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Ecological & Social Responsibility

Veranwortung für Natur und Gesellschaft wahrnehmen


Responsibility Statement

Für die nächsten Generationen

Als Unternehmen tragen wir eine hohe Verantwortung für Natur und Gesellschaft. Es ist Teil unserer Philosophie, diese Verantwortung wahr zu nehmen und aktiv positive Beiträge zu leisten. Wir möchten die ökologischen und sozialen Lebensgrundlagen unserer Gesellschaft nicht nur erhalten sondern verbessern. Das schulden wir den kommenden Generationen.

  • Best Execution Policy
    Best Execution Policy (Asset Management) Date: February 28, 2022 Introduction This document, hereinafter referred to as the "Best Execution Policy," governs principles and procedures for the van Grunsteyn GmbH, Frankfurt am Main, hereinafter referred to as the "Asset Manager," to achieve the best possible result within the framework of portfolio management for professional clients, especially for funds for which the Asset Manager has assumed portfolio management. The Asset Manager can execute trading decisions through various means. In principle, executions can be achieved on various execution venues, i.e., on trading venues (regulated markets, multilateral trading systems, organized trading systems, or comparable third-country markets), OTC (over the counter) through systematic internalizers, other OTC market makers, or other liquidity providers, or through comparable facilities of a third country, collectively referred to as "Execution Venues." For the execution of orders related to the purchase or sale of financial instruments, hereinafter referred to as "Orders," the Asset Manager relies on Walter Ludwig GmbH Wertpapierhandelsbank, Frankfurt am Main, hereinafter referred to as the "Broker." In this context, the Broker provides financial commission business and fixed price business for the Asset Manager. The Asset Manager transmits orders to the Broker regarding the following classes of financial instruments: Stocks and stock certificates Debt securities Other instruments (spot foreign exchange transactions) To achieve the best possible execution of orders, the Asset Manager carefully selects and reviews the Broker. Selection Principles The selection of the Broker was made according to selection principles determined by the Asset Manager. In particular, it evaluated the following criteria: Brokerage commissions, crossing possibilities (evaluation of competitiveness) Access to Execution Venues, specialization in specific market segments or regions (evaluation of execution probability) Organizational structure, settlement capacities, financial and liquidity position (evaluation of settlement security) The above criteria are also subject to regular reviews, at least annually, after the establishment of the business relationship. Execution Principles The Broker has committed to the Asset Manager to implement the following execution principles to achieve the best possible execution of orders. The Asset Manager generally transmits orders to the Broker without specifying a particular Execution Venue. The Broker will select the Execution Venue where the best execution is expected to be achieved. This may include the Broker itself. To achieve the best possible execution of orders, the Broker must consider the following criteria: Execution price Execution costs Execution speed Execution probability Settlement security Execution volume Execution method All other aspects relevant to order execution, such as market liquidity and, if applicable, the counterparty's creditworthiness The relative importance of the above criteria is determined primarily by: The characteristics of the client, particularly their classification as a professional client The characteristics of the order The characteristics of the financial instrument that is the subject of the order The characteristics of the Execution Venues through which the order can be executed In the best possible execution of orders, customary price fluctuations for financial instruments and the Broker's ability to achieve consistently cost-effective, complete, and timely executions are also considered. The significance of these criteria may vary depending on the type of trading decision made by the Asset Manager, the objectives, investment policy, and specific risks of the respective fund, as set out in the prospectus or the terms and conditions, and the type of financial instruments to be acquired or disposed of. If executions take place OTC, market data commonly used to assess the price of the affected financial instrument or obtained from a comparison with similar financial instruments may be considered in the evaluation. The availability of suitable emergency safeguards is always checked as a qualitative factor. If an order can be executed on multiple Execution Venues, including the Broker, the Broker's commissions and execution costs at the relevant Execution Venues must be compared in the interest of achieving the best possible result. Note: An explicit instruction from the Asset Manager may prevent the Broker from fully or partially complying with the above execution principles. Monitoring of Compliance The Asset Manager monitors the effectiveness of the implementation of the execution principles by the Broker, particularly the execution quality, and addresses any deficiencies as necessary. The Asset Manager regularly assesses whether there have been material changes and, if necessary, also considers replacing the Broker or involving another financial commission agent to achieve the overarching goal of the best possible order execution. A material change in this context is a significant event with potential implications for criteria of best execution, such as execution