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IMP AG (hereinafter "company") falls under the term "asset manager" according to Art. 367a No. 3 of the Liechtenstein Persons and Companies Act (PGR) and must therefore, describe its engagement policy in accordance to Art. 367h PGR.

The company does not exercise any shareholder rights according to Article 367h Paragraph 1 Items 1 and 4 PGR that are based on the engagement in stock corporations, in which the company has invested into as a part of asset management mandates. In particular, no rights related to the general meetings of stock corporations are exercised. The right to a share of profits and subscription rights are exercised in the interest of asset management mandates.

The monitoring of important corporate events in accordance to Article 367h, Paragraph 1, Item 2 of the PGR are implemented according to the corporations’ statutory reporting in financial reports and ad-hoc notifications.

There is no exchange of dialogue with the corporate bodies or other relevant stakeholders of the corporations in accordance to Article 367h Paragraph 1 Item 3 PGR.

There is no collaboration with shareholders or other relevant stakeholders of the corporations in accordance to Article 367h Paragraph 1 Items 5 and 6 PGR.

In the event of conflicts of interest in accordance to Article 367h Paragraph 1 Item 7 PGR, the necessary disclosure as well as clarification on how to proceed in regards to those affected is exercised in reference to the statutory provisions.

An annual publication regarding the implementation of the engagement policy does not take place in accordance to Art. 367h Paragraph 2 PGR as the corresponding rights management are not exercised.

A publication of the voting behavior in accordance to Article 367h Paragraph 2 PGR is not implemented as voting participation is not exercised.


In order to meet the legal requirements of Article 3 Paragraph 2 of Regulation (EU) 2019/2088 on sustainability-related disclosure requirements in the financial services sector ("Disclosure Regulation"), IMP AG (hereinafter "company") must provide information on its strategies for including sustainability risks in asset management activities ("Strategies for incorporating sustainability risks as an asset manager").

The required information on strategies for the inclusion of sustainability risks as an asset manager relates primarily to the portfolio management of financial products within the meaning of the Disclosure Ordinance. The company has made the fundamentally strategic decision to consider financial products that are not based on the EU criteria for ecologically sustainable economic activities. This means that sustainability risks are not systematically included in the investment decision-making process for the portfolio management. Their valuation does not show any relevant effects on the return because, due to the specific investment policy and the associated investment restrictions as well as the performance achieved in the past, a relevant effect on the overall portfolio cannot be assumed.

It should be noted, however, that past performance is not indicative of future performance. No single sustainability risk is expected to have a material adverse financial impact on the portfolio return. Adverse impacts of investment decisions on sustainability factors are not systematically considered because the data base is complex and based on environmental, social, or governance data that is difficult to obtain, implement, estimated, outdated or otherwise inaccurate.

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