Please note this is a convenience translation only and the legally binding document is the German version.
Strategies of the company for the inclusion of sustainability risks
Due to legal requirements (Art. 3 Disclosure Regulation), we are obliged to provide the following information. We do not intend to advertise ecological or social features in our investment strategies or for other specific financial instruments:
Declaration on the non-consideration of adverse effects on sustainability factors
Due to legal requirements (Art. 4 Disclosure Regulation) we are obliged to provide the following information:
Disclosure pursuant to Section 16 of the Remuneration Ordinance for Institutions
The Company's compensation systems are designed in such a way that, as a matter of principle, false incentives are avoided and no incentives are given to take high risks. Fixed and, where applicable, variable compensation is paid, with the fixed compensation being set in such a way that no economic dependency on the variable compensation components or excessive incentive can arise for the employee. Depending on the financial situation of the Company, the variable compensation may be reduced to zero. In application of the materiality, protection and confidentiality principles of Section 26a (2) of the German Banking Act (KWG), detailed disclosure of the total amount of fixed and variable remuneration and the number of employees receiving variable remuneration is not provided, as this information would allow conclusions to be drawn about the confidential remuneration of individual employees due to the size and structure of the Company. Further required disclosures are published annually in the Federal Gazette.
Statutory Disclosure on the Implementation of the Second Shareholder Rights Directive (ARUG II, zweite Aktionärsrechterichtlinie, Second Shareholder Rights Directive)
Spinoza Capital GmbH falls under the definition of an asset manager within the meaning of § 134a para. 1 no. 2 AktG (Aktiengesetz, Stock Corporation Act) and must therefore describe its participation policy within the meaning of § 134b AktG.
You can notify us of any complaints by e-mail or by letter using the following contact details:
Spinoza Capital GmbH
D-60327 Frankfurt am Main
Please provide us with your name, contact details and a description of your concern. You will immediately receive a confirmation of the receipt of your complaint by letter or e-mail.
We will then endeavor to resolve your concern as quickly as possible in your interest. If this is not possible within two weeks of receipt, you will receive an interim reply from us by letter or e-mail.
Within four weeks of receipt, you will receive a final decision from us by letter or e-mail. If this is not possible, we will inform you of the reasons and our estimate of when the resolution is expected to be completed.
Complaints will be discussed with at least one member of management. If this does not lead to satisfactory results, the Company’s auditor for the current fiscal year can be called in as an arbitrator upon request. Any costs incurred shall be borne by the Company.
Liability for contents
The contents of our pages have been created with the utmost care. However, we cannot guarantee the accuracy, completeness and timeliness of the content. As a service provider, we are responsible for our own content on these pages in accordance with § 7 Para. 1 of the German Telemedia Act (TMG). According to §§ 8 to 10 TMG, however, we are not obligated as a service provider to monitor transmitted or stored third-party information or to investigate circumstances that indicate illegal activity. Obligations to remove or block the use of information under the general laws remain unaffected. However, liability in this regard is only possible from the point in time at which a concrete infringement of the law becomes known. If we become aware of any such infringements, we will remove the relevant content immediately.
Liability for links
Our offer contains links to external websites of third parties, on whose contents we have no influence. Therefore, we cannot assume any liability for these external contents. The respective provider or operator of the pages is always responsible for the content of the linked pages. The linked pages were checked for possible legal violations at the time of linking. Illegal contents were not recognizable at the time of linking. However, a permanent control of the contents of the linked pages is not reasonable without concrete evidence of a violation of the law. If we become aware of any infringements, we will remove such links immediately.
The contents and works created by the site operators on these pages are subject to German copyright law. Duplication, processing, distribution, or any form of commercialization of such material beyond the scope of the copyright law shall require the prior written consent of its respective author or creator. Downloads and copies of this site are only permitted for private, non-commercial use. Insofar as the content on this site was not created by the operator, the copyrights of third parties are respected. In particular, third-party content is identified as such. Should you nevertheless become aware of a copyright infringement, please inform us accordingly. If we become aware of any infringements, we will remove such content immediately.