Transparency Obligations
Disclosure Regulation
Sustainability-related disclosures pursuant to Regulation (EU) 2019/2088
HanseMerkur Trust AG publishes the sustainability-related disclosures required by Articles 3 to 5 of the Disclosure Regulation on its website. The publication includes strategies for integrating sustainability risks into investment processes, statements on the principal adverse impacts of sustainability, and on the remuneration policy in connection with the consideration of sustainability risks.
Download
Please click here to access the complete PDF.
Engagement and Disclosure Obligations according to the Shareholder Rights Directive (ARUG II)
As an asset manager within the meaning of Section 134a (1) No. 2 of the German Stock Corporation Act (AktG), HanseMerkur Trust AG must describe its engagement policy within the meaning of Section 134b AktG.
-
HanseMerkur Trust AG does not exercise shareholder rights within the meaning of Section 134b (1) No. 1 AktG that are based on engagement in the company. In particular, no rights related to the general meetings of stock corporations are exercised. The right to a share of profits within the meaning of Sections 60ff. AktG and subscription rights are exercised in consultation with clients.
-
The monitoring of important matters of the companies within the meaning of Section 134b (1) No. 2 AktG is carried out by taking note of the legally mandated reporting of the companies in financial reports and ad-hoc announcements.
-
An exchange of views with the company's corporate bodies and stakeholders within the meaning of Section 134b (1) No. 3 AktG does not take place.
-
Cooperation with other shareholders within the meaning of Section 134b (1) No. 4 AktG does not take place.
-
In the event of conflicts of interest within the meaning of Section 134b (1) No. 5 AktG, disclosure to the affected parties will take place in accordance with legal provisions, and further steps will be clarified with them.
-
An annual publication on the implementation of the engagement policy within the meaning of Section 134b (2) AktG does not take place because the corresponding rights are not exercised.
-
A publication of voting behavior within the meaning of Section 134b (3) AktG does not take place because participation in votes does not occur.
Remuneration Principles
The remuneration principles of HanseMerkur Trust AG are determined taking into account supervisory requirements (Section 63 (3) WpHG and, more specifically, the German Securities Institutions Remuneration Ordinance (WpIVergV) and BT 8 MaComp.).
Remuneration System
The remuneration at HanseMerkur Trust AG for the Management Board and employees is based on a fixed and a variable component. The basis of the variable remuneration is the annual agreement on company-specific and individual targets. This target agreement is reached through a top-down process at the beginning of each year. Starting with the Management Board, the targets are broken down to the subordinate positions. The targets, in accordance with the respective tasks, are both quantitative and qualitative. In the context of an annual target achievement discussion, the degree of target achievement is agreed upon between the superior and the employee, and the amount of variable remuneration is derived therefrom. The amount of variable remuneration for the Management Board and employees is limited to a maximum amount that is in an appropriate relationship to the fixed annual remuneration.
Overall, a system has been implemented that offers sufficient incentives for dedicated and performance-oriented cooperation at HanseMerkur Trust AG, while keeping variable remuneration within limits so that no excessive risks are taken in the individual mandates.
The Supervisory Board of HanseMerkur Trust AG is informed about the remuneration system once a year, allowing the body to form its own judgment on its appropriateness. Furthermore, the remuneration principles are reviewed once a year and, if necessary, adjusted promptly.
Hamburg, September 2026