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Sparda-Bank Muenchen eG

PRI reporting framework 2020

You are in Strategy and Governance » Investment policy

Investment policy

SG 01. RI policy and coverage

New selection options have been added to this indicator. Please review your prefilled responses carefully.

01.1. Indicate if you have an investment policy that covers your responsible investment approach.

01.2. Indicate the components/types and coverage of your policy.

Select all that apply

Policy components/types

Coverage by AUM

01.3. Indicate if the investment policy covers any of the following

01.4. Describe your organisation’s investment principles and overall investment strategy, interpretation of fiduciary (or equivalent) duties,and how they consider ESG factors and real economy impact.

Our legal status as a cooperative bank requires us to work in the best interest of our stakeholders, which are called "Genossen". We do not  maximize our profit, we maximize our ability to survive the next 100 years and the ability to fulfill our cooperative service mandate.

We therefore pursue a very conservative investment policy. Loss avoiding is one of our most important principles. We believe that seldom gains in previous - or even current - business periods can cover the potential losses that can occur. We do not like the theory of expectes losses, that can be calculated and must be overcompensated by a higher nominal yield. We believe that putting our money in safe places is the best way to safeguard steady and appropriate returns. "Safe places" does not necessarily mean "risk free". We concentrate on risks that we believe we are able to manage.

We strongly believe that there is a positive correlation between acting sustainably and being economically successful. Most of the economically catastrophic events that make big companies fail can be attributed to unsustainable behaviour.

We therefore act sustainably and follow those, who do the same.

01.5. Provide a brief description of the key elements, any variations or exceptions to your investment policy that covers your responsible investment approach. [Optional]

01.6. Additional information [Optional].


SG 01 CC. Climate risk (Private)

SG 02. Publicly available RI policy or guidance documents


02.1. Indicate which of your investment policy documents (if any) are publicly available. Provide a URL and an attachment of the document.






02.2. Indicate if any of your investment policy components are publicly available. Provide URL and an attachment of the document.

02.3. Additional information [Optional].

The audit opinion on our "Gemeinwohl-Bericht" can be found at (in German language).

The policies, formalised guidelines, etc. mentioned in SG 02.1 and 02.2 in our "Gemeinwohl-Bericht" (which best translates into "report on public welfare") are absolutely mandatory for the whole staff of our bank. We have mandatory operating instructions in power which are fundamental for all our business operations. Our operating instruction Nr. 61.00.02. 02 "Eigenanlagenstrategie" (=Strategy of our own investments) Nr. 2.1 says (translation follows) "Unsere Eigenanlagen müssen Nachhaltigkeitskriterien genügen, die in einem separaten Dokument, dem Gemeinwohl-Bericht näher bestimmt sind. Wir berichten über die Nachhaltigkeit unserer Eigenanlagen im Rahmen der Gemeinwohl-Auditierung, des Reportings an die UNPRI, sowie auf unserer Homepage." Translation: "Our own investments must comply with sustainability criteria outlined in the 'Gemeinwohl-Bericht'. We report on the sustainability of our own investments in our auditing of the Gemeinwohl-Ökonomie, the reporting to the PRI and on our homepage."

(Link to our homepage, with information on our investments that is - in addition to our "Gemeinwohl-Bericht" - also publicly available and regularly updated:

SG 03. Conflicts of interest

03.1. Indicate if your organisation has a policy on managing potential conflicts of interest in the investment process.

03.2. Describe your policy on managing potential conflicts of interest in the investment process.

We try to avoid these conflicts wherever possible.

We have setup strict Chinese walls that make sure that own investment activities and retail business activities are kept separated. Consequently possible conflicts should not occur at all. The MIFID-regulations force banks to make respective operations transparent for the public.  

Should a conflict occur nevertheless, we grant highest priority to the interest of our retail banking clients.

Should a conflict occur within our own investment activities, we discuss the matter in our monthly meeting with the management board, the heads of accounting and controlling departments and treasury. We have a best-practice process in power for that.




03.3. Additional information. [Optional]

SG 04. Identifying incidents occurring within portfolios

04.1. Indicate if your organisation has a process for identifying and managing incidents that occur within investee entities.

04.2. Describe your process on managing incidents

We have set up a monitoring tool based on Bloomberg. When specific indicators score below pre-defined thresholds, the issue is set on the agenda of the next monthly meeting with the management board. Possible consequences could be selling the portfolio company, exercising engagement via our service provider, or waiting for improvement in the near future. As we have stern ESG policies in power, this is very unlikely to happen.