Legal information
General information
(1) Disclaimer
The information provided on our website is based on sources that we consider reliable. However, we assume no guarantee for the accuracy, completeness, or timeliness of such information, nor for any recommendations or for the economic or fiscal implications thereof. This publicly accessible information is provided for general information purposes and shall not under any circumstances replace investor/product-related advisory services. In particular, information relating to securities shall not constitute solicitations to buy or sell. The public offering and sale of securities are subject to the national laws and other statutory provisions in force in each individual country.
All information published on this website is diligently and promptly verified and updated by H&A Global Investment Management GmbH. Nevertheless, H&A Global Investment Management GmbH does not assume any guarantee for the completeness, accuracy, and timeliness of such information. H&A Global Investment Management GmbH cannot be made liable in the event of inaccurate, incomplete, or not current data, nor in the event of falsification of information.
(2) Governing law/Place of jurisdiction
All legal relationships between you and H&A Global Investment Management GmbH shall be governed by the laws of the Federal Republic of Germany. We expressly inform you that our Internet offering is aimed exclusively at persons who are subject to a legal system in which such choice of law clause is permitted. Place of jurisdiction – to the legally permissible extent – is agreed as Frankfurt am Main,or Munich.
(3) Limitations of liability
H&A Global Investment Management GmbH cannot guarantee the failure-free functionality of this website. In no event shall H&A Global Investment Management GmbH be liable for any loss or damage of any kind. This disclaimer includes direct, indirect, and consequential damage arising out of or related to the access to, performance of, or queries submitted to the H&A Global Investment Management GmbH site, or that could arise through links to other sites, even where H&A Global Investment Management GmbH has not indicated the possibility that such damage could occur.
(4) No acceptance for orders by email
We would like to inform you that we do not accept any legally binding orders or instructions via email. Please contact your relationship manager.
(5) Linked websites
When you click specific links on the H&A Global Investment Management GmbH website, under certain circumstances, you will leave the H&A Global Investment Management GmbH website. H&A Global Investment Management GmbH has not reviewed the other websites linked to the H&A Global Investment Management GmbH website, and does not assume any responsibility for their contents, including for the products or services offered, or other offerings and information.
(6) Copyright
The content and structure of this website are protected by copyright. The prior consent of H&A Global Investment Management GmbH is to be obtained before reproducing any information or data, particularly the use of text, text extracts, or images.
Complaints Management
It is a top priority for us to ensure that our business partners are continually satisfied with the services we offer. One of the key principles of our company is to provide our business partners with continuous added value throughout our entire business relationship and to resolve any problems that may arise promptly and in the best way possible. In order to meet this expectation of ourselves, we have put sophisticated complaints-handling policies and procedures in place.
H&A Global Investment Management GmbH:
Investor Protection
Conflict of Interest Policy
As of: September 2024
Best Execution Policy
As of: March 2025
Quality Report 2024 on Top 5 Reporting
As of: March 2025
Top 5 Broker Reporting
As of: March 2025
ESG: Regulatory disclosure obligations
Transparency in the strategies for dealing with sustainability risks
Sustainability risks within the meaning of Regulation (EU) 2019 / 2088 of the European Parliament and of the Council of 27 November 2019 on sustainability-related disclosures in the financial services sector are environmental, social or governance events or conditions that, if they occur, could have an actual or potential material adverse effect on the value of the investment. These effects may have an impact on the net assets, financial position and results of operations of the assets under management.
Sustainability risks are included as a qualitative assessment as part of the general analysis activity by the portfolio’s decision-makers. In the investment process, they are analysed alongside other risk factors within the fundamental analysis, assessed qualitatively and included in the investment decision.
They are analysed according to the individual environmental, social and governance dimensions (‘ESG’). Depending on the available data, the analysis may include content from non-financial reporting, assessments from ESG data providers or adverse media checks. The analysis is subject to the principle of proportionality and the assessment of materiality lies with the portfolio decision-maker.
Developments at European and national level with regard to sustainability risks and the associated requirements for the financial industry are monitored on an ongoing basis. This strategy may be adjusted due to changes in the legal framework and improvements in the data situation and available methods.
Transparency of adverse sustainability impacts at company level
HAGIM does not take PAIs into account at company level.
The products managed and/or distributed by HAGIM that take PAIs into account have so far played a very minor role in HAGIM’s total volume, as PAIs are not taken into account in the vast majority of products. The extent to which they will be taken into account at product level in future depends primarily on the needs of our investors.
In dealing with Article 4 SFDR, HAGIM pursues a proportionality approach. HAGIM also plans to take PAIs into account at company level if the products that take PAIs into account make up a not insignificant proportion of the total volume. This proportion has been set at 10%. As soon as HAGIM takes PAIs into account at company level, this will be done to the extent that the data situation allows at that time. The data situation depends, among other things, on neighbouring regulatory or voluntary disclosure obligations for the investable companies.
HAGIM continues to monitor regulatory developments and developments on the market very closely and will take adjustments in the requirements or on the market into account.
Transparency of the remuneration policy in connection with the consideration of sustainability risks
Employee remuneration is an instrument of business policy and is generally determined by the Management Board. The Management Board is therefore responsible for the appropriate design and implementation of the remuneration system and for avoiding remuneration-related risks. The principles of the remuneration policy must be explained in detail to the Supervisory Board at least once a year. The remuneration policy also applies to the Management Board of HAGIM. The remuneration of the managing directors is determined by the company’s Supervisory Board.
The remuneration policy is in line with the business and risk strategy, the objectives and interests of the company and includes measures to avoid conflicts of interest. HAGIM’s remuneration guidelines have been developed in consultation with the HR department and Compliance and are designed to ensure that the remuneration of relevant persons does not jeopardise customer interests in the short, medium or long term.
Sustainability risks are defined as events or conditions in the areas of the environment, social affairs or corporate governance, the occurrence of which could have an actual or potential material negative impact on the value of the investment. As the remuneration of the portfolio managers is based, among other things, on the performance of the assets under management, i.e. the value of the investments, the alignment of client and employee interests is guaranteed at all times.