Union Investment follows a set of principles and procedures for the benefit of its customers:


Union Investment is an active shareholder that takes a multidimensional engagement approach. By engagement we mean the active involvement of shareholders in influencing a company’s strategy by addressing senior management or the supervisory board directly.
The basis for this is Union Investment’s binding Proxy Voting Policy, which governs voting activities at AGMs.

General Conflict of Interest Policy

Acting in the customer’s interest is the guiding principle that shapes our business relationship with you. This requires us to take appropriate precautions to identify and avoid, or find fair solutions for, any potential conflicts of interest that could arise. Below, we explain our far-reaching precautions.


General Conflict of Interest Policy

Guidelines for responsible investment

Guidelines for responsible investment

We consider sustainability to be a core element of the cooperative principles by which we operate. We have adopted a clear sustainability strategy that provides a framework for responsible action. These guidelines set out the approach that we take to ensure responsible investment.

Guidelines for responsible investment

Best Execution Policy

The best execution policy governs the principles and procedures aimed at securing the best possible outcome in transactions for customers’ portfolios. It also applies to all asset management customers in their capacity as professional clients.

Best Execution Policy

Declaration of conformity of Union Investment

The German Sustainability Code (DNK) contains 20 code criteria and supplementary KPIs (27 GRI or 19 EFFAS indicators) that outline the cornerstones of corporate sustainability. In the declaration of conformity, companies report on how they are meeting the code criteria or explain why they are deviating from them.

Federal Association of German Fund Management Companies (BVI) code of conduct

The BVI code of conduct establishes a standard for the good and responsible handling of investors’ money and rights. It specifies how investment management companies should comply with their legal obligations towards investors and how they should represent the investors’ interests vis-à-vis third parties.
Through reliability, integrity and transparency, investment management companies hope to boost public and investor confidence and better meet their increased information requirements.

The BVI code of conduct is primarily aimed at German investment management companies, but compliance with it is also recommended for foreign companies operating in the German market.

This applies to Union Investment’s companies based in Luxembourg.

BVI Website

Human rights policy statement

The Union Investment Group is one of the largest fund managers in Germany. It is an active asset manager, offering tailored investment solutions for both retail and institutional investors.

Union Investment considers sustainability to be a core element of the cooperative principles by which it operates. Our mission is to focus on the long term and to take a holistic view of the markets, of developments, and of the requirements of our investors. We have adopted a sustainability strategy that provides a framework for responsible action. Respect for internationally recognised human rights is also an integral part of our corporate values and strategy. These rights are inherent in all human beings, and we recognise that they are interrelated, interdependent and indivisible. While states have a duty to protect human rights, we believe that companies have a responsibility to respect human rights.

As a member of the DZ BANK Group, we at Union Investment are committed to taking steps to identify and eliminate any human rights violations in connection with our business activities and in our supply chains. In doing so, we take into account the interests of relevant stakeholder groups and always try to make decisions in such a way that conflicting objectives are disclosed, carefully weighed up and, where possible, resolved.

This policy statement on respect for human rights applies to all companies in the Union Investment Group. It complements the Modern Slavery and Human Trafficking Statement, which is published annually by our subsidiary Union Investment Institutional GmbH.


Human rights policy statement

Inducements according to section 2 (1) of the German Regulation on Investment Conduct and Organisational Rules (KAVerOV) in conjunction with article 24 of Commission Delegated Regulation (EU) No. 231/2013 at Union Investment Institutional GmbH

Dear investor,

We are delighted that your company has chosen products and solutions from Union Investment and shown great confidence in our business. Thank you.

In connection with individual and collective asset management and the exercising of the functions* referred to in annex 1 of Directive 2011/61/EU, our company may receive fees, commission or non-monetary benefits as defined by article 24 of Commission Delegated Regulation (EU) No. 231/2013, from third parties.

Union Investment Institutional GmbH currently receive no inducements.

For further details, please contact the company.

Union Investment Institutional GmbH

  1. 1 * ANNEX I
    1. Investment management functions which an AIFM shall perform, as a minimum, when managing an AIF:
    a) portfolio management
    b) risk management.
    2. Other functions that an AIFM may additionally perform in the course of the collective management of an AIF:
    a) Administration:
    i) legal and fund management accounting services, ii) customer inquiries, iii) valuation and pricing, including tax returns, iv) regulatory compliance monitoring, v) maintenance of unit-/shareholder register, vi) distribution of income, vii) unit/share issues and redemptions, viii) contract settlements, including certificate dispatch, ix) record keeping;
    b) Marketing;
    c) Activities related to the assets of AIFs, namely services necessary to meet the
    fiduciary duties of the AIFM, facilities management, real estate administration activities,
    advice to undertakings on capital structure, industrial strategy and related matters,
    advice and services relating to mergers and the purchase of undertakings
    and other services connected to the management of the AIF and the companies and other assets in which it has invested.

Inducements according to section 5 (2) of the German Investment Code (KAGB) in conjunction with section 70 of the German Securities Trading Act (WpHG) at Union Investment Institutional GmbH

Dear Investor,

We are delighted that you have chosen products and solutions from Union Investment and shown great confidence in our business. Thank you.

In connection with its provision of a service or ancillary service as defined in section 20 (2) numbers 1 to 3 and section 20 (3) numbers 2 and 5 KAGB (e.g. portfolio management or investment advice), the company may receive fees, commission, other cash payments or non-cash benefits, as defined in section 70 (2) sentence 1 WpHG, from third parties. 

Union Investment Institutional GmbH currently receive no inducements.

For further details, please contact the company.

Union Investment Institutional GmbH

Notifications and complaints

To submit information or make a complaint, investors can contact us at:

Union Investment Institutional GmbH
Weissfrauenstrasse 7
60311 Frankfurt/Main
Phone: +49 69 2567-7652
Fax: +49 69 2567-1010

To enforce their rights, investors also have recourse to legal action in the ordinary courts or can seek alternative dispute resolution.

Union Investment Institutional GmbH, an investment management company in accordance with the KAGB, has signed up to the ombudsman service for investment funds of the Federal Association of German Fund Management Companies (‘BVI ombudsman’) and participates in its arbitration proceedings for the resolution of disputes. In the event of disputes relating to provisions in the KAGB, consumers may call on the BVI ombudsman.

Consumers are individuals whose investment in funds is generally unrelated to their professional or freelance employment, i.e. they are acting on their own behalf.

The contact details of the BVI ombudsman are:

Büro der Ombudsstelle
BVI Bundesverband Investment und Asset Management e.V.
Unter den Linden 42
10117 Berlin
Phone: +49 30 6449 0460
Fax: +49 30 6449 04629

Further provisions are set out in the ‘procedural rules’ for the out-of-court settlement of disputes about consumer rights relating to the Federal Association of German Fund Management Companies (BVI). Applications for arbitration must be submitted in writing to the office of the BVI ombudsman.

Further information about the BVI ombudsman and its procedures is available at

You can also complain to the Federal Financial Supervisory Authority (BaFin). This is possible if you have the impression that legal regulations are violated. The BaFin then checks whether the legal regulations are complied with.

Bundesanstalt für Finanzdienstleistungsaufsicht
Graurheindorfer Strasse 108
53117 Bonn

Phone: +49 228 4108-0
Fax: +49 228 4108-1550

The right to seek recourse in the courts remains unaffected by proceedings for the alternative resolution of Disputes.

Tax strategy for the UK

The tax strategy applies to all UK activities of the DZ BANK Group (the London branches of: DZ BANK, DVB BANK SE and its subsidiaries, Union Investment Institutional GmbH and Quoniam Asset Management GmbH).

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