No consideration of adverse impacts of investment decisions on sustainability factors

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Howaldt & Co. Investmentaktiengesellschaft TGV does not consider any adverse impacts of its investment decisions on sustainability factors.

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The Sub-Fund (Teilgesellschaftsvermögen) Wertanlagen is not a financial product in accordance with Art. 8 or 9 of the Directive (EU) 2019/2088.

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Reason: In the opinion of Howaldt & Co., the sustainability criteria specified by the legislator in the so-called taxonomy regulation (EU) 2020/852 cannot be objectively and consistently verified as long as they are not reported by the portfolio companies and audited there on the basis of uniformely applicable standards.

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TGV Wertanlagen also invests globally and cannot fall back on corresponding, consistently applied criteria for companies outside the European Union. A statement on the percentage of proven "sustainable" investments would, therefore, not be possible at the moment.

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As a small shareholder in its investments, TGV Wertanlagen does not have the opportunity to exert any significant influence on the corporate management of the associated companies, nor on their interpretation or application of the aspects specified in the taxonomy regulation (EU) 2020/852.

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Howaldt & Co. is focused on identifying and including investments that should be able to maintain their value and/or business development successfully over a period of at least 5 years and have the prospect of continuing to do business successfully beyond this period. This presupposes that Howaldt & Co. assumes, based on its research, that environmental and social problems in these companies do not pose risks with a particularly high probability of occurrence or significance in a company context or in the context of TGV Wertanlagen’s overall portfolio.

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Howaldt & Co. does not yet intend to consider adverse impacts of its investment decisions on sustainability factors.