For our clients
We perceive the impending transformation of the economy both as a challenge and as an opportunity. To assist our clients along this process, we are continuously expanding our range of advisory services and products to include sustainable solutions – both in the lending business and in the asset management field.
The transformation towards a sustainable economy is a mission for the whole of society, a challenge to which we want to make an active contribution. Our business practices promote the 17 UN Sustainable Development Goals (SDGs) in a number of ways, most notably the following:
SDG 7: Ensure access to affordable, reliable, sustainable and modern energy for all
We help our clients with the financing of energy-saving construction and renovation solutions. In addition, we support companies in their renewable energy projects, from small ventures to complex funding arrangements for wind farms and solar parks of various sizes.
In conjunction with public funding institutions, we offer our corporate clients tailor-made solutions to boost efficiency, reduce carbon emissions and, ultimately, maintain their competitiveness. Further information
SDG 12: Ensure sustainable consumption and production patterns
Sustainability plays an important role in our investment and credit consultancy services. Since both lending and investment decisions may entail adverse impacts on sustainability, the bank has established investment and lending policies to mitigate such impacts. Our employees thus screen all loan applications for potential risks with regard to environmental, ethical and social impacts.
Investment consultancy with a vision
Clients who wish to invest in securities may request the inclusion of their sustainability criteria in our investment proposals.
Find out more in the “Sustainability in our investment consultancy services” brochure.
Inclusion of sustainability risks in investment decisions and disclosure of adverse effects
Please find below:
- relevant information pursuant to EU Regulation 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability-related disclosures in the financial services sector (“Disclosure Regulation”).
- relevant information regarding the engagement policy, engagement report and voting behavior of Oldenburgische Landesbank AG pursuant to Section 134b of the German Stock Corporation Act (AktG)
Information pursuant to Art. 3 of the Disclosure Regulation
Aug. 2, 2022: Addition of specific details on the inclusion of sustainability risks in investment consulting and financial portfolio management operations; removal of the respective outlook.
Dec. 30, 2022: Update of the process governing the incorporation of sustainability risks
Jan. 15, 2024: More specific desription of the process governing the incorporation of sustainability risks
This statement describes and explains the strategies OLB applies to incorporate sustainability risks into its investment decision-making processes and its investment and insurance consulting activities. The statement is updated on an ongoing basis and aligned with any progress made in the implementation of sustainability activities.
In its role as a financial market participant and financial advisor, OLB currently includes relevant financial risks in its selection procedures where such risks may have a significant negative impact on the investment or consultancy return. These include, for instance, market price risks, strategic risks and reputational risks.
As a rule, OLB recommends dividing the portfolio into different asset classes, sectors and regions to build an individual opportunity-risk profile (diversification).
As regards the inclusion of sustainability risks in its investment consulting, the bank pursues a strategy whereby sustainability risks are incorporated into the upstream selection of products offered as part of such consulting activities. To this end, the bank works with a recognized external data provider specializing in sustainability risk assessment (currently MSCI ESG Research) and uses this data to routinely assess and review the sustainability risks of the financial products offered as part of its investment consulting services. This process allows for a more objective and independent assessment of sustainability risks.
Alongside diversification aspects, investment decisions for financial portfolio management also take sustainability risks into account in the selection of individual financial instruments. The bank uses a recognised external data provider that specialises in the assessment of sustainability risks (currently MSCI ESG Research). This data is used to assess the sustainability risks of the financial products selected for financial portfolio management, and to monitor compliance with the criteria defined by OLB. This ensures an independent assessment of sustainability risks. The MSCI ESG rating model identifies the sustainability risks on a scale from AAA to CCC that are most important for an industry or sector:
Financial instruments with a very high sustainability risk (MSCI ESG rating "B" and "CCC") are excluded from an investment. The absence of an MSCI ESG rating also leads to exclusion.
For certificates, the sustainability risk is considered at the level of the underlying asset.
Sustainability risks are events or conditions in the dimensions of environmental, social or corporate governance, the occurrence of which could have an actual or potential material negative impact on the performance of investments. Sustainability risks can arise, for example, in the environment dimension through weather events caused by climate change such as heavy rainfall, storms and drought (physical risks) or from the transition to a low-carbon economy, e.g. through increased prices of emission certificates for emission-intensive sectors of the economy or changes in social attitudes and consumption patterns (transitory risks). In the dimension of social issues, these include risks arising from non-compliance with labour law standards and, in the dimension of corporate governance, the occurrence of reputational damage due to violations of anti-corruption rules.
Further information is available in our.
