Compliance Investments

Principles for dealing with conflicts of interest

As Willis Towers Watson Investments GmbH ("WTWI") we are committed to providing services to our clients in their best interests. To ensure that our clients' interests are always put first, we must be alert to whether business activities involve a conflict of interest or the appearance of a conflict of interest. This is critical to our business. Identifying such situations and dealing with them, including disclosure to the client, is critical to our reputation and success. This includes.

• actual or potential conflicts of interest
• the appearance of a conflict of interest
• A situation that appears to be conflict-free but could develop into a conflict-laden situation.

Type of conflict of interest

WTWI has identified the following types of conflicts of interest:

• Conflicts regarding clients: WTWI cannot act in the best interests of one client without adversely affecting the interests of another client.
• Conflicts relating to the company: WTWI's own interests are in conflict with a duty that the company has to a customer.
• Personal conflict: A colleague's personal interest is actually or potentially in conflict with a duty we have to a customer or with their duty to WTWI.

Dealing with conflicts of interest

All conflicts of interest - actual, suspected, or potential - must be identified and investigated before proceeding with the work concerned. If a conflict of interest cannot be avoided, the nature of the conflict and its cause shall be indicated.
WTWI has consolidated processes and effective guidelines that make it possible to identify potential conflicts of interest promptly, react accordingly and ensure effective handling in the interests of customers. The procedure for different conflict categories is documented in detail in the internal guidelines and employees are required to follow them. The effectiveness of the measures is reviewed annually and if changes and improvements in handling are recognised, the guidelines are adjusted accordingly. In addition, all employees receive regular training. Our program includes one mandatory seminar per year and further refresher training opportunities as required or in parallel with legal changes.

Contact:

If you have any further questions about our handling of conflicts of interest, the Legal and Compliance department will be happy to answer them by e-mail: Compliance_WTWI@wtwco.com

Complaints procedure for clients of Willis Towers Watson Investments GmbH

Introduction

Willis Towers Watson Investments GmbH is committed to meeting the exacting standards of integrity expected of our industry and providing excellent service to our clients. However, we recognise that we may not be able to meet your expectations and if this happens, we will address your concerns.

If you are unhappy with our service and are thinking about making a complaint, this leaflet tells you how to make a complaint. If you have already complained to Willis Towers Watson Investments GmbH, this leaflet explains how we will proceed and what you can expect next.

Complaint report

If you wish to make a complaint about Willis Towers Watson Investments GmbH, you can do so in writing (e- mail, fax, or letter), by telephone or in a personal meeting. You can raise your concern directly with your normal point of contact (Client Lead Consultant) or the person dealing with a particular issue on your behalf.

Our process

If your complaint is straightforward, we will endeavour to deal with it immediately and informally. Otherwise, we will proceed as follows:

• forward your complaint to our complaints manager.
• confirm the complaint in writing within five working days and inform you who is responsible for reviewing the complaint.
• respond to your complaint as soon as possible - however, if we are unable to do so within four weeks, we will keep you informed of the status of our work and let you know when we expect to send our final response.
• analyse your complaint and endeavour to provide you with a final response within eight weeks, explaining our decision and the reasons for it.

The processing of complaints is free of charge.

What you can do if you are not satisfied with our response

• If you feel that we have not handled your complaint properly or are unhappy with our final response, you can ask for the decision to be reviewed by senior management in the first instance. If you are not satisfied with the outcome of the resolution by senior management, you can escalate the matter to the Willis Towers Watson Investments GmbH Complaints Officer. We are confident that our escalation process will enable any complaint to be resolved in an appropriate time and manner.
• You can also contact the German Federal Financial Supervisory Authority ("BaFin") with your complaint in accordance with Section 4b of the German Financial Services Supervision Act. The complaint must be submitted to BaFin by letter, fax or e-mail and should include the facts of the case and the reason for the complaint.

You also have the option of filing a civil lawsuit.

[Willis Towers Watson does not participate in dispute resolution proceedings before an alternative dispute resolution body].

