Participation Policy pursuant to the Shareholder Rights Directive, Art 3 of Directive (EU) 2017/828
Ithuba, as an asset manager pursuant to sec. 185 (1) (1) Stock Exchange Act 2018 [BörseG 2018] within the meaning of the 2nd EU Shareholder Rights Directive, is obliged to publish a detailed participation policy describing how it integrates shareholder participation into its investment strategy. Ithuba does not currently perform any fund management mandates. In the event that it assumes a fund management mandate, Ithuba will publish a detailed participation policy tailored to the fund assets (in particular in the case of direct equity investments) on its website in a timely manner.
Disclosures in accordance with Regulation (EU) 2019/2088 on sustainability‐related disclosures in the financial services sector (EU Sustainable Finance Disclosure Regulation) and Commission Delegated Regulation (EU) 2022/1288 (regulatory technical standards for the Disclosure Regulation)
ITHUBA is a financial services provider that specialises in serving professional clients. Achieving client-specific objectives is the sole focus of the company’s tailored investment advice and portfolio management services.
As an investment firm in the meaning of section 3 Wertpapieraufsichtsgesetz (Austrian Securities Supervision Act) 2018, which is authorised to provide portfolio management in accordance with Article 2(1)(b) Disclosure Regulation and to provide investment advice in accordance with Article 2(11)(d) Disclosure Regulation, ITHUBA is classified as a financial market participant or financial adviser and, as such, is obliged to disclose the following information.
At present, ITHUBA (in its role as a financial market participant with regard to portfolio management, and as a financial adviser in the event that it provides financial advice) has not identified any potential material negative impacts on investment decision‐making processes, on any investment advice provided, or on the company’s assets, finances, earnings and reputation arising from sustainability risks.
ITHUBA continuously monitors actual and potential material negative impacts on investment decision‐making processes (in connection with portfolio management, and on any financial advice provided), and on the company’s assets, finances, earnings and reputation arising from sustainability risks as part of its general risk management strategy.
No consideration of adverse impacts of investment decisions on sustainability factors: ITHUBA and its employees are committed to upholding environmental, social and climate-friendly values. However, the company and its employees do not consider the principal adverse effects of investment decisions on sustainability factors in portfolio management, given the nature and scope of the investment services offered in accordance with the EU criteria, as the requisite financial instruments are either not available or their availability is limited. Therefore, it is not possible for ITHUBA to provide portfolio management in this area in the best interests of its clients.
Declaration on consideration of principal adverse impacts on sustainability factors in investment advice: In view of the company’s size, the nature and scope of its activities and the types of financial product about which advice is provided, ITHUBA considers some of the principal adverse impacts on sustainability factors when assessing the suitability of the financial products concerned, based on information provided by the relevant financial market participants (product manufacturers).
Prior to a consultation, new and existing clients are informed about the risks and opportunities associated with sustainable financial products using the Sustainability Information document. The individual responsible for the (prospective) client answers any questions that they may have in this regard. The (prospective) client can then voluntarily (i.e. without being influenced) disclose their sustainability-related preferences.
If the (prospective) client decides to invest in a financial instrument or product for which the principal adverse impacts on sustainability factors are considered, and if the (prospective) client specifies qualitative or quantitative factors that demonstrate such consideration, ITHUBA compares the client’s specifications with the information provided by the financial market participants (product manufacturers) concerned.
If an assessment of suitability shows that one or more financial instruments or products meet the (prospective) client’s specifications or are suitable for the (prospective) client, the financial instrument(s) or product(s) in question can be recommended to the (prospective) client.
If an assessment of suitability shows that no financial instruments or products meet the (prospective) client’s specifications or are suitable for the (prospective) client, no financial instruments or products are recommended to the (prospective) client and these circumstances are explained to the (prospective) client. The (prospective) client is then free to reconsider their original specifications and, if necessary, adjust them. This explanation of the circumstances and any adjustments made by the (prospective) client are documented.
If the (prospective) client adjusts their original specifications, a new assessment of suitability is carried out on the basis of the adjusted sustainability preferences.
If the (prospective) client decides to be classified as “sustainability-neutral”, the (prospective) client may subsequently be offered suitable financial products with sustainability characteristics, as well as suitable financial products without sustainability characteristics.
The remuneration policy is not subject to sustainability risks.