For us, corporate governance stands for the transparent, responsible and purposeful implementation of international and national regulation as well as for our values and principles.

The guidelines of Aquila Capital are regularly reviewed based on the development of national and international standards and regulatory requirements and are adapted accordingly. When performing their tasks, the management board and board of directors as well as the employees of Aquila Capital fully identify themselves with the corporate governance guidelines.

Best Execution policy

As a capital management company, Aquila Capital Investmentgesellschaft mbH is obliged to provide investors with adequate information regarding the best execution of client orders. 

For more information, please refer to the mandatory disclosures and access the Principles of best execution document under the "Downloads" area.

Principles of Dealing with Conflicts of Interest

At a capital management company with a wide-ranging client base, numerous circumstances can lead to potential conflicts of interest. To ensure the protection of our clients, we strictly adhere to legal regulations and industry guidelines, implementing several systems and controls aimed at effectively identifiying, managing and mitigating any potential conflicts of interest.

For more information, please refer to the Aquila Capital Conflicts of Interest Policy.

Information ABOUT THE PROCEDURE FOR COMPLAINTS

The satisfaction of our clients is of utmost priority to us. For this reason, we have established a point of entry for complaints which you can turn to if you wish to provide feedback. Alongside the compliance of legal guidelines, your comments are valuable as they enable us to continuously optimise our processes.

For more information, please refer to the Information about the Procedure for Complaints Aquila Capital Investmentgesellschaft.

Rules of proper conduct

Employees of Aquila Capital are guided by the laws, regulations, policies, and standards that apply to our industry and profession. Yet we aim to advance our actions beyond mere compliance with local laws and regulations to ensure the long-term prosperity of all our stakeholders – employees, suppliers, contractors, partners, clients, local communities, and society at large. Since most laws and guidelines do not cover all spheres of our influence, we also have our own set of values. We developed a Code of Ethics to formalise our expectations and standards for the way we do business as Aquila Capital employees. 

Remuneration Policy of Aquila Capital

The Remuneration Policy is intended to avoid inappropriate sustainability risks from the environmental, social and corporate governance areas. To this effect, each employee must comply with the Company’s ESG Policy. If an employee does not comply with law or regulatory or supervisory requirements or breaches internal requirements such as the Company’s compliance principles or rules, applicable group or company guidelines (for example, the Code of Ethics or the ESG Policy) or corporate values of the Company committed by the employee in his/her work will factor into the annual calculation of bonuses and commissions. Any such conduct may lead to substantial reductions in or full loss of a variable compensation. 

Compliant to the Alternative Investment Fund Manager (AIFM) policy, please find mandatory disclosures concerning remuneration here.

Whistleblowing system of Aquila Capital

In line with Aquila Capital's organisational culture of transparency and trust, the Compliance department has put a Whistleblowing system in place where information about any type of misconduct in a work-related context can-and-should-be reported under the protection of anonymity.    

The whistleblowing system covers all subsidiaries of Aquila Capital and is available to our employees as well as third parties worldwide, at any time. By reporting suspicious and/or illicit activities, you can help identify and prevent organisational misconduct, malfeasance, and thereby strengthen our company’s corporate governance. 

Aquila Capital’s whistleblowing system is facilitated by the German legal advisory firm BDO Legal Rechtsanwaltsgesellschaft mbH (“BDO”) with the following possible channels of reporting complaints:  

Complaints and reports will be reviewed by the BDO ombudsperson. The ombudsperson will inform the assigned contact person from the Aquila Capital Compliance department about the content of a report, if it is compliance relevant and requires further investigation for resolution. The anonymity of the whistleblower will be upheld – your identity will only be disclosed with your prior consent. 

Confidential treatment of a complaint is guaranteed to ensure protection of whistleblowers. However, please be conscious that if the whistleblowing system is deliberately abused to report unjustified, unsubstantiated assumptions, this could be subject to further verification. 

For information on Aquila Capital's data processing under the Whistleblowing system, please see our Privacy Policy.