Sustainability-related disclosures of Yellowfin Asset Management GmbH

Transparency in sustainability risk management strategies (Article 3 EU Disclosure Regulation¹)

At Yellowfin Asset Management, we successively identify actual or potential sustainability risks as part of our valuation of securities. These are environmental, social or governance events or conditions that can actually or potentially have a significant negative impact on a company’s financial position, results of operations and reputation.

Among other economic opportunities and risks, we include these sustainability risks in our investment decision-making processes. By taking sustainability risks into account, we can minimise the resulting losses in the investment. This can lead to a better odds-risk ratio.

As part of our portfolio allocation, we attach great importance to diversified investment. Like other company-specific risks, sustainability risks can be significantly reduced through broad diversification.

Expected impact of sustainability risks on the return of financial products

Sustainability risks can lead to both a short-term loss in value and have a long-term impact on the value of an investment. A short-term loss in value can be triggered, for example, by sudden and unexpected environmental damage. A long-term loss in value can occur, for example, if a company does not make a fundamental reorientation or adaptation of its business model in time due to sustainability aspects. In addition, measures to avoid sustainability risks can also involve costs and have an adverse impact on returns. 
 

Statement on the consideration of principal adverse impacts on sustainability factors (Art. 4 EU Disclosure Regulation)

Yellowfin Asset Management GmbH does not currently take into account adverse impacts of investment decisions on sustainability factors. 
Adverse sustainability impacts can occur in all areas of ESG consideration. As part of our analysis of equities and bonds, we identify adverse sustainability impacts and take them into account if they are economically relevant.
As the impact of environmental and social factors as well as sustainable governance varies from industry to industry, they are weighted according to relevance. The weighting is based on the sector logic of MSCI ESG Research. For example, CO2 emissions in manufacturing industries are higher than in financial institutions.
Sustainability impacts are taken into account on the basis of the defined exclusion criteria, but cannot currently be comprehensively determined for all sustainability indicators for adverse impacts. For this purpose, the relevant data necessary for determining and weighting the adverse sustainability impacts is not yet available in the market in full, in sufficient scope and in the required quality. Yellowfin will regularly review the data situation and, on this basis, re-decide, if necessary, on the possibility of taking into account key adverse impacts of investment decisions on sustainability factors as part of internal strategies.
 

Exclusion criteria for all portfolios of Yellowfin Asset Management GmbH

We apply the following exclusions for equities and bonds to all asset management portfolios. All exclusion criteria are checked using ESG data from the rating agency MSCI ESG Research. Excluded from the exclusions are passive/passive-enhanced mandates for which the investor explicitly wishes for professional tracking error management in the equities and bonds sector.

Company

MSCI ESG rating < B (scale: CCC to AAA, where AAA is the best rating).

We apply exclusion criteria to companies for controversial business areas and business practices.
 

Controversial business areas

The following limits were chosen because otherwise companies would be excluded due to the smallest shares of turnover (e.g. online mail order retailers or streaming services with pornographic films on offer).

Countries

For countries (sovereign issuers), we apply environmental, social and governance exclusion criteria. MSCI ESG rating < B (scale: CCC to AAA, where AAA is the best rating)

investment funds

As no day-to-day information on a Fund’s holdings is available, there is a separate valuation process based on the Fund Companies’ disclosures under the Disclosure Regulation.

Generally for all financial instruments

We refrain from using financial instruments that make direct or indirect investments (e.g. derivatives) in basic foodstuffs such as wheat, corn and soy.
 

Transparency in the remuneration policy in connection with the consideration of sustainability risks (Art. 5 EU Disclosure Regulation)

Yellowfin Asset Management GmbH’s remuneration system consists of a remuneration model that meets both general and specific regulatory requirements. In this context, Yellowfin ensures that both the remuneration model derived from the remuneration system and the remuneration parameters as well as the components of the remuneration are sustainable, i.e. that they are geared towards the long-term success of the company and are designed transparently. This takes into account that the remuneration-related objectives of the employees are sufficiently ambitious and can make an effective and sustainable contribution to the achievement of the company’s objectives. In addition, no incentives are set to take disproportionately high risks that are incompatible with the risk profile or portfolio allocation.

Yellowfin’s remuneration system is in line with the inclusion of sustainability risks. The determination of variable remuneration is determined both by the achievement of quantitative targets and the achievement of qualitative targets defined at Commerzbank Group level. 

Among the qualitative objectives of the Commerzbank Group are: Environmental, social and governance (ESG) objectives. These include, for example, specific goals for sustainability, customer and employee satisfaction, demographic change, risk and reputation management, and compliance goals.

Date: 30.04.2026