Contact details:

Willis Towers Watson Investments GmbH
Ulmenstraße 30, 60325 Frankfurt am Main
E-Mail: Complaints_WTWI@wtwco.com

Federal Financial Supervisory Authority (BaFin)
Graurheindorfer Straße 108, 53117 Bonn
Phone: + 49 (0)228 4108-0
Fax: + 49 (0)228 4108-1550
E-Mail: poststelle@bafin.de

Willis Towers Watson Investments GmbH, Sucursal en Espana
ES Madrid - C/Martinez Villergas, número 52 - Bloque 1, Planta 3 / 5ª planta
T: +34 915 90 51 12
E: Complaints_WTWI@wtwco.com

Comisión Nacional del Mercado de Valores (CNMV)
(CIF Q-2891005-G), Calle Edison nº 4, Madrid.
Tlfno: +34 915851500
Sede electronica: Sede electrónica CNMV Registro electrónico

WTW Investments NL Branch
Prof. E.M. Meijerslaan 5, 1183 AV Amstelveen Postbus 75201, 1070 AE Amsterdam, Nederland
T: +31 88 543 3140
E: Complaints_WTWI@wtwco.com

Autoriteit Financiële Markten (AFM)
t.a.v. Functionaris Gegevensbescherming, Postbus 11723, 1001 GS, AMSTERDAM
Telefoonnummer: +31 20 797 3400
E-Mail: BES@afm.nl

Remuneration policy

Willis Towers Watson Investments GmbH ("WTWI") is subject to the regulatory requirements applicable to financial services institutions with regard to the organisation of its remuneration system, known as the Remuneration Ordinance for Institutions (Institutsvergütungsverordnung - InstitutsVergV).

WTWI's remuneration system comprises fixed and variable remuneration elements and is reviewed at least once a year to ensure that it is appropriate and complies with all legal requirements. The calculation of variable remuneration considers the company's overall result, the team's target achievement and the employee's personal performance.

WTWI is committed to sustainability and endeavours to apply ESG parameters accordingly when calculating the variable remuneration component of the remuneration system. The sustainability criteria to be applied in WTWI's remuneration policy are determined, implemented and disclosed in accordance with the formulation of the Sustainability Policy and the definition of an ESG taxonomy in accordance with Article 5 SFDR (Regulation (EU) 2019/2088 of the European Parliament and of the Council on sustainability-related disclosures in the financial services sector).

Sustainability policy

Inclusion of sustainability risks in our investment advisory activities

For the WTW Group, sustainable investment means implementing long-term investment strategies, integrating environmental, social, and corporate governance ("ESG") factors, and considering the real impact on society and the planet when making investment decisions. In our view, this is an integral part of professional risk management and makes a positive contribution to a stable financial market. We believe that the principles underlying sustainable investments form the cornerstone of a successful long-term investment strategy and that sustainable investment considerations significantly improve the risk profile and returns of our clients' portfolios.

Sustainable investment is central to our investment process and is consistently applied at all stages of the investment decision-making process: from the definition of basic assumptions and guidelines, through risk management, portfolio construction and manager selection, to implementation and monitoring. We regard sustainable investment as an integral part of our decision-making and not as a separate or detached consideration.

Sustainable investment is anchored in the processes of our investment research department, our advisory services, and our product solutions. In our research and analyses, we consider the entire spectrum of potential sustainability risks and opportunities, which can be both financial and non-financial in nature. Unless customer-specific objectives or requirements dictate otherwise, we endeavour to identify and integrate those risks and opportunities that we consider to be financially material.

In particular, these would be transition risks and physical risks that could affect our customers' portfolios.

Further details on our sustainability strategy can be found as a download in our Group-wide guideline on sustainability risks.

Our latest publications in the area of sustainability policy are available here.

Possible effects of sustainability risks on returns

The effects of a sustainability risk materialising can be diverse and vary depending on the specific risk and asset class. In general, if a sustainability risk materialises in relation to an asset, this has a negative impact on its value and can lead to a complete loss. Sustainability risks can lead to physical losses, including damage to property and infrastructure. The materialisation of a sustainability risk can also lead to financial and operational risks, including negative effects on creditworthiness.

Sustainability risks should be considered as a separate type of risk but can also have an impact on downstream risk types, such as reputational risks or litigation risks. The increasing importance of sustainability aspects for both companies and consumers mean that the materialisation of a reputational risk can lead to considerable damage for the companies concerned.

For a sponsoring company of an occupational pension scheme or portfolio, for example, reputational damage can lead to a decline in demand for products or services, loss of key personnel, exclusion from potential business opportunities, increased operating costs and/or increased capital costs. The company could also suffer from the impact of fines and other regulatory sanctions.

The time and resources of the management team to manage sustainability risk, including changes in business practices and dealing with investigations and litigation, may distract from the continued development of the business.

A sustainability risk may occur and affect a specific investment or have a broader impact on an economic sector, geographical regions, and economic areas.

Consideration of sustainability risks in the remuneration policy

The consideration of sustainability risks in the remuneration policy can be found above in our remuneration policy guidelines.

