Disclosure requirements with regard to ESG (Environment–Social–Governance)

Findos Investor GmbH (LEI: 529900KTZLVBTB31NB44) provides the following information in accordance with the Sustainable Finance Disclosure Regulation (EU2019/2088):


Consideration of sustainability risks1 (Art. 3)

In view of the high standards of ethical conduct and integrity that our investors apply in the context of their own business activities, it is our clear understanding that comparable standards need to shape the investment principles at Findos Investor GmbH. In addition to the economic aspects of an investment decision, it is our obligation and established practice to include considerations about the environment, social aspects and corporate governance.

As part of the investment process, Findos Investor GmbH considers sector exclusions and carries out an ESG risk classification based on the region and industry, which is reviewed as part of the due diligence for the specific company.

Identified sustainability risks are addressed and clearly speak against a potential investment. We do not engage in investments that are in conflict with our standards.


Consideration of adverse sustainability impacts2 (Art. 4)

We acknowledge that our investments impact the environment and social matters due to their participation in the economic system.

Based on our findings in the investment process, ESG goals are defined as part of the strategy for the holding period and reviewed annually in the ESG reporting. In addition, Findos Investor GmbH, a signatory of the UN PRI, adheres to the United Nations Principles of Responsible Investment. The funds and the investments must of course comply with all applicable laws and regulations, as well as all generally accepted rules and standards applicable in the respective business area. The principles of diversity and inclusion (DEI – Diversity, Equity and Inclusion) continue to be promoted by us in our daily business.


The fund focuses on maintaining, developing and improving the competitive positioning as well as the sustainable long-term earnings situation of the investments in their relevant markets. The funds do not invest with the aim of simplifying, dissolving or breaking-up corporate structures.

However, Findos Investor GmbH, its advised funds and their underlying investments do not currently take the EU criteria for environmentally sustainable economic activities, i.e. no principle adverse impacts into account, as the data basis does not yet meet the regulatory requirements. By implementing the annual reporting at the investment level, Findos Investor GmbH is working on gathering the corresponding data basis. How Findos Investor GmbH considers adverse sustainability impacts and discloses the respective information is therefore reviewed annually.


Consideration of sustainability risks in the remuneration policy (Art. 5)

Findos Investor GmbH takes sustainability risks into account in its remuneration policy to the extent that no incentives are created to take sustainability risks. The employees’ management of sustainability risks is implicitly considered in the performance assessment, however, it is not assessed separately.


1 | A sustainability risk is an environmental, social or governance condition or event whose materialisation could potentially have a negative impact on the value of an investment.

2 | Adverse sustainability impacts are the investment’s effect on the environmental and social environment. Compared to sustainability risk, it is an outward-looking risk approach.


Published: 01.03.2021 | Updated: 17.02.2022