price, execution costs, execution speed, execution probability, settlement security, execution volume, execution method, and all other aspects relevant to order execution, such as market liquidity and, if applicable, the counterparty's creditworthiness. Execution Quality Analysis The Asset Manager analyzes the execution quality achieved by the Broker for each class of financial instruments annually. This analysis takes into account not only the information on execution quality provided by the Broker in accordance with Delegated Regulation (EU) 2017/576 but also, in particular, the following criteria: Execution price Execution costs Execution speed Execution probability Settlement security The Asset Manager compiles the results, together with relevant information about the Asset Manager and its services and the Broker, in a report and publishes it on its website Review of Execution Principles The Asset Manager reviews this Best Execution Policy at least annually. A review also takes place whenever a material change occurs that potentially impairs the Asset Manager's ability to continue achieving the best possible order execution for its clients. A material change in this context is a significant event with potential implications for parameters of best execution, such as execution price, execution costs, execution speed, execution probability, settlement security, execution volume, execution method, and all other aspects relevant to order execution, such as market liquidity and, if applicable, the counterparty's creditworthiness.
  • Sustainability policy
    As of
  • Participation policy
    Engagement Policy (Asset Management) Date: March 1, 2022 Engagement Policy This chapter outlines the engagement policy of van Grunsteyn GmbH, Frankfurt am Main, hereinafter referred to as the "Asset Manager," in accordance with § 134b AktG. 1.1. Exercise of Shareholder Rights As part of asset management or fund management, the Asset Manager is authorized to subscribe to, purchase, sell, or exchange financial instruments within the agreed-upon investment strategy, exercise subscription rights, or otherwise dispose of or exercise rights related to them, and perform any other actions deemed appropriate in connection with the management of assets or funds. The Asset Manager generally does not exercise voting rights at shareholder meetings. However, the exercise of these rights by its clients or the responsible capital management company is not excluded. The Asset Manager does not monitor how or whether its clients or the responsible capital management company exercise voting rights at shareholder meetings. 1.2. Monitoring of Significant Issues As an active asset manager, the Asset Manager engages in the capital market based on well-founded investment decisions. Thorough analyses serve as the basis not only for investment decisions in portfolio companies to assess associated opportunities and risks but also for ongoing monitoring and analysis of significant matters related to portfolio companies. Analyses are typically based on qualitative and quantitative factors with the aim of ensuring the sustainable success of investments. Sustainable success in this context refers to avoiding losses and maximizing profits. 1.3. Exchange of Views The exchange of views with the bodies of portfolio companies, particularly the management board, can be an important source of information for analyses and investment decisions based on them. In addition to discussing the current market environment and the current challenges and opportunities of portfolio companies, discussions may also focus on publicly known future investment projects and potential expansions into other markets. During such exchanges, it is also possible to discuss the strategic orientation of the portfolio company. 1.4. Collaboration with Other Shareholders In general, collaboration with other shareholders does not take place. However, discussions with other investors regarding the exchange of publicly known information may occur. During such discussions, no agreements regarding the exercise of voting rights are made, and the investment behavior of the Asset Manager is not disclosed. 1.5. Handling of Conflicts of Interest The Asset Manager's handling of potential conflicts of interest is outlined in the "Customer and Investor Information on Handling Conflicts of Interest," which is available for download on the website Report on Implementation The Asset Manager provides an annual report on the implementation of the engagement policy. These reports are available for download on the website for a minimum of three years. The first report for the fiscal year 2022 will be published in 2023
  • Compensation policy
    Compensation Policy (Fund Management) As of March 17, 2022 This compensation policy applies to all employees and directors of van Grunsteyn GmbH. It is based on our commitment to being the preferred investment partner for investors and the preferred employer for employees. Adequate compensation plays an essential role in achieving these business strategic objectives. Attracting and retaining the most capable employees is a central component of our compensation strategy. The cornerstone of this strategy is the concept of performance-based compensation, taking into account market factors and societal values. The compensation policy is also a significant part of our risk management. Adequate risk management includes an appropriate, transparent, and sustainability-oriented compensation system. In particular, the compensation system must not provide incentives to take excessive risks. This applies especially to employees who have a significant impact on our risk profile (Risk Takers). The responsibility for the appropriate design of the compensation system