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 below; the concrete form of our participation policy is stated in each case and published at

  • Monitoring those companies in which investments have been made with regard to important matters such as financial and non-financial performance, capital structure, risk, strategy, and social and environmental impact and corporate governance.

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 first pre-screening, taking into account the respective investment policy. 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.

  • Maintaining dialog with companies in which investments have been made.

Contacting investor relations specialists or, less frequently, management at investor conferences or company presentations, focusing on financial details and, at most, strategic considerations. 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.

  • Exercise voting and other rights associated with shares.

For asset management, especially in the case of discretionary mandates, the alignment of the exercise of voting rights with the client's wishes applies.

  • Cooperation with other shareholders.

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.

  • Communication with the relevant stakeholders of the investees.

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.

  • Dealing with actual and potential conflicts of interest.

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 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.

Change history:

Version Valid from:  Subject matter to change:  Amended by:
Version 1 25.11.2020 New publication of document Anja Ergard
 Version 2 01.05.2022 Adaption of ESG criteria, formal adjustments

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