This is a convenience translation. The German version is legally binding. Deutsch

Sustainability-related transparency

Information as of: 20 August 2026

A. Entity-level disclosure

I. Our strategies for integrating sustainability risks (pursuant to Art. 3 OffenlegungsVO)

As a company, we wish to contribute to more sustainable, resource-efficient economic activity, with the aim in particular of reducing the risks and impacts of climate change. In addition to observing sustainability objectives in our own corporate organisation, we see it as our task to sensitise our clients, in the design of their business relationship with us, to aspects of sustainability.
Environmental conditions, social dislocation and/or poor corporate governance can in several respects have a negative impact on the value of our clients’ investments and assets. These so-called sustainability risks can have a direct impact on the assets, financial position and earnings as well as on the reputation of the investment objects. As such risks cannot ultimately be fully excluded, we have developed specific strategies for the financial services we offer in order to identify and limit sustainability risks.
To limit sustainability risks, we seek to identify and, as far as possible, exclude investments in companies that exhibit elevated risk potential. With specific exclusion criteria, we consider ourselves able to align investment decisions with environmental, social or governance-related values. To this end we draw on market-recognised assessment methods.
Identifying suitable investments can consist, first, in our investing in investment funds whose investment policy is equipped with a suitable and recognised sustainability filter to reduce sustainability risks. Identifying suitable investments to limit sustainability risks can also consist in our drawing on recognised rating agencies for product selection in discretionary portfolio management.

II. Our remuneration policy in connection with the consideration of sustainability risks (pursuant to Art. 5 OffenlegungsVO)

Our company’s strategies for integrating sustainability risks also feed into the internal organisational guidelines. Observance of these guidelines is material to the assessment of our employees’ work performance and thus likewise influences future salary development. In this respect, remuneration policy is aligned with our strategies for integrating sustainability risks.

III. Statement on the principal adverse impacts of investment decisions on sustainability factors (pursuant to Art. 4 OffenlegungsVO)

a. Summary

ZUWAX Asset Management GmbH is a financial market participant within the meaning of Regulation (EU) 2019/2088 (OffenlegungsVO) insofar as it provides financial portfolio management, and a financial adviser insofar as it provides investment advice or investment brokerage. We consider the principal adverse impacts of investment decisions on sustainability factors (Art. 4 Abs. 1 Buchst. a OffenlegungsVO). Where the information from product providers is available to us, we also consider such impacts in investment advice and investment brokerage (Art. 4 Abs. 5 OffenlegungsVO).

Sustainability factors comprise environmental, social and employee matters, respect for human rights and the fight against corruption and bribery. Principal Adverse Impacts (PAI) are the principal adverse impacts of investment decisions on these factors.

This entity-level statement applies to the asset management of ZUWAX Asset Management GmbH. The product-level disclosure (including the statement that the investments underlying the investment strategies do not take into account the EU criteria for environmentally sustainable economic activities) follows in section B. The EU Taxonomy is a different regulatory framework from PAI consideration pursuant to Art. 4 OffenlegungsVO.

b. Description of the principal adverse impacts

We use the mandatory PAI indicators pursuant to Annex I Table 1 of Delegated Regulation (EU) 2022/1288, insofar as data are available for the instruments held. These include in particular greenhouse-gas emissions and CO₂ intensity, activities in fossil fuels, violations of the UN Global Compact principles and the OECD Guidelines, lack of processes to monitor compliance with these standards, the gender ratio in governing bodies, and involvement in controversial weapons.

Quantitative measurement is carried out annually on the basis of Morningstar raw data. Missing values are not estimated; where there are gaps we report a correspondingly low coverage ratio. A tabular quantification according to the binding template in Annex I will be published as soon as the annual data delivery reaches sufficient coverage. Until then, PAI are taken into account qualitatively via the strategies set out below.

c. Strategies for identification and weighting

To determine PAI we use exclusion criteria, best-in-class selection based on ESG ratings from recognised data providers (MSCI, LSEG, ISS ESG, Sustainalytics) and the annual Morningstar PAI delivery. Instruments that violate the principles of the UN Global Compact or exhibit an elevated controversy risk should not be held, or only on an exceptional basis. In the Global Future / Global Future+ investment strategy these criteria feed into fund selection. For arranged investment funds (including NXT ELTIFs) we rely on the PAI and sustainability disclosures of the capital management company and the portfolio managers.