As a tied agent (Section 34d (4) of the German Trade Regulation Act (GewO)/new version: (7) Sentence 1 No. 1), OLB provides insurance consulting and brokerage services exclusively to, and for the account and on behalf of, Allianz insurance companies. In the case of insurance investment product brokering, the relevant company is Allianz Lebensversicherungs-AG.
Information on the strategies that Allianz Lebensversicherungs-AG employs to incorporate sustainability risks into its investment decision-making processes is available.
Information pursuant to Art. 4 of the Disclosure Regulation
Aug. 2, 2022: Addition of specific details on the inclusion of principal adverse impacts (PAI); insertion of subheadings to improve legibility
Dec. 30, 2022: Update of the process governing the incorporation of principal adverse impacts (PAI) on sustainability factors
May 22, 2023: Editorial change
Jan. 15, 2024: Update of strategy at company level
This statement describes and explains the steps OLB takes in its role as a financial market participant and financial consultant in the course of its due diligence to incorporate adverse impacts on sustainability factors (environmental, social and employee matters, respecting human rights, anti-corruption and bribery) in its investment processes and consultancy services. The statement is updated on an ongoing basis and aligned with any progress made in the implementation of sustainability activities. OLB advises clients on financial instruments (e.g. equities or investment funds) as part of its investment consultancy services, or invests in such products as part of its financial portfolio management. In addition, OLB itself also holds a portfolio of highly liquid securities with excellent credit ratings as a liquidity reserve.
Statement on the consideration of principal adverse impacts on sustainability factors in investment advice
Business activities and the activities of companies, industries and countries may have both positive and negative impacts on the environment and society. Principal adverse impacts (PAIs) refer to negative, material or presumably material impacts on sustainability factors which are caused or compounded by, or directly related to, the investment decisions made or the consulting provided by OLB. Sustainability factors include environmental, social and employee matters, respect for human rights and anti-corruption and bribery.
When providing investment advice, the bank incorporates the principal adverse impacts on these sustainability factors as follows: Based on the mandatory information that product issuers or product manufacturers must provide for regulatory purposes, financial products offered to investors are rated on the basis of the efforts undertaken to avoid adverse impacts on sustainability factors in the context of their investments.
Based on the product data, the indicators which are listed in Table 1, Annex 1 of the Regulatory Technical Standards (RTS) of the European Supervisory Authorities (ESA), and are published by the respective manufacturers/issuers, are broken down into five main categories as per industry standard: greenhouse gas emissions, reduction of biodiversity, water pollution, hazardous waste and negative social and employee impacts.
In addition, OLB assesses whether relevant financial products, such as real estate funds, disclose the inclusion of “energy efficiency” and “fossil fuels” indicators in the case of real estate companies.
The broad transparency achieved by using product data to classify brokered investment products according to the corresponding PAIs allows OLB to give substantial consideration to the most important adverse impacts on sustainability factors in its investment consulting.
Statement on principal adverse effects of investment decisions on sustainability factors
Principal adverse sustainability impacts are defined as impacts of investment decisions that have adverse effects on the following sustainability factors:
- Environmental, social and employee matters
- Respecting human rights and
- Anti-corruption and bribery.
To comply with due diligence obligations at the corporate level, aspects of adverse sustainability impacts are also considered as part of OLB's financial portfolio management. For this purpose, data on the financial instruments are collected with regard to their sustainability in the dimensions of environmental, social and governance. The information needed for this purpose is provided by a recognised external data provider that specialises in sustainability analyses (currently MSCI ESG Research).
The legal framework is derived from Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability-related disclosures in the financial services sector (hereinafter referred to as the "SFDR").
However, OLB does not pursue a sustainability strategy at the product level of its financial portfolio management.
OLB's financial portfolio management does not advertise environmental or social characteristics (financial products under Article 8 of the SFDR), nor does it seek to make sustainable investments (financial products under Article 9 of the SFDR). The investments underlying this financial service do not take into account the EU criteria for ecologically sustainable economic activities.
For financial instruments acquired via financial portfolio management, the main adverse sustainability impacts are determined, which are based on the main adverse sustainability impacts defined by the legislator. This information is made available on a quarterly basis via the quarterly reporting.
As part of its financial portfolio management, OLB may invest in stocks or bonds of individual companies, certificates, mutual funds or ETFs. For certificates, the underlying asset or basket of securities (e.g., an index) is considered.
