Possible conflicts of interest

Incrementum AG is an owner-managed company specializing in the provision of highly professional financial services. The constant respect for and the interests of the customers, as well as their fair treatment, have the highest priority. Incrementum AG seeks to permanently protect and reconcile the interests of its customers, shareholders and employees. Nevertheless, conflicts of interest in a company providing different financial services cannot always be completely ruled out. In accordance with the statutory provisions, Incrementum AG therefore informs about its precautions for dealing with potential conflicts of interest.

Conflicts of interest may arise between the companies, the management, the owner, the employees or other persons associated with Incrementum AG and their customers or between their customers.

The consistent customer orientation in the corporate culture is the central instrument to avoid influencing non-judgmental interests in consulting, order execution, asset management or other services. Great care in selecting employees, commitment to the highest standards and respect for international market opportunities help Incrementum AG to put customer interests at the center of its actions.

Organizational measures to avoid conflicts of interest

Incrementum AG has taken the following measures to prevent potential conflicts of interest:

• Create a compliance function that is responsible for identifying, avoiding and managing potential conflicts of interest and taking appropriate measures where necessary;
• Establishing and maintaining a client and risk-oriented organization that ensures the financial and regulatory integrity of the Company at all times;
• Organizational measures to safeguard customer interests in investment advice and asset management;
• Arrangements for the acceptance and granting of benefits and their disclosure;
• The delineation of business areas and functions from each other and simultaneous control of the flow of information among each other (as far as this makes organizational sense);
• Arrangements concerning the treatment and disclosure of proprietary transactions in financial instruments of employees and institutions;
• Rules governing the acceptance of gifts and other benefits by employees and organs;
• When executing orders, Incrementum AG acts in accordance with its Best Execution Policy or the instructions of the client;
• The remuneration system is designed to prevent conflicts of interest, including those related to sustainability risks. It is intentionally neutral, meaning there are no incentives to either take on or avoid specific sustainability risks. At all times, the interests of the client are prioritised within our remuneration framework. Consequently, there are no incentives to acquire financial instruments, nor are there incentives for frequent buying and selling of financial instruments;
• The company does not exercise any shareholder rights within the meaning of art. 367h par. 1 fig. 2 and 4 PGR based on participation in the companies in which the company is invested within the scope of asset management mandates. The participation policy of Incrementum AG can be found here;
• Ongoing training of the employees.

Disclosure of potential or actual conflicts of interest

• Conflicts of interest that can not be avoided and which may arise will be disclosed to the clients concerned prior to a general contract, special transaction or advice.
• There are no retrocession agreements or other agreements between Incrementum AG and banks or other third parties regarding partial reimbursement on custody fees, stock exchange and trustee commissions, brokerage fees or other fees. For the customer, the (special) conditions agreed with the respective bank are used.
• For efficient portfolio management, Incrementum AG also uses investment funds that are launched and managed by Incrementum AG. When using such products, no double charge of the customer.
• The selection of funds or other products – be it directly in the customer portfolio or indirectly via investment funds managed by Incrementum AG – is carried out exclusively on the basis of customary, qualitative and quantitative selection criteria (best-in-class approach). All purchases of funds and other products are always made in the best interests of the client, whenever possible at net interest rates or against reimbursement of inventory commissions or closing commissions in favor of the client or fund.
• Incrementum AG receives from other service providers, e.g. Brokers, gratuitous or discounted payments in connection with securities transactions, such as financial analysis or other informational material, training and, in part, technical services and equipment for accessing third-party information systems. The receipt of such donations is not directly related to the services rendered to the customer. Incrementum AG uses these grants to provide its services in the high quality claimed by the customer and to continuously improve them.
• Partly, Incrementum AG pays success-based commissions and fixed fees to tied or independent intermediaries who supply Incrementum AG with or without reference to a specific business to customers or individual transactions. In addition, tied agents may also receive direct payments from third parties, in particular, fund companies and securities issuing houses, in addition to the agency fees paid by Incrementum AG.
• Financial analyzes prepared or disseminated by Incrementum AG are also inform about relevant potential conflicts of interest.