Exclusion criteria have been defined for the fund in order to rule out from the outset companies and states that are active in certain controversial business areas or commit violations of recognised standards. 

Exclusion criteria for companies: 
 

• Genetically modified plants and animals (sales > 5 %)
• Production of outlawed weapons (i.e. cluster bombs, landmines, biological and chemical weapons and incendiary weapons using white phosphorus) and nuclear weapons and their strategic components such as enriched uranium
• Production or distribution of conventional weapons (systems) (sales > 5 %) 
• Production of thermal coal (sales > 5 %) and its conversion into electricity (sales > 15 %)
• Serious violation of the ten principles of the UN Global Compact
• Oil and gas production using unconventional methods: Extraction of oil sands and fracking (sales > 5 %)
• Operation of nuclear power plants, products and services for nuclear power plants, extraction of uranium (sales > 5 %)
• Tobacco (sales > 5 %)
• Pornography and pornographic entertainment services (sales > 5 %)

Exclusion criteria for states:

• Countries with a sustainability rating of CCC according to MSCI ESG Research
• Not a signatory of the Paris Climate Agreement
• Non-free states according to Freedom House ("Not free" )  

Exclusion criteria for financial instruments:
 

• Agricultural commodities 

The fund management takes into account the most important indicators of adverse impact for each investment decision. These are used to examine possible negative effects of an investment decision on important ESG issues. 

14 key indicators of adverse impacts have been defined for companies and two for countries. These cover the following areas:

• Greenhouse gas emissions,  
• Biodiversity,  
• Water,  
• Waste and
• Social issues / Employee concerns. 

As part of the consideration, the fund manager regularly and for each investment decision checks whether the company or the issuer of the security has a negative impact on important environmental, social or corporate governance issues. If this is the case, the fund manager either does not acquire the security or actively tries to influence the issuer or the company, depending on the severity of the negative impact. The aim is to reduce the negative impact of an investment on the environment and society.

Information on the main adverse impacts on sustainability factors is available in the fund's annual report.

¹_{For more details see ESG Target market data Link}

Sustainability Disclosure

pursuant to Art. 10 of Regulation (EU) 2019/2088

ERGO Vermögensmanagement Robust | ISIN: DE000A2ARYR2

The ERGO Vermögensmanagement Robust is an actively managed mixed fund with a sustainability concept. It invests globally in a variety of asset classes such as equities and bonds, and through indirect investments in real estate, precious metals and commodities. It can acquire equities up to a value of 50% of the fund's net asset value, and bonds up to 100%. Equities normally account for up to 30% of the fund's holdings. When selecting securities for investment, the fund management checks whether the issuer operates sustainably. Issuers can be companies as well as states. Thus, in addition to the issuer's financial success, ecological, social and good corporate governance aspects of the issuer are taken into account (ESG criteria) when considering the merits of an acquisition for the fund. Among the aspects investigated are, for instance, how the issuer is active with regard to environmental and climate protection, human rights, health and safety, reporting and combating bribery and corruption.

The ERGO Vermögensmanagement Robust is a product in accordance with Article 8 of the Disclosure Regulation (Regulation (EU) 2019/2088). This fund promotes environmental and/or social features and, although it does not specifically seek to make sustainable investments as provided for by the Disclosure Regulation, it does have a minimum share of 8% of sustainable investments.

Environmental and/or social features of the financial product

The fund promotes itself with the following environmental and/or social characteristics:

• Ruling out investments in companies and countries in accordance with the fund's exclusion policy
• Considering an investment's material negative impacts on sustainability factors when making investment decisions
• Holding at least the minimum share of sustainable investments in accordance with the Disclosure Regulation

No reference value has been determined for assessing whether the fund achieves the environmental and/or social objectives it advertises.

Methods used to assess, measure and monitor the environmental and/or social features, relevant sustainability indicators and criteria for the valuation of the underlying assets.

The fund's investment strategy ensures that it provides the environmental and/or social product characteristics aspired to. The compulsory elements of the investment strategy ensure that in particular direct investments, i.e. equities and bonds, align with the advertised environmental and/or social characteristics. See the annex to the sales prospectus at Link in the Mandatory Publications section, for details on the sustainability strategy ("Sustainability strategy of the fund").

