Participation Policy of FAME Investments AG
Pursuant to § 185 BörseG 2018 para. 1 line 1, asset managers are obliged to develop and publish a participation policy in which it is stated how they allow shareholders to participate in their investment strategies. This applies to points a) to f) below; the concrete form of our participation policy is stated in each case and published at www.fameinvestments.at.
This is done as part of the normal investment process of FAME Investments AG. Beyond pure financial ratios or balance sheet analysis, potential investments are analyzed in detail after a possible pre-screening, taking into account the respective investment policy. In addition to the strategic orientation and qualitative aspects, ESG criteria are also taken into account in the investment decision, especially for those mandates that explicitly require this, for example because they are certified with an eco-label such as the Austrian Environmental Standard (UZ) 49. Investments made are monitored on an ongoing basis as part of the observation of market developments, both by means of up-to-date business reporting and via the financial press and relevant database services such as Bloomberg and Refinitiv. In addition, information from custodian banks is also used for corporate actions such as dividend payments, capital increases, payment defaults and the like.
Contacting investor relations personnel or, less frequently, management at investor conferences or company presentations, focusing on financial details and, at most, strategic considerations. Greater engagement on ESG criteria is envisaged, primarily of course with those mandates that also take such an approach. In case the proxy is granted to FAME Investments AG, the participation in general meetings and thus also a dialogue with the shareholdings is possible in this way.
For asset management, especially in the case of discretionary mandates, the alignment of the exercise of voting rights with the client's wishes applies.
In principle, this refers to the possibility of informal exchanges with other shareholders of an investee company, whereby such exchanges would be limited to non-material details of corporate policy in addition to corporate governance and would in no way be aimed at various agreements.
Here, particular attention is paid to sensitization with regard to the possible disclosure of insider information, as situations can arise here in which sensitive information on internal company details is also unintentionally passed on by various corporate bodies. We are aware of potentially conflicting interests and, if necessary, involve Compliance in any such situations that may arise.
By acting prudently, we avoid the occurrence or development of potential conflicts of interest from the outset. However, if such a situation cannot be avoided entirely, for whatever reason, we will seek to minimize actual or potential conflicts of interest with the assistance of Compliance and, if necessary, seek a solution in the interests of our investors.
Pursuant to § 185 BörseG 2018 para 1 line 2, asset managers must publicly disclose once a year how they have implemented their participation policy. This includes a general paraphrase of voting behavior, an explanation of the most important votes and the use of voting advisors. This excludes votes that are insignificant due to the subject matter of the vote or the level of participation in question. As we have not exercised voting rights to date, this point is not relevant to us. However, as soon as we make use of this right, we will of course publish any voting behavior at www.fameinvestments.at. This also applies mutatis mutandis to any use of voting advisors, which would only occur to a significant extent in the case of international shareholdings.