Disclosure / Disclosure Policy

Information on the disclosure of the investment strategy to institutional investors

Pursuant to Art. 367k para. 1 PGR, asset managers must disclose annually to institutional investors1, with whom they have entered into an agreement pursuant to Art. 367i para. 2 PGR2, how their investment strategy and its implementation is consistent with this agreement and contributes to the medium- and long-term performance of the institutional investor’s assets.

This includes reporting on:

  1. the main medium- to long-term material risks associated with the investments;
  2. the composition of the portfolio, the portfolio turnover and the portfolio turnover costs;
  3. the use of voting advisors for the purposes of participation activities; and
  4. its policy on securities lending and how it is applied, if any, to carry out its participation activities, particularly at the time of the general meeting of the companies in which investments have been made.

Pursuant to Art. 367k para. 2 PGR, the above disclosure also includes information on whether and, if so, how the asset managers make investment decisions based on an assessment of the medium- to long-term development of the performance, including non-financial performance, of the company in which investments have been made, and whether and, if so, what conflicts of interest existed in connection with the participation activities and how they were dealt with.

Implementation at ONE Asset Management AG:

Medium- to long-term material main risks associated with the investments:

General market risks, market environment:

The risk of financial losses on investments lies primarily in the development of the current economic and market environment, and in particular in the fluctuations of the leading benchmark indices. These risks are taken into account through appropriate diversification. All investments and securities are continuously reviewed for suitability and appropriateness. A comprehensive investment report is also submitted to the customer annually as part of the reporting obligations. In the case of a reduction in value in steps of -10%, the loss threshold report required by law is also automatically generated, indicating the loss to the customer within each quarter.

External risks:

The risk of default or depreciation of an investment is always possible due to unforeseeable events such as environmental and natural disasters.

Country risks:

Political stability varies from country to country and region to region. Political instability or social disorder can lead to unexpected devaluations. This risk is mitigated by regional diversification.

Emittent risk, Liquidity risk:

The collapse of an issuer can mean a default of the investment. This risk is mitigated by broad allocation, investments in listed, liquid products and/or companies. This ensures flexibility and the ability to act in a timely manner.

Currency risks:

The risk of foreign currency losses due to an unfavorable development of exchange rates for the investor cannot be excluded. This risk is reduced by a strategy that focuses primarily on investments in reference currencies.

Other risks:

Loan borrowing or leverage is only undertaken at the direction of the customer and will not be recommended. This reduces the potential risk of loss.
Interest rate risks are reduced through appropriate asset allocation and associated diversification.
Settlement risks are met through solid counterparties and custodian banks as well as through compliance with MIFID regulations.

The Asset Allocation of the portfolio, the portfolio turnover and the portfolio turnover costs:

Please take note of the relevant MiFID – reports, which you usually receive on an annual basis.

Use of voting advisors for the purpose of participation activities:

No voting advisors are appointed.

Policy on securities lending:

No securities lending is done.

Information on whether and, if so, how investment managers make investment decisions based on an assessment of the company’s medium- to long-term performance, including non-financial performance:

The principle of the best execution approach is applied in the context of asset management. See also the Execution Policy of ONE Asset Management AG.

Investment decisions are made within the framework of asset management, based on the parameters defined with the client. For this purpose, the customer risk profile and the investment profile serve as a basis.

Monitoring is carried out within the framework of the annual reporting. In doing so, ONE Asset Management AG verifies compliance with the customer and investor profile agreed with the customer. The review can be carried out by the respective account manager, when using the standardized investment guidelines.

The compliance function monitors this process and has to be informed of any violations by the management.
The company also provides information on potential conflicts of interest in the current conflict of Interest Policy („Information in dealing with potential conflicts of interest“)

Conflicts of interest in connection with any participation activities:

The asset manager does not carry out any participation activities (see information on the currently participation policy at www.oneam.com).

This policy is a document issued by the management with the primary aim of presenting the underlying topic in a clear and comprehensible manner. It is intended to set out all the necessary principles, parameters and actions in respect to this issue.

1 According to Art. 367a item 2 PGR, an „institutional investor“ is: a) a company, which carries on life insurance activities within the meaning of Art. 2 item 3 and reinsurance activities within the meaning of Art. 13 item 7 of Directive 2009/138/ec5, insofar as these activities relate to life insurance obligations, and which is not excluded under the said Directive; b) an institution for occupational retirement provision within the meaning of Art. 2 of Directive (EU) 2016/23416.

2 Where an asset manager invests on behalf of an institutional investor, whether with discretionary powers under an individual client mandate or under a collective investment undertaking (…)
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