The mandatory elements of the investment strategy are:

Exclusion criteria for companies and states

The fund uses exclusion criteria ("negative screening" strategy) in implementing its ESG concept. These exclusion criteria rule out investments in companies and countries that are active in certain controversial business areas or that violate recognised standards. The exclusion criteria are checked before and during the investment phase, using various indicators from the external data provider MSCI ESG Research. The exclusion criteria do not encompass securities for which no data is available, target funds, derivatives or bank deposits.

Considering material adverse impacts on sustainability factors when making investment decisions

Furthermore, the investment strategy takes into account the main adverse impacts of investment decisions on sustainability factors in accordance with Annex I, Table 1 of the final draft of the regulatory technical standards of the Disclosure Regulation published in April 2022. The analysis is performed using data from the external provider MSCI ESG Research. This mandatory element does not encompass securities for which no relevant ESG data is available, target funds, derivatives or bank deposits.

Holding at least the minimum share of sustainable investments pursuant to the Disclosure Regulation

The fund also undertakes to hold a minimum share of 8% sustainable investments in accordance with the Disclosure Regulation. For the fund, a company's economic activity is sustainable for investment purposes if its products and/or services make a positive contribution to at least one of the 17 United Nations Sustainable Development Goals (SDGs). The analysis is carried out using data from the external providers MSCI ESG Research and ISS ESG. This mandatory element does not encompass securities and target funds for which no SDG data is available, or derivatives and bank deposits.

The degree to which the product features specified in the section "Environmental and/or social characteristics of the financial product" are met or not is measured using sustainability indicators. The sustainability indicators are continuously observed and measured during a financial year. The results of the analysis are made available to the fund management on a regular basis so that, if necessary, appropriate changes can be made to improve the results in the portfolio. At the end of the financial year, the result for each sustainability indicator is published in the annual report.

The responsible department monitors both the legal and regulatory limits and the sustainability-related exclusion criteria resulting from the pre-contractual documents on a daily basis (the sales prospectus and the fund's investment rules can be found at Link, Mandatory Publications section). The specifications are applied in the company's trading system and used by the portfolio management for ex-ante verification. Thus, any trade that would/could cause a limit violation is blocked. If a transaction is refused, the predefined chain of action is applied: Portfolio Management and Limit Management come together and discuss the situation, and initiate appropriate measures.

All contractual and statutory fund limits are thus continuously monitored and communicated in the event of a breach (active/passive) in accordance with the escalation model.

The process described above ensures that only securities are held in the portfolio that are classified as investable according to the sustainability criteria defined for the fund. If a security no longer meets the specified criteria and is no longer considered sufficiently sustainable, the fund manager is obliged to sell the security within a reasonable period of time or, where there is a quota of sustainable investments, to meet the mandatory minimum share again.

At regular product meetings, the ecological/social characteristics and the investment strategy of the fund are reviewed, among other things. As a rule, the Portfolio Management department, the ESG specialist team and Product Management Mutual Funds are involved in this analysis. In addition, developments on the market relating to sustainability and sustainable investment products are continuously observed, and where necessary the fund's sustainable investment strategy is further developed.

The fund is also audited annually by the fund's auditor.

Data sources used

The integration of ESG analyses into the investment process requires in-depth research and appropriate training of the fund managers. For this reason, the portfolio management uses in particular the ESG analyses conducted by the external providers MSCI ESG Research and ISS ESG to evaluate issuers from a sustainability standpoint.

MSCI ESG Research is an established provider of environmental, social and corporate governance analyses and ratings. With more than 200 sustainability analysts it screens over 14,000 issuers, including companies and countries, as to their sustainability. Sources of information include corporate reporting (annual reports, sustainability reports) and a variety of external sources (global and local media, government reports, reports by non-governmental organisations). MEAG uses information from the MSCI ESG Rating and MSCI ESG Fund Rating databases.

ISS ESG has internationally recognised expertise in all areas of sustainable and responsible investment. This includes topics such as climate change, UN SDGs, biodiversity, human rights, labour standards, corruption, controversial weapons and much more. With over 500 employees, ISS ESG has more than 25 years of experience and expertise in ESG research and ESG rating. MEAG uses in particular ISS ESG data from the ISS ESG SDG Solutions Assessment (SDGA) to determine its ratio of sustainable investments.