The weighting is based on data availability, severity of the impact and the chosen investment strategy. Article 8 strategies (Global Future, Global Future+) are filtered more strictly than strategies that do not promote environmental or social characteristics (Global, Select, Income). A complete exclusion of all adverse impacts is not possible.

d. Engagement policy

Engagement and the exercise of voting rights are not part of the investment strategy of ZUWAX Asset Management GmbH. As a wealth manager we are not authorised to exercise voting rights or to issue instructions in that regard. A reduction of PAI via the exercise of voting rights at the level of the target companies therefore does not take place. Insofar as target funds have their own engagement policies, any effects arise from their disclosures.

e. Reference to internationally recognised standards

We are guided by the ten principles of the United Nations Global Compact (human rights, labour standards, environment, anti-corruption) and, where applicable, by the OECD Guidelines for Multinational Enterprises. A Paris-Aligned Benchmark as a binding reference value has not been designated.

f. Historical comparison

This is the first complete statement pursuant to Art. 4 OffenlegungsVO in this website version (as at 20 August 2026). A historical comparison of PAI indicators will be included once at least two annual data sets are available.

B. Product-related disclosure

As a wealth manager, ZUWAX Asset Management GmbH offers various investment strategies. The investments underlying the investment strategies do not take into account the EU criteria for environmentally sustainable economic activities.

The investment strategies ZUWAX Global Future and ZUWAX Global Future+ are classified as a financial product within the meaning of Art. 8 OffenlegungsVO. The following sustainability-related disclosure under section IV. therefore relates exclusively to our discretionary portfolio-management strategies ZUWAX Global Future and ZUWAX Global Future+ and not to the discretionary portfolio-management strategies ZUWAX Global, ZUWAX Global+, ZUWAX Select, ZUWAX Select+ and ZUWAX Income.

IV. Statement of the environmental and social characteristics (pursuant to Art. 10 OffenlegungsVO)

Sustainability-related disclosures on ZUWAX Global Future.

a. Summary

As a financial product within the meaning of Art. 8 OffenlegungsVO, the ZUWAX Global Future investment strategy promotes environmental and social characteristics by taking into account, when selecting the invested financial instruments, their methods for implementing sustainability features. Sustainability objectives (within the meaning of Art. 9 OffenlegungsVO) are not pursued with the investment strategy.

b. No sustainable investment objective

This financial product promotes environmental or social characteristics, but does not have as its objective sustainable investment.

c. Environmental or social characteristics of the financial product

The investment strategy is implemented via funds that are assessed and selected by our investment team on the basis of data from several independent providers (including MSCI, LSEG, ISS ESG). Fulfilment of the environmental or social characteristics of the investment strategy is not ensured solely by the classification of the invested funds pursuant to the OffenlegungsVO, but by an assessment of all positions contained in the fund.

The starting point of an investment decision in funds is the strategic asset allocation (“SAA”), which optimises the return-risk ratio for the individual investor profile in every portfolio. The SAA is constructed from indices (for example the MSCI USA Net Total Return Index for US equities) that cover a large part of the market capitalisation of their investment universe. In the course of product selection, funds are then chosen whose holdings, compared with the respective SAA index, achieve a markedly improved sustainability profile while at the same time minimising tracking error versus that index.

At fund level, this criterion is achieved through a combination of exclusion criteria and best-in-class security selection according to ESG criteria. To fulfil the environmental and social characteristics of the investment strategy, criteria have been defined that are applied to the portion of the portfolio that can be assessed according to ESG criteria. This comprises around 90 percent of the strategy and thus, across the board, the asset classes equities and bonds. Holdings in cash and gold, which together account for no more than 10 percent of the strategy, are classified as the portion of the portfolio that cannot be assessed according to ESG criteria. Gold cannot be meaningfully assessed from an ESG perspective, but fulfils an important function in the portfolio, as an allocation leads to a marked improvement in the return-risk profile. The precious metal is therefore taken into account to a limited extent in the asset allocation.

d. Investment strategy

ZUWAX Global Future is a passive, rules-based investment style that covers the asset classes equities and bonds as well as, to a limited extent, gold and the money market. The composition of the portfolio is based on efficient combinations of the various securities through which the individual return-risk profile is optimised. The investment style is offered in ten different risk classes, thereby matching the investor’s personal risk-bearing capacity and return expectation as closely as possible. After the initial investment of the volume according to the strategic asset allocation (SAA) in one of the ten risk classes, ongoing monitoring and steering of the assets is performed by a rebalancing algorithm that reviews the portfolio composition daily and resets the portfolio to the target allocation if defined thresholds are exceeded or undershot. The investment strategy is implemented via funds that are assessed and selected by our portfolio management on the basis of data from several independent providers (including LSEG Data & Analytics, ISS ESG, MSCI).

