On the occasion of the EU consultation on the revision of the CSR Directive, Deutsches Aktieninstitut advocates harmonizing the various regulations on sustainability reporting. Introducing additional reporting requirements should be avoided. Instead, the EU Commission should review the impact of the various reporting requirements (Taxonomy Regulation, TCFD) that have just been adopted. Additional reporting requirements should only be introduced after a thorough cost-benefit analysis. If there ...

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On the occasion of the consultation of the German Federal Government Sustainable Finance Council’s Interim Report, Deutsches Aktieninstitut has criticized a lack of confidence in market-economical solutions when it comes to the transformation process towards a more sustainable economy. In addition, Sustainable Finance-initiatives should be launched and promoted on the European level in order to prevent competitive distortions within Europe. The materiality principle has to remain the ...

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On the occasion of the trilogue negotiations on the EU taxonomy, Deutsches Aktieninstitut expressed its concerns regarding the design of the taxonomy in a letter to the Permanent Representation of Germany to the European Union. Deutsches Aktieninstitut rejects the extension of the scope to all financial products as proposed in the compromise. If the scope is extended, entire branches of industry could be cut off from financing. The compromise proposal does not sufficiently take into account ...

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On the occasion of the consultation on Sustainable Corporate Governance held by the EU Commission, Deutsches Aktieninstitut expressed its concerns about the consultation questionnaire and the consultation procedure in a letter to DG Justice. Some of the policy measures mentioned are unclear: for example the proposal that companies are obliged to have a general public benefit and to follow a statute issued by an office. In several sections, the questions seem to be more about the ...

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In the framework of the hearing of the Finance Committee of the German Bundestag, Deutsches Aktieninstitut commented on Sustainable Finance. The complexity of the planned taxonomy specifications will present companies in the financial and real economy with major challenges. Under no circumstances can the result of the taxonomy be that entire branches of industry are cut off from financing by exclusion or excessively strict requirements. The Deutsche Aktieninstitut therefore rejects the ...

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Digitization, climate change and global trade conflicts: only together will politics and the business community be able to solve the pressing issues of our time. On the occasion of the start of the new term of office of the EU Parliament and the upcoming inauguration of the new EU Commission, the paper "Restarting Europe" of Deutsches Aktieninstitut focuses on topics such as the Capital Market Union, strengthening the competitiveness of European companies and the path to a sustainable economy.

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Deutsches Aktieninstitut participates in the consultation on the taxonomy report of the Technical Expert Group (TEG). Deutsches Aktieninstitut demands that all sectors and industries affected by the taxonomy be included in the debate. The focus on the company perspective is essential for a widely accepted taxonomy. In addition, a practicable taxonomy requires a holistic and comprehensive approach that fits into the present European legal framework.

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In the context of the revision of the German Sustainability Code (DNK), Deutsches Aktieninstitut opposes additional reporting and documentation requirements for companies. When defining materiality, flexibility and proportionality should be the guiding principles. Deutsches Aktieninstitut takes a critical view of a description of how companies have identified the key issues and risks of their sustainability strategy. A detailed industry-specific specification of key topics and indicators should ...

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On the occasion of the EU consultation on a review of the non-binding guidelines for the European CSR-Directive, Deutsches Aktieninstitut has pointed at the necessity of adopting a proportionate and realistic framework on climate reporting not confronting companies with a mission impossible. In particular the reporting of Scope 3 emissions in accordance with the Greenhouse Gas Protocol is presently unable to render reliable results. The same applies for the concept of Scenario-Analyses as ...

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After the European Parliament’s decision to postpone the joint vote of the ECON and ENVI committees on the EU Commission’s proposal for a sustainable finance taxonomy, Deutsches Aktieninstitut has again hinted the Committee-members at the concerns of listed companies. While Deutsches Aktieninstitut generally welcomes the EU Commission’s legislative proposal, it opposes the parliamentary position of extending the taxonomy’s scope of application as well as the promotion of a “green” ...

