Code of conduct
Conflicts of interest
Best execution principles
The European Union (EU) created the EU action plan on financing sustainable growth in order to achieve the energy and climate targets set in the Agenda 2030. The financial services sector is essential for achieving the sustainability goals, as well as for sustainable development.
Investment decisions have an impact on the environmental, social and corporate governance matters. To fulfill our responsibility as a fund service platform, Universal Investment considers sustainability risks in advance of investment decisions as well as negative sustainability impacts caused by investments.
The EU action plan on financing sustainable growth has given rise, inter alia, to regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability-related disclosure in the financial services sector ("Disclosure Regulation"). Universal Investment publishes the following documents within the meaning of the disclosure regulation.
Policies on the Integration of sustainability risk
In accordance with Article 3 of the disclosure regulation Universal Investment discloses how sustainability risks are dealt with in Universal Investment's investment decisions. Sustainability risk means an environmental, social or governance event or condition that, if it occurs, could cause a negative material impact on the value of an investment.
Statement on principal adverse impacts of investment decisions on sustainability factors
Principle Adverse Impacts (PAI) are potential adverse effects of investment decisions on sustainability factors. Sustainability factors are environmental, social and employee matters, respect for human rights, anti‐corruption and anti‐bribery matters. In accordance with Article 4, paragraph 1, section a of the disclosure regulation, Universal Investment takes a position on the consideration and management of adverse sustainability impacts and discloses the activities and due diligence strategies on this matter.
As of December 31, 2022, Universal Investment has updated the statement on principal adverse impacts of investment decisions on sustainability factors in line with the requirements of Commission Delegated Regulation (EU) 2022/1288 of April 6, 2022. Among other things, the reference period of the statement and the scope of the financial products covered have been adjusted. In addition, the statement no longer covers the entire group and only relates to Universal-Investment-Gesellschaft mbH. Universal Investment-Luxembourg S.A. publishes a separate statement.
In accordance with the requirements of Delegated Regulation (EU) 2022/1288, as of June 30, 2023, the Universal Investment statement was extended to disclose for the first time the principal adverse impacts of investment decisions related to the calendar year 2022.
In accordance with Article 5 of the disclosure regulation, Universal Investment discloses in the remuneration policy information on how the policy is consistent with the integration of sustainability risks.
Please find all fund related regulation information and documents in our fund finder.
Mifid II – best execution principles
Introduction to the top 5 annual reports and evaluation of execution quality
(As of March 2023)
In accordance with section 82 (9) of the German Securities Trading Act (WpHG), please find attached the five execution venues (brokers and trading venues) for each category of financial instrument of greatest importance in terms of trading volume on which we executed customer orders in the previous year, as well as information on the execution quality achieved in accordance with the requirements of commission delegated regulation (EU) 2017/576 of 8 June 2016 supplementing directive 2014/65/EU of the European Parliament and Council on the basis of technical regulation standards for the annual publication of information by securities firms on the identity of trading venues and execution quality (Official Journal of the European Union L 87 of 31 March 2017, p. 166).