The contents of the website may not be reproduced in whole or in part or made available in any other way without the prior written consent of the company. The information and opinions presented on this website come from sources that the company believes to be reliable; however, the company gives no assurance as to its correctness and completeness. The company assumes no liability for any loss resulting from the use of the materials on this website.
This website is not to be understood as investment, legal or tax advice or to the effect that an investment or investment strategy is suitable for your personal situation and, furthermore, does not contain any investment recommendation directed at you personally.
There are risks associated with investing in the financial instruments presented on this website. Further details can be found in the relevant sales prospectus.
The financial instruments presented on this website have been reported to the Federal Financial Supervisory Authority for public distribution in Germany.
Unregulated products can be sold anywhere without the approval of the regulatory authority.
Past performance is not to be regarded as a guide or guarantee for future performance; no representation or warranty, express or implied, is made with respect to future performance. Opinions and / or assessments are based on the company's assessment on the date of initial publication and are subject to change without notice. The price / rate or value as well as the income of the securities or financial instruments mentioned on this website can rise as well as fall. Securities and financial instruments denominated in foreign currencies are subject to fluctuations in exchange rates, which may have a positive or negative effect on their value, the price / rate or the income of these securities and instruments. Investors in securities whose value is affected by currency fluctuations are de facto subject to this risk.
This website is updated and revised at regular intervals. Regardless of the date of access, materials are only up-to-date on the stated date of first publication. The company reserves the right to delete or change information on this website without prior notice. The company may have published further reports which are inconsistent with the information on this website or which lead to different results. These reports reflect the various assumptions, views and analytical methods of the analysts who prepared these reports. The company is not obliged to draw the user's attention to these reports.
Information and content, in particular prices, market, stock exchange or other economic information that CIS Asset Management (Deutschland) GmbH receives from third parties (news agencies or other commercial information providers) and / or that CIS Asset Management (Deutschland) GmbH receives via links and makes available to the user for third-party providers (third-party content) are not the responsibility of CIS Asset Management (Deutschland) GmbH; the company assumes no liability for this. In particular, the company assumes no responsibility for the currency of price information, which may only be passed on with a delay. Furthermore, CIS Asset Management (Deutschland) GmbH does not adopt the third-party content as its own, even if it can be reached via links on its website or via links on the website.
Any modification of the materials on the website, its contents or copies, or the transfer or distribution thereof to third parties without the prior written consent of the company is prohibited. The trademarks, service marks and logos used on this website are trademarks, service marks or registered trademarks or service marks of the company, its affiliates or other companies.
CIS Asset Management (Deutschland) GmbH has no influence on which systems and security programs are used by the customer / user of the website. For example, even calling up harmful third-party websites can result in potential risks if the customer systems are inadequately secured. CIS Asset Management (Deutschland) GmbH assumes no liability for the customer's systems.
However, the company points out that, due to this potential risk, it is absolutely essential that the customer / user always keeps his own system up to date, e.g. by regularly updating the security software (e.g. virus scanners and firewall systems) or by installing important system updates. CIS Asset Management (Deutschland) GmbH advises: Obtain information in the relevant documentation from the software manufacturer of your programs and, if necessary, seek advice from security experts.
A customer should only invest into financial instruments if they have the necessary knowledge of the corresponding financial instruments and the risks involved. The client should also ensure that the product is suitable for him / her given his /her investment objectives, risk appetite and other personal and financial situation.
CIS Asset Management (Deutschland) GmbH provides standardized basic information on financial instruments and the associated risks.
We are aware of the importance of financial markets for achieving and maintaining ESG objectives and support these in cooperation with our selected network of CLO managers. From a capital market/financial policy perspective, CLO securitizations generally have a positive social impact, as they are suitable for promoting economic activity, whether by companies or public institutions, by expanding traditional financing options for companies. However, this aspect does not directly affect the ESG impact of individual CLO securitizations, either positively or negatively.
A typical CLO issue securitizes 200-350 individual loans from different companies. The size of individual securitized loans from a single company therefore ranges between 0.50% and 0.27% of the total volume of a CLO issue. CIS CLO issues bundle tranches of CLO issues from different CLO managers. This ensures even greater diversification. It is therefore not possible to seriously claim that individual CLO issues have a positive ESG impact.
Due to the high level of risk and impact diversification inherent in CLO securitizations with respect to the situation of individual companies acting as borrowers of the underlying securitized loans (hereinafter referred to as “CLO borrowers”), this principle generally also applies to positive ESG-related contractual provisions in CLO documentation or positive ESG ratings pertaining to individual companies/borrowers involved in the CLO structure.
Our ESG securitization, investment, and reporting efforts within the framework of the CIS ESG/Sustainability Strategy therefore focus on avoiding or minimizing criteria that are, in line with prevailing practice and the standards of the EU transparency regulations, classified as indicators of potential adverse ESG/sustainability impacts. In this context, the predefined Principal Adverse Impact (PAI) indicators, as outlined in the EU ESG transparency rules, could initially be considered.
However, given the high degree of diversification of CLO issues, any potential ESG-related adverse impacts of individual CLO issues are likely to be insignificant in relation to the total volume of loans securitized in a CLO issue, even if individual CLO borrowers in these issues have corresponding Principal Adverse Impact Indicators. For this reason, CIS also refrains from making a formulaic quantitative comparison of the PAI-burdened CLO securitization volume with the total securitization volume not burdened by PAI.
