Exercise of Shareholder and Creditor Rights
Pursuant to Art. 32, German Investment Act (InvG), as well as the code of conduct published by the BVI Federal Investment and Asset Management Association, Commerz Real Investmentgesellschaft mbH (CRI) exercises the voting rights arising from the pool of segregated assets under its management without regard to third-party interests exclusively in the interest of the pool of segregated assets and of preserving the integrity of the market. To this end, CRI supports any measure designed to enhance the value of the shares associated with the pool of segregated assets sustainably and long-term, and votes against any measure incompatible with this objective. For CRI, the central deciding factor in exercising the voting right is therefore the investor interest of the respective pool of segregated assets and the integrity of the market (cf. Art. 9 II, InvG) without regard to third-party interests.
The voting rights are principally exercised by CRI itself. The voting behaviour of CRI regarding the corporate divisions addressed in the agenda items is based on criteria of a transparent and sustainable corporate governance policy. The voting behaviour is guided by the following principles, among others:
- Strengthening the Shareholder or Creditor Rights: Each shares should principally convey identical voting rights.
- Supervisory Board: The members of the supervisory board should be competent and independent, and not be exposed to conflicts of interests.
- Appropriate Remuneration Structures: The remunerations of executive committees should be transparent, performance-based, and reflect the company's long-term development.
- Objectivity of Auditors: Auditors commissioned to review the annual accounts must not be dependant on the company reviewed, and must be paid transparent and adequate remuneration.
- Corporate Transparency: Reporting should ensure the highest possible degree of transparency concerning the business situation and performance.
- Dividend Policy: Dividends should reflect the financial result of the company, and should be on a level with industry peers.
Protection against Economic Crime
Money Laundering / Compliance
Every other German company is threatened by economic crime. Just recently, a number of cases became public knowledge. Commerz Real Group has put in place comprehensive safeguards to protect clients and employees from fraudulent activities, and to keep products and processes from being misused for fraudulent activities or economic crime.
Through our Corporate Governance, we have pledged ourselves to integrity in our interaction with each other and with our clients. We therefore have a strict cross-divisional commitment to prevent fraud before it even occurs. This means for us to be receptive for information and to give clients, employees, and third parties the opportunity to draw our attention to possibly fraudulent intent.
Investigations have shown that third-party tips can often contribute to the detection of economic crime. Commerz Real Group, too, has for years relied on proven channels and contact options, e. g. via the Compliance or Internal Audit departments. In addition, we – like our parent company, Commerzbank AG – set up a system that clients, employees, and third parties may use any time to notify us online of suspected economic crime. To this end, we use the internet-based Business Keeper Monitoring System (BKMS).
Anyone wishing to use the system to notify us of suspicious activity has the option to submit the information anonymously. However, since we strive for open communication with clients, staff, and third parties, we would like to encourage you to state your name when notifying us. Also, please be sure to create a mail box within the system so we can contact you in case we have questions. We will in any case treat your information strictly confidentially.
The sole purpose of the system is to uncover economically criminal activities within our company. Misusing the system for other purposes may qualify as a criminal act.
Naturally, there is also the option to contact the Compliance Office and the Internal Audit department or any other contact you trust directly.