Our policy for assessing good governance practices of investee companies consists in implementing a combination of exclusion criteria and a best-in-class approach based on the assessments of recognised ESG data providers. Exclusion criteria aim to exclude companies that violate the principles of the United Nations Global Compact. The ten principles of the Global Compact comprise guidelines on human rights, labour rights, corruption and environmental breaches. Thus, companies shall respect the protection of international human rights and ensure that they are not complicit in human rights abuses. In a next step, the best-in-class approach ensures that the invested funds include companies that stand out through an above-average governance rating.

e. Allocation of investments

The share of sustainable investments is 0 percent.

The share of sustainability-related investments is around 95 percent. Sustainability-related investments means those that promote environmental and social characteristics or take into account adverse impacts on sustainability factors. For the promotion of environmentally and socially sustainable characteristics, portfolio management does not rely exclusively on the classification by fund providers pursuant to the OffenlegungsVO.

It can, however, be assumed that at least 80 percent of the invested volume is invested in funds that the providers have classified pursuant to Art. 8 or Art. 9 of the OffenlegungsVO. Overall, around 95 percent of the invested volume is invested taking sustainability characteristics into account. An exception is cash held for operational purposes, as well as a small share of precious metals that serve to optimise the return-risk profile. Both positions – liquidity and gold – together account for no more than 5 percent of the invested volume of this investment strategy.

An overview of the composition of all investment strategies can be found in our onboarding journey. The quarterly IVA certificates (audit reports of the Institut für Vermögensaufbau on the return-risk profile and the sustainability profile of the Global Future portfolios, trees rating 1–5) are provided on request at [email protected]. The methodology is described by IVA at https://institut-va.de/nachhaltigkeits-bewertung/. ZUWAX-specific reports are currently not deposited as standalone files on this website.

f. Monitoring of environmental or social characteristics

The share of sustainability-related investments in the ZUWAX Global Future investment style is reviewed, assessed and certified quarterly by IVA. On the basis of a consensus rating of several independent ESG rating providers (ISS ESG, Sustainalytics, LSEG Data & Analytics), IVA evaluates the funds used by the portfolio management of ZUWAX Asset Management GmbH on the basis of their respective actual investments (portfolio positions). IVA measures sustainability on a scale of 1 to 5 trees for each invested fund and then calculates at strategy level what percentage of the portfolio is invested in funds with 1, 2, 3, 4 or 5 trees. This breakdown as well as information on the rating providers can be found in the IVA certificates, which we provide on request at [email protected].

g. Methods for environmental or social characteristics

Compared with the non-sustainable broad market indices for global equities and global bonds (benchmarks), the funds included in the investment strategy exhibit a qualifying sustainability profile. To measure the sustainability profile, ratings from the data provider MSCI are used.

In addition, the Institut für Vermögensaufbau (IVA, https://www.institut-va.de) has been mandated as an independent body to measure the sustainability of the strategy. It is a bank-independent German company that promotes wealth building for private investors by providing independent financial-scientific services. The IVA assesses the portfolio on a quarterly basis. The certification reports (Conservative: risk classes 10, 20 and 30; Balanced: 40, 50 and 60; Return-oriented: 70, 80 and 90; Equity-based: Global Future 100) are available on request at [email protected].

Conservative: for Global Future portfolios in risk classes 10, 20 and 30.

Balanced: for Global Future portfolios in risk classes 40, 50 and 60.

Return-oriented: for Global Future portfolios of risk classes 70, 80 and 90.

Equity-based: for the pure equity portfolio Global Future 100.

An overview of the ESG assessment of all ZUWAX Global Future strategies is available on request at [email protected].

h. Data sources and data processing

The data used by ZUWAX Asset Management GmbH to measure and assess sustainability are obtained from MSCI and Morningstar as well as from the proprietary Sustainability Rating of our partner, LGT Bank (Switzerland) Ltd. The data used by IVA are obtained from the providers ISS ESG, LSEG Data & Analytics and Sustainalytics.