Negative CIS ESG/sustainability criteria focus therefore differently in avoiding or minimizing exposure to industries that are generally considered harmful to ESG, such as addictive substances (alcohol, tobacco), gambling (casinos, online betting), and the promotion of fossil fuels, such as oil companies or environmentally harmful raw material exploration.
To identify relevant CLO borrowers, reference is made to their national industry classification codes, such as SIN or NAISC codes in the US or the NACE code in the EU, which takes into account the requirements of the statistical classification of economic activities in the European Community (Regulation (EC) 1893/2006) and also forms the basis for the classification of economic activities in Germany. As shown by the examples of fossil fuels, the security and defence industry, the nuclear industry, and the cement industry, the classification of certain economic sectors as typically ESG-damaging can be subject to change and can also be assessed differently by customers. The same applies to the question of whether only the core area of relevant economic activities should be covered or whether supplier or processing activities should also be included, and whether ESG-neutral subsidiaries of corporations with an overall negative ESG orientation should be included or not. CIS will coordinate this with customers as part of the alignment of its own ESG/sustainability strategies with the sustainability strategy/ideas of the respective customer in accordance with the MIFID II requirements for financial advisors.
Alternatively, and in addition, CIS considers available CLO borrower ratings from ESG rating agencies in the lower third as relevant indicators of negative ESG impact.
Information according to § 16 InstitutsVergV
As a financial services company, we are subject to the “Enactment on the Regulatory Requirements for Remuneration Systems of Institutions”. This enactment distinguishes between simple and significant institutions. Since our balance sheet total has neither reached nor exceeded 15 billion Euros in the last three financial years (according to §17 InstitutsVergV item 1), CIS Asset Management (Deutschland) GmbH is not yet considered a "significant company". In addition, we cannot be classified as a CRR institute.
Nevertheless, according to Section 16 of this enactment, we are obliged to publish information on the structure of the remuneration systems on our website. Due to the structure of our business model, which does not allow us to acquire customer deposits, that risks taken are only at the expense of our equity and that the remuneration structure is regularly analysed, there are no other special risks for the institute.
The remuneration system for management and employees is based on fixed payments. The personnel expenses for employees and management are disclosed in the management report for the annual financial statements. Further publication obligations do not exist according to the Institutsvergütungsverordnung or Art. 450 Paragraphs 1 and 2 of Regulation (EU) No. 575/2013) in conjunction with Art. 434 Paragraph 2 of this enactment.
Complaints
Complaints are more than expressions of displeasure. They provide valuable information about opportunities for improvement in our company and the expectations of our business partners. They offer an opportunity to create customer satisfaction and thus to strengthen or regain customer relationships.
Regardless of this, complaints can help to identify and avoid illegal behaviour and corresponding risks in a timely manner (compliance-relevant complaints).
Any serious expression of displeasure by the customer is a complaint. This also applies to complaints that are obviously unfounded. These can be labelled as “obviously unjustified complaints”, but must not be ignored. Telephone or verbal complaints must also be recorded.
CIS Asset Management (Deutschland) GmbH ensures that all significant customer complaints are dealt with promptly, fairly and in a comprehensible manner. This concerns both complaints that relate directly to CIS Asset Management (Deutschland) GmbH and complaints that directly affect business partners of CIS Asset Management (Deutschland) GmbH.
The processing of complaints is free of charge.
As soon as we receive a complaint, we will process it immediately. You will receive feedback on your complaint within five business days of receipt of the complaint. If it becomes apparent that due to the complexity of the matter the processing process will take longer, we will inform you within the above-mentioned period and inform you about the reasons for the delay.
CIS Asset Management (Deutschland) GmbH has appointed a complaint manager who carries out the tasks according to internal principles.
If you have any complaints or feedback, please contact:
CIS Asset Management (Deutschland) GmbH
Hauptstraße 81
D-65760 Eschborn
Ms Inès Bartsch
Phone: +49 (0) 6196 / 77305 – 18
E-Mail: ib[at]cisasset.com
Ombudsman
Employees as well as external business partners or clients can report possible of possible conflicts of interest via the ombudsman of CIS Asset Management (Deutschland) GmbH in an identity-protected manner:
BKPI LEGAL & COMPLIANCE
Bolongarostraße 103
D-65929 Frankfurt am Main
Dr. Reinhard Preusche
Phone: +49 (0) 151 2408 1524
E-Mail: reinhard.preusche[at]bkpi-legal.de
Other
This website is issued or approved by CIS Asset Management (Deutschland) GmbH ("CIS Asset Management") which is authorised and regulated by the Federal Financial Supervisory Authority ("BaFin"). CIS Asset Management whose registered office is at Hauptstraße 81, 65760 Eschborn, Germany, appears in the BaFin's Register (Registration No. 121247). CIS Asset Management is registered as a Gesellschaft mit beschränkter Haftung (private limited company) in Germany (Amtsgericht Frankfurt, Company Number HRB 87624).
CIS Asset Management is subject to the BaFin rules and guidance, details of which can be found on the BaFin's website at www.bafin.de. The BaFin regulates the financial services industry in Germany and is located at Graurheindorfer Str. 108, 53117 Bonn, Germany and Marie-Curie-Str. 24-28, 60439 Frankfurt, Germany.
Users of this website are not automatically regarded by the company as customers due to this use.
Place of Jurisdiction
The applicable law, in the sense of the "legal information", is the law of the Federal Republic of Germany.
