products within the meaning of Article 2(22) of the Disclosure Regulation. In order to be able to take sustainability risks into account in our advice, we require relevant information from the product manufacturers (insurance companies within the meaning of Article 2(2) of the Disclosure Regulation). If the insurance investment product does not take into account sustainability risks in accordance with Article 6(1) of the Disclosure Regulation, we will expressly point this out.

2) Consideration of the adverse impact of investment decisions on sustainability factors in accordance with Article 4 (5) of the Disclosure Regulation

In addition, we also take into account the adverse impact of investment decisions on sustainability factors in our insurance advisory activities. The product manufacturers disclose to us whether and how the insurance investment products they manufacture take into account the adverse effects of investment decisions on sustainability factors (Article 4(1)(a) of the Disclosure Regulation) or whether and why these effects are not taken into account (Article 4(1)(b) of the Disclosure Regulation). We will expressly point this out when brokering insurance investment products.

3) Impact on our insurance advisory activities

Due to our commercial law status as an insurance broker and advisor in insurance matters and the resulting legal obligation to take into account the wishes and needs of our clients when brokering insurance investment products, we will in future broker insurance investment products in accordance with Articles 6, 8 and 9 of the Disclosure Regulation.
If an insurance investment product is not adequately classified by the product manufacturer, we will expressly point this out to the client.

4) Consideration of sustainability risks in connection with our remuneration policy pursuant to Section 5 of the Disclosure Regulation

In the course of our activities as an insurance broker, we receive remuneration directly from the insurer for the successful brokerage of insurance investment products. This remuneration is commission in accordance with Section 30 of the German Brokerage Act (Maklergesetz), in the form of conclusion/follow-up/support/turnover/portfolio/participation commissions or bonuses. We ensure that our remuneration structure does not encourage excessive risk-taking in relation to sustainability risks. In particular, we take precautions to ensure that neither the remuneration nor any other factors create incentives for us or our employees to recommend a particular insurance investment product to a customer when another product would better meet the customer’s needs. Our internal compliance management ensures that neither we nor our employees are remunerated in a manner that conflicts with our duty to act in the best interests of our customers.