The data used by ZUWAX Asset Management GmbH are sense-checked, compared with previously collected data and regularly verified for currency. Raw data from Morningstar are collected annually, sense-checked and used for the “Statement on principal adverse impacts of investment decisions on sustainability factors (pursuant to Art. 4 OffenlegungsVO)”. Data are not estimated; where data are missing, a correspondingly low coverage ratio is stated.

i. Limitations regarding methods and data

The ESG assessments performed by us and our partners are not based on self-collected and interpreted data, but exclusively on the ratings of established ESG data providers. No guarantee can be given as to the accuracy and currency of the data.

Companies whose equities and bonds are included in funds in which ZUWAX Asset Management GmbH invests each have an ESG rating. ZUWAX Asset Management GmbH is not aware of any cases in which equities and bonds of individual companies were held permanently in any of the invested funds despite the absence of an ESG rating. We therefore do not consider the attainment of the environmental or social characteristics promoted by the financial product to be at risk.

The external certification reports of IVA are moreover prepared only for funds for which a consensus rating is available on the basis of the data of all providers used for this purpose.

j. Due diligence

For the ZUWAX Global Future investment strategy, only funds whose investments are aligned with the advertised environmental or social characteristics come into consideration. The exclusion criteria at portfolio level set a minimum standard that companies must meet in order to be investable for the portfolio. Regular internal controls ensure that the exclusion criteria are complied with.

Daily algorithm-based monitoring and, where needed, rules-based reallocation (rebalancing) also ensures that the share of individual asset classes in each client portfolio corresponds in the long term to the agreed investment guidelines. Algorithm-based rebalancing serves as ongoing internal control and ensures that the shares of sustainability-related investments described under “Share of the investment” are complied with.

To fulfil the duty of care in promoting environmentally and socially sustainable characteristics within the ZUWAX Global Future investment strategy, IVA has been mandated as an independent body to measure the ESG score on a quarterly basis. This external control regularly validates the ESG profile of the entire investment strategy on the basis of data from several independent rating providers.

k. Engagement policy

Any engagement is not part of the investment strategy. ZUWAX Asset Management GmbH as asset manager is not authorised to exercise voting rights or to issue instructions in this regard. The entity-level engagement policy is described under section III. letter d.

l. Reference benchmark

ZUWAX has not defined a separate reference value for the investment strategy against which the environmental or social characteristics promoted by the financial product are measured.

Sustainability-related disclosures on ZUWAX Global Future+.

a. Summary

As a financial product within the meaning of Art. 8 OffenlegungsVO, the ZUWAX Global Future+ investment strategy promotes environmental and social characteristics by taking into account, when selecting the invested financial instruments, their methods for implementing sustainability features. Sustainability objectives (within the meaning of Art. 9 OffenlegungsVO) are not pursued with the investment strategy.

b. No sustainable investment objective

This financial product promotes environmental or social characteristics, but does not have as its objective sustainable investment.

c. Environmental or social characteristics of the financial product

Global Future+ represents a further development of the Global Future investment strategy, in which the core portfolio of equity and bond funds as well as other daily-tradable securities is supplemented by an allocation in ELTIFs. Due to differing data coverage for investments in exchange-traded and non-exchange-traded assets, environmental and/or social characteristics are advertised to a differing extent in the two components of the investment strategy.

Promotion of characteristics for exchange-traded investments (equities, bonds, gold and liquidity)

The liquid part of the investment strategy is implemented via funds that are assessed and selected by our investment team on the basis of data from several independent providers (including MSCI, LSEG, ISS ESG). Fulfilment of the environmental or social characteristics of the investment strategy is not ensured solely by the classification of the invested funds pursuant to the OffenlegungsVO, but by an assessment of all positions contained in the fund.

The starting point of an investment decision in funds is SAA, which optimises the return-risk ratio for the individual investor profile in every portfolio. The SAA is constructed from indices (for example the MSCI USA Net Total Return Index for US equities) that cover a large part of the market capitalisation of their investment universe. In the course of product selection, funds are then chosen whose holdings, compared with the respective SAA index, achieve a markedly improved sustainability profile while at the same time minimising tracking error versus that index.