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Deutsches Aktieninstitut supports the overarching aims of Commission’s Action Plan on Sustainable Finance. However, we do see some legislative plans and practical transposition-measures as problematic. Our concerns relate among others to the composition of the ‘Technical Expert Group on Sustainable Finance’ (TEG) in which industrial companies are clearly underrepresented. In addition, we see the absence of addressing conflicts of interests between different ESG-goals as well as a certain ...

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In its response to the questionnaire on the early recommendations of the High Level Expert Group on Sustainable Finance, Deutsches Aktieninstitut underlines its support for and the importance of a sustainable economic development, to which also the financial system has to contribute. The current debate should, however, be led more balanced and also taking into account the role of the legislator and its responsibility for policy actions, e.g. as regards the environment, in the first place.

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The Deutsche Aktieninstitutwelcomes the opportunity to comment the issue finches for the non-binding guidelines on non-financial reporting. The Commission is supposed to present the guidelines in order to facilitate the disclosure of non-financial information for undertakings. Therefore it is important that the guidelines will be finalized as soon as possible so companies, especially those that will report non-financial information for the first time, can get the necessary ...

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In its comments on the ministerial draft statute for transposing the CSR-directive into German law, Deutsches Aktieninstitut welcomes the freedom of choice for companies to prepare a separate non-financial report instead of the non-financial statement. However, the plan to add consumer issues to the non-financial reporting obligations, should not be pursued. Also the concept that all non-financial information have to be submitted within the non-financial statement creates problems. 

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Regarding the implementation of the CSR-Directive Deutsches Aktieninstitut pleads not to include small and medium sized enterprises or additional reporting aspects but to implement the directive one-to-one. Clarifications regarding the rules set out in the directive should be left to the European legislator, who can enact the non binding guidelines mentioned in the directive if considered appropriate.

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In its comments Deutsches Aktieninstitut supports the European Commission’s initiative on building a Capital Markets Union. Further to the steps proposed by the Commission the demand-side of capital markets should, however, be addressed more precisely. This applies especially to the aspect of corporate finance. In addition, a cumulative impact-assessment of the regulatory initiatives launched in the aftermath of the financial crisis is necessary in order to identify and remove barriers for ...

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In the political guidelines for the next EU Commission Jean-Claude Juncker pledges to create a European Capital Markets Union in order to improve the financing of the European economy and in order to further integrate capital markets. This paper lays down Deutsches Aktieninstitut’s perspective on what should be the guiding principles of a proper functioning Capital Markets Union. Our key message is that the perspective on capital markets regulation has to be changed: capital markets, if ...

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In its answer to the Commission´s Online Consultation Deutsches Aktieninstitut emphasizes that after having adopted the Directive on disclosure of non-financial information no more legal steps by the Commission are necessary. Insteadthe EU should raise the awareness for the importance of CSR by enhancing market reward for CSR. From the point of view of Deutsches Aktieninstitut the main challenge to-be for the EU policy on CSR is to create an International Fair Level Playing Field in order to ...

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Institutional investors increasingly integrate environmental, social and governance (ESG) into the assessment of business and strategy of portfolio companies. This trend is documented in this survey conducted by Deutsches Aktieninstitut and Rothschild & Co. It is based on interviews with institutional investors managing a total of 14.4 trillion assets. A high number of original quotes from different investors allows readers to form an own opinion.

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On the occasion of the upcoming German Presidency of the Council of the European Union, Deutsches Aktieninstitut demands that Germany should put the Capital Market Union at the top of its political agenda. Strong capital markets for financing companies are crucial, especially in times of crisis.

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Besides the usual financial criteria, environmental and social topics, as well as corporate governance, are becoming ever more important to institutional investors when valuing companies and making investment decisions. A study released today by Deutsches Aktieninstitut and Rothschild & Co affirms this trend. The study “ESG from the perspective of institutional investors – what listed companies should know” is based on extensive interviews with 18 international institutional investors, ...

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At the traditional Brussels reception of Deutsches Aktieninstitut the new EU Commissioner for Financial Stability, Lord Hill, and Markus Ferber, MEP, delivered speeches to more than 200 guests. Werner Baumann, President of Deutsches Aktieninstitut, outlined the expectations of the German economy on the European legislator and presented the latest positions paper of the institute „The Road to Growth: Setting Capital Markets Regulation Right”. 

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