Transparenzverordnung
Potential sustainability risks in the insurance investment and financial products we broker are currently not taken into account in our advisory process. A sustainability risk is defined as an event or condition in the areas of environment, social affairs, or corporate governance, the occurrence of which could actually or potentially have a material negative impact on the value of an investment. The precise definitions and criteria (technical regulatory standards) for applying the provisions of the EU Sustainable Finance Disclosure Regulation (SFDR) are still being determined by the European legislator and are currently partly uncertain. Before specific sustainability risks of an investment can be incorporated into the advisory process, more concrete requirements from the legislator must first be established, and these requirements must then be reflected in the product design by the product providers, with corresponding information made available and reviewed. It is therefore planned to include potential sustainability risks in the advice on insurance investment products as soon as the relevant regulations by the European legislator are in force and the corresponding information has been provided and verified by the product providers. The inclusion of sustainability aspects in the advice on insurance investment products (e.g. private pension insurance) will likely become a legal requirement starting from the first quarter of 2022, following the amendment of the relevant IDD Directive (EU Directive on Insurance Distribution) and the MiFID Directive (EU Directive on Markets in Financial Instruments). Upon request by the client, environmentally oriented and socially responsible insurance investment products that take ecological and/or social aspects and/or corporate governance into account are already included in the advisory process. The remuneration for the advice on insurance investment products that our advisors receive from our product partners is not influenced by the sustainability risks associated with the brokered products. In particular, this means that the amount of remuneration is neither positively nor negatively affected by the sustainability or the sustainability risks of the respective product.
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