OLB reflects the most important adverse sustainability impacts in the selection of financial instruments solely on the basis of the exclusion criteria defined at the corporate level. At the company level, the share of the following adverse sustainability impacts with respect to the selected financial instruments may not exceed 5% on the basis of market value:
- Activities negatively affecting biodiversity-sensitive areas (in accordance with Annex I Table 1 of the SFDR - Adverse sustainability indicator No. 7)
- Exposure to controversial weapons (anti-personnel mines, cluster munitions, chemical weapons and biological weapons) (according to Annex I Table 1 of the SFDR - Adverse sustainability indicator No. 14)
In addition, at company level, the proportion of the following adverse sustainability impacts resulting from direct investments made in companies (shares or bonds of individual companies) and certificates with a company as the underlying asset is limited to a maximum of 5% based on the market value (investment funds, ETFs and certificates with a basket of securities as the underlying asset are not taken into account):
- Violations of UN Global Compact principles and Organisation for Economic Cooperation and Development (OECD) Guidelines for Multinational Enterprises (in accordance with Annex I Table 1 of the SFDR - Adverse sustainability indicator No. 10)
- Investments in companies without carbon emission reduction initiatives aimed at aligning with the Paris Agreement or independent corporate initiatives (in accordance with Annex I Table 2 of the SFDR - Adverse sustainability indicator No. 4, supplemented by the assessment of independent initiatives of the companies)
Statement on the consideration of principal adverse impacts on sustainability factors in insurance advice
As a tied agent (Section 34d (4) of the German Trade Regulation Act (GewO)/new version: (7) Sentence 1 No. 1), OLB provides insurance consulting and brokerage services exclusively to, and for the account and on behalf of, Allianz insurance companies. In the case of insurance investment product brokering, the relevant company is Allianz Lebensversicherungs-AG. Information on the consideration of principal adverse impacts on sustainability factors in insurance advice by Allianz Lebensversicherungs-AG is available.
Jun. 30, 2023: Initial publication
Jan. 15, 2024: Editorial adaptation of initial publication
Oldenburgische Landesbank AG considers principal adverse impacts of its investment decisions on sustainability factors. The present statement is the consolidated statement on principal adverse impacts on sustainability factors of Oldenburgische Landesbank AG.
Information pursuant to Art. 5 of the Disclosure Regulation
July 11, 2022: Inclusion of qualitative targets for sustainable corporate development in the variable remuneration of executive board members and non-pay scale employees.
April 17, 2023: The targets for sustainable corporate development in the variable remuneration of Executive Board members and non-pay scale employees are no longer purely qualitative; the information in the first indent has been adjusted accordingly.
- A share of 10-15% of the variable remuneration paid to executive board members and non-pay scale employees at OLB is linked to qualitative targets related to sustainable corporate development.
- Remuneration paid to the bank’s employees is not linked to any potential sustainability risks associated with the financial investment products that OLB brokers or issues.
- As a tied agent (Section 34d (4) of the German Trade Regulation Act (GewO)/new version: (7) Sentence 1 No. 1), OLB provides insurance consulting and brokerage services exclusively to, and for the account and on behalf of, Allianz insurance companies. In the case of insurance investment product brokering, the relevant company is Allianz Lebensversicherungs-AG.
OLB’s compensation as an agent is based on commissions (included in the insurance premium) and is not linked to the sustainability risks associated with the brokered insurance investment products. This also applies to the remuneration paid to OLB’s employees.
June 22, 2023: Completion of the information on the occasion of the regular update
OLB provides financial portfolio management services to its clients. However, OLB does not exercise any shareholder rights pursuant to Section 134b (1) AktG on behalf of its clients as part of these financial portfolio management services. OLB defines the mandate entrusted to it by its clients as the professional management of the clients’ assets. In this context, the main focus is on risk-appropriate growth of the clients’ assets. OLB does not regard itself as a legitimate representative of shareholder rights. Apart from this, the bank would not be in a position to do justice to the diversity of its clients’ interests when it comes to exercising shareholder rights.
Our engagement policy has thus been defined as follows:
- OLB does not exercise any shareholder rights within the meaning of Section 134b (1) No. 1 AktG. The bank exercises the right to a share in profits as defined in Sections 60 ff. AktG and to subscription rights in the interests of its clients.
- Important matters relating to the companies within the meaning of Section 134b (1) No. 2 AktG are monitored via the statutory disclosure of information by the companies in their financial reports and ad hoc announcements.
- An exchange of opinions with the company’s corporate bodies and/or stakeholders pursuant to Section 134b (1) No. 3 AktG does not take place.
- Collaboration with other shareholders pursuant to Section 134b (1) No. 4 AktG does not take place.
