As an asset manager, we are required to provide our clients with certain information on sustainability topics in accordance with Regulation (EU) 2019/2088 on sustainability‐related disclosures in the financial services sector (SFDR).

How Inyova incorporates sustainability risks into investment decisions (Articles 3 and 6 SFDR).

Sustainability risks, as defined by SFDR, environmental, social, or governance events or conditions that, if they occur, could cause an actual or a potential material negative impact on the value of the investment. Environmental conditions, social upheavals, or poor corporate governance can have a negative impact on the value of customers’ investments in portfolios managed on their behalf by Inyova in several ways. They can have a direct impact on the financial position, financial performance and cash flow, as well as on the reputation of the investments. Since such sustainability risks cannot be completely ruled out, we have developed specific strategies for our product to identify and limit sustainability risks.To limit sustainability risks in the product we manage for our investors, we try to identify and, if possible, exclude investments in those companies or bonds that have an increased risk potential. With specific exclusion criteria, we see ourselves in a position to align investment decisions with environmental, social or governance values. For this purpose, we generally use methods recognised in the market. Companies are only included in the Inyova universe and available for investment if they meet our exclusion criteria (no or very low sales of weapons, nuclear power, coal, uranium, oil sands, tobacco or no relevant violations of the UN Global Compact). For many of the stocks in the Inyova universe, we also obtain an ESG rating from a recognised rating agency and check whether this is above average. Regarding the bonds within the Inyova universe, we invest via investment funds whose investment policy uses a suitable and recognised sustainability filter to reduce sustainability risks. 

We expect that the remaining sustainability risks will have only a minor adverse impact on the return of the products and will not deviate significantly from the general market risk. However, sustainability risks that are not yet apparent to us may have a significantly greater impact on returns.

How Inyova considers adverse impacts of investment decisions on sustainability factors (Articles 4 SFDR).

Investment decisions may have adverse impacts on the environment (e.g. climate, water, biodiversity), on social and labour concerns, and may also be detrimental to the fight against corruption and bribery. Consideration of such adverse impacts under the SFDR requires a formalised process based on certain data. Due to our size, we are free to decide whether to implement this process under the SFDR. 

Inyova assesses adverse impacts when including companies in the Inyova universe and as part of the ongoing monitoring of all companies in the Inyova universe. This screening and monitoring includes exclusion criteria as well as performance in the environmental or social topic areas and the overall ESG performance score. In our view, the application of the standardised indicators for adverse impacts in accordance with the Disclosure Regulation does not represent any additional added value, which is why we have decided not to implement this process at present. Inyova therefore does not currently consider adverse impacts of investment decisions on sustainability factors in accordance with the Disclosure Regulation. This applies to all our investment decisions and relates both to Inyova’s business as a whole and to the individual Inyova Invests products that we manage for investors.

If investors choose the product to include certain footprint issues or individual exclusion criteria (as described in our whitepaper), this may result in the reduction of adverse impacts in the selected topic areas for their product. In addition, Inyova will continually assess whether the process required by the SFDR can be implemented at a later date.

How Inyova’s remuneration policy is consistent with the integration of sustainability risks in investment decisions (Article 5 SFDR).

Inyova’s policies for the integration of sustainability risks into investment decisions are also incorporated into the company’s internal organisational guidelines. Adherence to these policies is instrumental in evaluating the job performance of our employees. Our compensation policy does not incentivise employees to take sustainability risks, as our compensation system does not include any performance-related variable components.  In this respect, the compensation policy is consistent with the strategies for the integration of sustainability risks.

What information does Inyova provide for the products promoting environmental or social characteristics under the Disclosure Regulation (Article 10 Disclosure Regulation)

Pre-contractual disclosure for the products (according to Art. 8 SFDR)

Website disclosure under article 10 OF SFDR for the products

The information pursuant to Article 11 Disclosure Regulation shall be made available to investors within the framework of the quarterly reports



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