Information on handling potential conflicts of interest

Asset management companies seek to protect and reconcile the interests of their customers, shareholders and employees. Nevertheless, conflicts of interest in asset management companies that provide their customers with a variety of high-quality financial services cannot always be completely ruled out. In accordance with Article 20 of the German Asset Management Act (AMA) and Article 12b of the Asset Management Ordinance (AMO), we inform you below about our arrangements for handling potential conflicts of interest.

Conflicts of interest may arise between our Company, other companies in our Group, our management, our employees, our contractually bound agents or other persons connected with us and our customers or among our customers.

For example, we and our employees have committed ourselves to high ethical standards in order to prevent non-material interests from influencing, for example, advice, order execution, asset management or financial analysis. We expect diligence and honesty, lawful and professional action, the observance of market standards and, in particular, the consideration of the Customer’s interest at all times.

In order to avoid potential conflicts of interest from the outset, we have taken the following measures, among others:

• creating a compliance role in our Company, who is responsible for the identification, prevention and management of potential conflicts of interest and takes appropriate measures, if necessary;

• creation of organisational procedures to safeguard customer interest in investment advice and asset management, e.g. through approval procedures for new products;

• arrangements for the acceptance and granting of benefits and their disclosure;

• delimitation of business units from each other and simultaneous control of the flow of information between each other (creation of confidentiality areas);

• all employees, who may experience conflicts of interest in the course of their work are identified and obliged to disclose all their transactions in financial instruments;

• a regulation regarding the proprietary business of our bodies and employees;

• rules governing the acceptance of gifts and other benefits by our employees;

• when executing orders, we act in accordance with our best execution policy or the instructions of the Customer;

• higher fee income does not automatically lead to more wages;

• ongoing inspection of all transactions carried out by our employees;

• ongoing training of our employees.


We will disclose any conflicts of interest that cannot be avoided to the affected customers before a deal or a consultation.

We would like to draw your attention to the following points:

• As an Asset Manager, ICM AG invests wholly or partly in products for which ICM AG is responsible as an investment consultant and/or initiator.

• We receive free grants from other service providers in connection with our securities business, such as financial analysis or other informational material, training and, in part, technical services and equipment for accessing third-party information and distribution systems. The receipt of such benefits is not directly related to the services rendered to you; we use these grants to provide and continually improve our services to the high quality demanded by you.

• Partly, we pay success-based commissions and fixed fees to tied agents or independent agents who, with or without reference to a specific business, provide us with 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 us.

• We also provide information on relevant potential conflicts of interest in financial analyses, prepared or distributed by us.

At your request, we will provide you with more details about these principles.