- In the event of conflicts of interest within the meaning of Section 134b (1) No. 5 AktG, such conflicts will be disclosed to the parties concerned in accordance with the statutory provisions.
- Annual reporting on the implementation of the engagement policy pursuant to Section 134b (2) AktG is not required, as the bank does not exercise any corresponding rights.
- Voting behavior within the meaning of Section 134b (3) AktG is not disclosed as the bank does not participate in any voting.
OLB does not pursue an engagement policy in accordance with Article 3g of Directive 2007/36/EC of the European Parliament and of the Council. For the reasons stated above, the financial portfolio management strategy does not provide for an adjustment of the engagement policy if no reduction in the principal adverse impacts is observed over several reporting periods.
As a universal bank with extensive expertise in the lending business, we are keenly aware of the entrepreneurial, social and societal aspects inherent in loan transactions. Among other factors, our credit specialists also screen loan approvals for potential risks in terms of environmental, ethical and social impacts. Where necessary, the bank involves its compliance, legal and risk management departments and uses questionnaires for a structured assessment of specific industry and sustainability criteria. Depending on the industry under consideration, areas that may require further scrutiny include the regional and social impacts of a project, impacts on biodiversity and species protection, compliance risks and climate change mitigation.
We assess all business and financing requests for compliance with the applicable laws and regulations and only implement them if all requirements are met. In this context, we may subject certain industries to closer scrutiny or exclude them in their entirety. In deviation from EU regulations, Germany, for instance, does not regard nuclear power as a green transitional technology. Among the reasons for this assessment are the unresolved final deposition issue and the unquantifiable health associated with nuclear energy. Consequently, we do not finance projects involving the construction of new nuclear power plants or capacity expansions at existing nuclear power plants.
Moreover, the policies and procedures we use to identify, manage and mitigate credit risk also take the impact of ESG factors on the borrowers’ financial position into account. In the private banking, freelancer and business segments, our property valuations reflect ESG risks in connection with the provision of real estate collateral. In the commercial lending business, ESG risks are identified, analyzed and assessed in a process comprising up to three stages:
Our scoring model employs the following dimensions and criteria to assess ESG risks:
|Greenhouse gas emissions
|Taxes imposed on polluting activities
|Physical and transitory risks
|Employees’ social security
|Adequate remuneration, fair workplace conditions
|Labor law standards, protection against discrimination
|Social risks arising from government policies and changes in the market environment
|Legally compliant corporate governance, business ethics
|Governance risks arising from government policies and changes in the market environment
Responsible approach to clients facing repayment problems
To secure long-term business relationships, we employ numerous safeguards to pre-empt any overspending by borrowers. Prior to granting a loan, for instance, we check the borrower’s material debt service quality (including a possible stress scenario). In the case of product deals, we outline the options for integrating a complaints management system, e.g. in the context of a withdrawal right system.
When it comes to customizing financing arrangements, we offer a variety of hedging instruments. In the mortgage financing segment and the installment loan financing segment, for instance, we provide detailed information on the options and requirements relating to financial protection against the risks of unemployment, occupational disability and other risks.
In line with the EU Mortgage Credit Directive, we offer a range of advisory services for clients associated with relevant warning indicators. In addition, we have credit monitoring systems in place that help us identify and address borrowers who are expected to experience financial difficulties. If such financial problems actually arise, we will work with the borrower to find a solution. We do not sell non-performing consumer receivables by transferring the corresponding collateral.
Our marketing activities are guided by the principles of honesty, integrity and transparency and promote long-term cooperative relationships with our clients. We use uniform, accessible language to communicate the bank’s values and beliefs to our clients.
To this end, all activities are managed on a centralized basis. For nationwide advertising campaigns, we are increasingly relying on digital forms of advertising (e.g. digital signage boards) to reduce the need for printed posters. Promotional mailshots are routinely posted as digital advertisements in the Client Inbox of our online banking system. We assess each client communication to determine whether digital media can replace the production of print products. Furthermore, we are rapidly reducing the production and distribution of small gifts (e.g. on World Savings Day). Where feasible, we choose regional products with environmentally friendly packaging. When it comes to images, we make sure to provide inclusive representations that do not discriminate against any particular group of people.
The protection of personal data is a key European fundamental right and is afforded special protection under the Charter of Fundamental Rights of the European Union. We unconditionally observe the provisions of the EU General Data Protection Regulation, the German Federal Data Protection Act and other regulations relating to data privacy and implement them in full. We do not approach clients with promotional communications until we have conducted a precise analysis of their needs. For this reason, we specifically avoid mass mailings.