Conflicts of interest policy


As an asset management company (Kapitalverwaltungsgesellschaft), HANSAINVEST Hanseatische Investment-GmbH (“HANSAINVEST” for short) manages its investment funds exclusively in the interests of investors and performs all activities honestly and with the required expertise, care and diligence. We always act honestly and in the best interests of the investment funds we manage, the investors and market integrity.


 Potential conflicts of interest may arise between

  • HANSAINVEST (or other companies from the SIGNAL IDUNA Group including directly or indirectly closely related units) and the managers or employees of HANSAINVEST and the investment funds managed by HANSAINVEST, the investors of these investment funds or customers of HANSAINVEST or
  • The investment funds managed by HANSAINVEST or their investors and another investment fund managed by HANSAINVEST or the investors in this investment fund or
  • The investment funds managed by HANSAINVEST or their investors and another HANSAINVEST customer or
  • HANSAINVEST customers.

 Conflicts of interest are also possible between 

  • HANSAINVEST and third parties it has engaged such as financial portfolio managers or asset managers, depositary banks and external assessors. 

For example, these could result in the following material conflicts with the interests of investment funds we manage or their investors in connection with 

  • Engaging closely related companies and persons (in particular SIGNAL IDUNA Group companies),
  • Personal relationships between the management or employees and these related persons,
  • Participation of the management or employees in supervisory or advisory boards or the management of other companies,
  • Personal transactions with assets that may be held in investment funds managed by HANSAINVEST by managing directors or employees of HANSAINVEST,
  • Incentive systems for managers or employees,
  • Giving or receiving gifts


To prevent extraneous interests influencing HANSAINVEST’s business activities, we require our employees to commit to upholding high ethical standards.

We expect our employees, managers and Supervisory Board members to exercise care and honesty, act lawfully and professionally and observe market standards at all times. The focus here is always on the interests of investors and the investment funds managed by HANSAINVEST. The standards to be observed are set out in internal regulations and work instructions. As well as binding standards for maintaining ethical conduct, these primarily include regulations to prevent transactions through the abuse of confidential information, avoid conflicts of interest and ensure HANSAINVEST’s professional independence.

In addition, an independent, permanent compliance organisation was set up that is responsible for identifying, avoiding and managing potential conflicts of interest, as well as supporting and monitoring employees when implementing these standards in day-to-day business. The compliance organisation makes decisions in line with statutory provisions, regardless of the instructions and interests of third parties. All employees are obliged to immediately report any transactions or situations that could lead to a conflict to the compliance office. In coordination with the managing directors responsible, the compliance office decides on how to proceed in terms of the investment fund and its investors.

The following individual measures are also in place: 

  • Establishment of confidentiality areas by way of physical/organisational separation between department and business units in order to prevent the abuse of confidential information and the separation of responsibilities to avoid the exertion of inappropriate influence (creation of information barriers, “Chinese walls”), where necessary and appropriate,
  • Regulations on giving and receiving gifts and benefits and disclosure of these,
  • Regulations on performing secondary activities and the establishment of remuneration principles that do not create incentives to put personal interests above the interests of the investment funds under management, investors or customers,
  • Regulations for employees’ personal transactions, including reporting to the compliance office, for employees for whom conflicts of interest may arise in connection with their work (known as relevant employees),
  • Regulations on compliance with insider trading law,
  • A private watch list is maintained to monitor sensitive information and to prevent the abuse of insider information for financial instruments with confidential information,
  • A restricted list is maintained that can be viewed by all employees, one purpose of which is to rule out potential conflicts of interest through business bans,
  • Establishment of remuneration systems,
  • Contractual obligation of the outsourced portfolio manager to avoid conflicts of interest,
  • Careful selection and regular (further) training of employees,
  • A Conflicts of interest policy (principles for accounting for investor interests) is prepared and regularly updated,
  • Best practice principles for acquiring or disposing of financial instruments,
  • Participation in the SIGNAL IDUNA Group’s compliance committee. 

If the organisational and contractual arrangements are not sufficient to avoid the risk of jeopardising the interests of investment funds managed by HANSAINVEST and their investors, HANSAINVEST informs the investors of the nature of the conflict and its causes prior to commissioning and in line with statutory requirements using a permanent data carrier or online. Based on this information, the investor can make a decision on investing in the investment fund managed by HANSAINVEST.

 Updated: May 2021