Imprint

Managing Directors:
Hubertus Clausius
Frank Eichelmann

Commercial register:
Amtsgericht Frankfurt am Main, HRB132475

Tax-Identification number:
DE317644590

Webdesign, programming:
Holger Reichard, www.wortmax.com

*Only the German version of the text is legally binding.

For legal disputes relating to financial or securities services agreements, the Ombudsman Office of the Association of Independent Asset Managers Germany (VuV) is the competent authority:

VuV Ombudsman Office
Stresemannallee 30, 60596 Frankfurt am Main
www.vuv-ombudsstelle.de

Supervisory Authority

Seahawk Investments GmbH is authorized to provide financial portfolio management, investment advisory services, as well as investment mediation and contract brokering in accordance with Section 15 Paragraph 1 in conjunction with Section 2 Paragraph 2 Nos. 3, 4, 5, and 9 of the WpIG (Securities Institutions Act) and is subject to supervision by the Federal Financial Supervisory Authority (BaFin).

Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin)
Marie-Curie-Straße 24-28
D-60439 Frankfurt am Main

Engagement Policy

Description and Publication of the Engagement Policy of Seahawk Investment GmbH pursuant to Section 134b of the German Stock Corporation Act (AktG)

Seahawk Investment GmbH – hereinafter referred to as the “Institution” – qualifies as an asset manager within the meaning of Section 134a (1) No. 2 AktG and is therefore subject to the provisions of Sections 134b and 134c AktG. Accordingly, it is required to describe and publish its engagement policy pursuant to Section 134b (1) AktG.

The Institution does not exercise shareholder rights on behalf of its clients. It does not attend general meetings, does not exercise voting rights for clients, only takes note of notifications from public companies insofar as they are mandatory disclosures, and does not engage in active communication with the company or other shareholders.

Therefore, the engagement policy has been defined as follows:

• The Institution does not exercise shareholder rights within the meaning of Section 134b (1) No. 1 AktG, which are based on engagement with the company. In particular, no rights related to general meetings of public companies are exercised. The right to a share in the profits under Sections 60 et seq. AktG, as well as subscription rights, is exercised in consultation with the clients.
• The monitoring of important matters of the companies pursuant to Section 134b (1) No. 2 AktG is carried out by taking note of the legally mandated reports of the companies in their financial statements and ad-hoc disclosures.
• There is no exchange of views with the company’s management and/or stakeholders of the company pursuant to Section 134b (1) No. 3 AktG.
• No collaboration with other shareholders pursuant to Section 134b (1) No. 4 AktG takes place.
• In the event of conflicts of interest pursuant to Section 134b (1) No. 5 AktG, these will be disclosed to the affected parties in accordance with legal requirements, and the further course of action will be clarified with the affected parties.
• The annual reporting on the implementation of the engagement policy pursuant to Section 134b (2) AktG is not carried out, as no relevant exercise of rights takes place.
• The publication of voting behavior pursuant to Section 134b (3) AktG does not occur, as no participation in votes takes place.

Disclosure pursuant to Section 7 of the German Remuneration Regulation for Institutions (InstitutsVergV)

The remuneration systems of Seahawk Investments GmbH are designed in such a way that inappropriate incentives are generally avoided. Fixed and, where applicable, variable remuneration components are paid, whereby the fixed remuneration is set at a level that prevents any economic dependency on variable remuneration components or the creation of excessive incentives for employees. Depending on the financial situation of the institution, variable remuneration may be reduced to zero.
Further mandatory disclosures pursuant to Section 7 of the InstitutsVergV are published annually in the management report (Lagebericht) of Seahawk Investments GmbH in the Bundesanzeiger (Federal Gazette).

Information on the Accessibility Enhancement Act (BFSG)

Seahawk Investments GmbH is not subject to the service-related requirements of the Accessibility Enhancement Act (Barrierefreiheitsstärkungsgesetz – BFSG). Nevertheless, we make every effort, where possible, to ensure that access to our services is as barrier-free as possible.

Limitation of liability for internal content

The content of our website has been compiled with meticulous care and to the best of our knowledge. However, we cannot assume any liability for the up-to-dateness, completeness or accuracy of any of the pages. Pursuant to section 7, para. 1 of the TMG (Telemediengesetz – Tele Media Act by German law), we as service providers are liable for our own content on these pages in accordance with general laws. However, pursuant to sections 8 to 10 of the TMG, we as service providers are not under obligation to monitor external information provided or stored on our website. Once we have become aware of a specific infringement of the law, we will immediately remove the content in question. Any liability concerning this matter can only be assumed from the point in time at which the infringement becomes known to us.

Limitation of liability for external links

Our website contains links to the websites of third parties (»external links«). As the content of these websites is not under our control, we cannot assume any liability for such external content. In all cases, the provider of information of the linked websites is liable for the content and accuracy of the information provided. At the point in time when the links were placed, no infringements of the law were recognisable to us. As soon as an infringement of the law becomes known to us, we will immediately remove the link in question.

Copyright

The content and works published on this website are governed by the copyright laws of Germany. Any duplication, processing, distribution or any form of utilisation beyond the scope of copyright law shall require the prior written consent of the author or authors in question.

Newsletter

This document is marketing information aimed exclusively at professional clients within the meaning of Section 67 of the German Securities Trading Act (WpHG) (natural and legal persons) with their habitual residence/registered office in Germany and is used exclusively for information purposes.

This marketing information cannot replace individual investment and investor advice and does not constitute a contract or any other obligation. Furthermore, the content does not constitute investment advice, an individual investment recommendation, an invitation to subscribe to securities or a declaration of intent or an invitation to conclude a contract for a transaction in financial instruments. Nor was it written with the intention of providing legal or tax advice. The tax treatment of transactions depends on the personal circumstances of the respective customer and may be subject to future changes. The individual circumstances of the recipient (including the economic and financial situation) were not taken into account when preparing the information. Past performance is not a reliable indicator of future performance. Recommendations and forecasts are non-binding value judgments about future events and may therefore prove to be inaccurate with regard to the future performance of a product. The information provided relates exclusively to the time of preparation of this marketing information; no guarantee can be given that it is up to date or will continue to be correct.

An investment in the aforementioned financial instruments/investment strategy involves certain product-specific risks – e.g. market or sector risks, currency risk, default risk, liquidity risk, interest rate risk and credit risk – and is not suitable for all investors. Therefore, potential investors should only make an investment decision after a detailed investment consultation with a registered investment advisor and after consulting all available sources of information. For further information, you can find the key information document (PRIIPs) and the securities prospectus free of charge here: https://seahawk-investments.com/fonds/. The information is provided to you in English.
The above content exclusively reflects the opinions of the author; these opinions may change at any time without being published. This information is protected by copyright and may not be reproduced or used for commercial purposes.

Data protection

Here you can find our data protection declaration (in German language).

*Only the German version of the text is legally binding.