Promotion of characteristics for non-exchange-traded investments (ELTIFs)

The semi-liquid part of the investment strategy is implemented via ELTIFs. ELTIFs are long-term investment funds that enable investors to invest in companies that require long-term capital.

ZUWAX invests exclusively in funds that themselves are subject to Art. 8 of the Disclosure Regulation. In selecting ELTIFs, the investment team also ensures that ESG criteria are integrated into the investment process. This can be implemented through a policy on exclusion criteria and/or through an assessment of the managers of individual investments along ESG metrics such as scorecards. The promotion should relate to various environmental and social characteristics, including from the categories environment, social, employees, supply chains and governance.

d. Investment strategy

Global Future+ pursues a rules-based investment strategy. Investment is made in the asset classes equities, bonds and private markets as well as, where applicable, to a limited extent in gold and the money market. The composition of each portfolio is based on efficient combinations of the securities used, through which the return-risk ratio is optimised for the individual investor profile. The investment strategy is offered in nine different risk classes, thereby matching as closely as possible the personal risk-bearing capacity and return expectation of each investor. After the initial investment of the invested volume pursuant to the SAA in one of the nine risk classes, ongoing monitoring and management of the assets is carried out by a control model that regularly reviews the composition of each portfolio and brings it back to the target allocation if defined thresholds are exceeded or undershot.

Our policy for assessing good governance practices of investee companies consists in implementing a combination of exclusion criteria and a best-in-class approach based on the assessments of recognised ESG data providers. Exclusion criteria aim to exclude companies that violate the principles of the United Nations Global Compact. The ten principles of the Global Compact comprise guidelines on human rights, labour rights, corruption and environmental breaches. Accordingly, companies shall respect the protection of international human rights and ensure that they are not complicit in human rights abuses. In a next step, the best-in-class approach ensures that the invested funds include companies that stand out through an above-average governance rating.

e. Allocation of investments

The share of sustainable investments is 0 percent.

The planned minimum share of investments used to attain the promoted environmental and/or social characteristics is 75 percent of the investment assets.

The liquid part of the investment strategy fulfils the promoted characteristics to at least 90 percent. An exception is cash held for operational purposes, as well as a small allocation to gold, which serves to optimise the return-risk profile. Both positions – liquidity and gold – together account for no more than 10 percent of the investment volume of the liquid part of the investment strategy. Possible shifts due to market movements have already been taken into account here.

The semi-liquid part of the investment strategy fulfils the promoted characteristics to at least 60 percent. Due to market movements, the share of semi-liquid investments in total investment assets can rise to as much as 40 percent within the portfolios with the highest risk class. In such a case, more than 75 percent of the investment assets would still be aligned with environmental or social characteristics.

The remaining part of the portfolio comprises essentially cash and cash equivalents, gold and – in the case of the semi-liquid part of the investment assets – investments that were not made to attain the promoted environmental or social characteristics. This share may amount to at most 25 percent of the investment assets.

f. Monitoring of environmental or social characteristics

The share of sustainability-related investments of the ZUWAX Global Future+ investment strategy is regularly reviewed and assessed. Through exclusion criteria and ESG ratings of the invested instruments as well as a daily review of portfolio weights, compliance with the stated shares can be maintained.

g. Methods for environmental or social characteristics

h. Data sources and data processing

i. Limitations regarding methods and data

Companies whose equities and bonds are invested in indirectly via funds by ZUWAX Asset Management GmbH each have an ESG rating. ZUWAX Asset Management GmbH is not aware of any cases in which equities and bonds of individual companies were held permanently in any of the invested funds despite the absence of an ESG rating. We therefore do not consider the attainment of the environmental or social characteristics promoted by the financial product to be at risk.

j. Due diligence

For the ZUWAX Global Future+ investment strategy, funds whose investments are aligned with the advertised environmental or social characteristics come into consideration. The exclusion criteria at portfolio level set a minimum standard that companies must meet in order to be investable for the portfolio. Regular internal controls ensure that the exclusion criteria are complied with.

k. Engagement policy

Engagement is not part of the investment strategy. ZUWAX Asset Management GmbH, as a wealth manager, is not authorised to exercise voting rights or to issue instructions in that regard. The entity-level engagement policy is described under section III. letter d.

l. Reference benchmark

ZUWAX has not defined a separate reference value for the investment strategy against which the environmental or social characteristics promoted by the financial product are measured.