Impact Asset Management GmbH ("IAM"), as an asset manager (external asset management of investment funds), is obliged to set up and publish a participation policy pursuant to section 185(1)(1) of the Austrian Stock Exchange Act. Pursuant to § 185 para 1 no 2 Austrian Stock Exchange Act 2018, IAM is further obliged to publicly disclose annually how the participation policy has been implemented. As an alternative to these obligations, an unequivocal and reasoned statement may also be publicly disclosed as to why these requirements are not met.
These regulations are fundamentally linked to the procedure in connection with the exercise of influence/voting rights in connection with shareholder status through investments in shares of listed companies. Since IAM mainly uses other investment funds (UCITS target funds) within the scope of the service it mainly provides, the asset management of investment funds, and shares in listed companies are only part of IAM's service to a very limited extent, IAM does not have any significant influence or possibility to participate in decisions of listed companies.
Accordingly, IAM refrains from fulfilling the requirements of section 185 of the Austrian Stock Exchange Act 2018.