Information regarding the consideration of sustainability risks

In order to implement the requirements of Art. 6 para. 1 subpara. 1 and Art. 6 para. 2 subpara. 1 Regulation (EU) 2019/2088 ("Disclosure Regulation"), we inform you below about the way in which sustainability risks are included in our investment advice and investment decisions and about the expected impact of sustainability risks on the return on your financial products.

Sustainability risks describe events or conditions in the environmental, social or governance areas whose occurrence could actually or potentially have a significant negative impact on the value of an investment. These risks can affect individual companies as well as entire sectors or regions.

The consideration of sustainability risks is anchored in the processes of our investment research department, our advisory services, and our product solutions. In our research and analyses, we consider the entire spectrum of potential sustainability risks and opportunities, which can be both financial and non-financial in nature. Unless required by customer-specific objectives or requirements, we endeavour to identify and integrate those risks and opportunities that we consider to be financially material.

The effects of a sustainability risk materialising can be diverse and vary depending on the specific risk and asset class. In general, if a sustainability risk materialises in relation to an asset, this has a negative impact on its value and can lead to a complete loss. Sustainability risks can lead to physical losses, including damage to property and infrastructure. The materialisation of a sustainability risk can also lead to financial and operational risks, including negative effects on creditworthiness.

Sustainability risks should be considered as a separate type of risk but can also have an impact on downstream risk types, such as reputational risks or litigation risks. The increasing importance of sustainability aspects for both companies and consumers mean that the occurrence of a reputational risk can lead to considerable damage for the companies concerned.

For a sponsoring company of an occupational pension scheme or portfolio, for example, reputational damage can lead to a decline in demand for products or services, loss of key personnel, exclusion from potential business opportunities, increased operating costs and/or increased capital costs. The company could also suffer from the effects of fines and other regulatory sanctions. The management team's time and resources to manage sustainability risk, including changes in business practices and dealing with investigations and litigation, may distract from the continued development of the business.

A sustainability risk may occur and affect a specific investment or have a broader impact on an economic sector, geographical regions, and economic areas.

Information in accordance with Regulation (EU) 2020/852

Under this agreement, WTWI may also provide portfolio management services within the meaning of Art. 4 (1) No. 8 of Directive 2014/65/EU. The portfolios to be managed by us may qualify as "financial products" within the meaning of Art. 2 No. 12 of the Disclosure Regulation. We would therefore like to draw your attention to the following with regard to the managed portfolios for the implementation of the requirements of Art. 7 of Regulation (EU) 2020/852: the investments underlying these financial products do not take into account the EU criteria for environmentally sustainable economic activities.

Disclosure report

This disclosure report as at 31 December 2022 implements the regulatory requirements for the disclosure of investment firms within the meaning of Part 6 of the Investment Firm Regulation (IFR). The disclosure requirements for Willis Towers Watson Investments GmbH (WTWI) are set out in Articles 46 to 53, some of which are specified in EBA standards.

Risk Disclosure Statement

This risk disclosure statement ("Statement”) is designed to enable an investor to understand the key concepts and risks associated with investing. This Statement does not provide an exhaustive list of the all our investment products and services offered, however, is intended to give you information on, and a warning of, the key risks associated with investment products and services so that you are able to understand the most significant risks associated with the investment products and services being offered and, consequently, to take investment decisions on a more informed basis. This Statement cannot disclose all the risks and other significant aspects of our investment products and services. You should satisfy yourself that you fully understand the conditions which apply to such investment products and services and the potential risk exposures. You should consider this Statement carefully before deciding whether or not to use any of our investment services or invest in any of our investment products.

The guidance contained in this Statement is not intended to be taken as investment advice based on a specific set of circumstances, nor as a recommendation to enter into any investment service or invest in any investment product. Where you are unclear as to the meaning of any of the disclosures or warnings described below, we would strongly recommend that you seek independent legal or financial advice. You should not invest in any investment product or agree to receive any investment service unless you understand the nature of the contract you are entering into and the extent of your exposure to risk. You should also be satisfied that any product or service is suitable financially in light of your investment objectives and, where necessary, you should seek appropriate independent advice in advance of making any investment decisions. All financial products carry a certain degree of risk. Even “low risk" investment strategies involve an element of uncertainty. The types of risk that might apply will depend on various matters, including how any relevant product, instrument or service agreement is created or drafted. Different instruments involve different levels of exposure to risk. Risk factors may occur simultaneously and may compound each other resulting in an unpredictable effect on the value of any investment. The value of investments and the income from them can fall as well as rise and you might lose the original amount invested. Fluctuations in such value and income can result from factors such as market movements and variations in exchange rates.

Past performance is not a reliable indicator of future results.