lies with the management. The compensation system is a tool of corporate governance and is therefore aligned with the achievement of the objectives set out in our business and risk strategy. This includes our product-related sustainability strategy for handling sustainability risks and adverse impacts of investment decisions on sustainability factors. The compensation of employees and directors consists of a fixed monthly base salary and a variable compensation that are in a reasonable proportion to each other. Criteria for determining the amount of the fixed base salary include relevant work experience, qualifications, the importance of the role to be fulfilled within the company, and the general salary level. Variable compensation is a discretionary compensation element that allows us to reward employees for their performance and behavior in addition to their base salary. The amount of variable compensation depends on the company's success and individual performance. Individual performance evaluations for variable compensation occur annually and consider to what extent the individual performance goals were met by the employee. Individual performance goals are determined depending on the employee's specific field of work. This also includes compliance with internal organizational policies and legal and regulatory requirements. For asset managers, this includes our product-related sustainability strategy, within which sustainability risks in investment decision-making processes are to be considered. Variable compensations are paid out annually, and guaranteed variable compensations are not granted. As we strive to adjust compensation to evolving internal and external expectations, the compensation system is regularly reviewed and improved as needed. This compensation policy is also subject to regular review (at least annually) and is published at
  • Minor non-monetary contributions
    Status: March 14, 2022 If we receive a minor non-monetary benefit from a third party, we shall only accept and collect it in a legally permissible manner if it is in particular justifiable, proportionate and suitable for improving the quality of the services provided to our customers without this conflicting with our acting in the best interests of the customer. The same applies if we grant such a minor non-monetary benefit to a third party. Minor non-monetary benefits may include in particular Product or service information or documentation Advertising materials for new issues, products Participation in training events, conferences, seminars Minor hospitality Other minor non-monetary benefits to increase the quality of service
  • Complaint management
    Complaint Management (Customer Information) Date: February 18, 2022 Van Grunsteyn GmbH places great importance on providing you with the best possible service at all times. However, if you ever have a reason to make a complaint, we kindly ask you to get in touch with us promptly. We consider any expression of dissatisfaction by a customer or prospective customer related to the provision of a securities service or a securities ancillary service as a complaint. Required Information To investigate and potentially resolve the reason for your complaint, we require the following information: Your name and postal address or email address Your daytime contact number, specifying the time when you are most easily reachable A description of the reason for your complaint, including dates, amounts, and any other useful information A proposed solution to the matter There are no costs associated with making a complaint. Ways to Submit a Complaint You can submit a complaint to us through the following channels: By mail: Van Grunsteyn GmbH Complaint Management An der Hauptwache 5 60313 Frankfurt am Main By email: Handling Your Complaint Prompt Resolution We strive to respond to your complaint promptly. Upon initiating the complaint management process, we will send an acknowledgment of receipt. An acknowledgment of receipt will be omitted if a verbal or written response to the complaint is provided on the same day. We aim to resolve the complaint within a period of 10 days. If the complaint remains unaddressed after 10 days or if completion within the specified timeframe is not expected, we will inform you in advance and provide an estimated resolution timeline. Individual Solution We thoroughly review and work on an individual solution for each complaint, conducting research as necessary to obtain all relevant information. Response In our response to your complaint, we will provide you with details and the outcome of our investigation. We are also open to discussing this with you personally. Actions If your complaint highlights an issue within our organization, appropriate measures will be taken immediately to prevent a recurrence of similar complaints. Sometimes, a Third Party Is Needed In addition to the option of filing a civil lawsuit, complaints can also be directed to one of the following third parties: Relevant Regulatory Authority Alternatively, you can address your complaint to the Federal Financial Supervisory Authority (BaFin). Complaints should be sent to BaFin by letter, fax, or email and should include the circumstances and grounds for the complaint. Federal Financial Supervisory Authority (BaFin) Marie-Curie-Str. 24-28 60439 Frankfurt am Main Fax: +49(0)228 4108-1150 Email: European Online Dispute Resolution Platform The European Commission has established a European Online Dispute Resolution Platform (ODR platform) at Consumers can use the ODR platform for the out-of-court resolution of disputes arising from online contracts with a company located in the EU.
  • NAV (Net Asset Value)
    See “NAV”.
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