Declaration on sustainability-related disclosure obligations for the activity of insurance brokerage as an
insurance broker and advisor in insurance matters pursuant to Regulation (EU) 2019/2088 of the
European Parliament and of the Council of 27.11.2019
Status September 2021
2. Sustainability Risks
3. Strategies for the Inclusion of Sustainability Risks in Insurance Advice (as per Art. 3 (2) of the Disclosure Regulation)
4. Negative impact on sustainability (acc. to Art. 4 para.5 a and b Disclosure Regulation)
5. Compensation policy – inclusion of sustainability risks (acc. to Art. 5 Para.1 Disclosure Regulation)
6. Document History
As an insurance broker and advisor in insurance matters, dhig GmbH (“dhig”) operates an insurance advisory business within the meaning of Article 2 No. 11 a of Regu-lation (EU) 2019/2088 of the European Parliament and of the Council of 27.11.2019 on sustainability-related disclosure requirements in the financial services sector.
In this context, insurance intermediaries acting as financial advisors (for example, in the context of advisory activities for health, accident or life insurance) will have to comply with a sustainability-related disclosure obligation as of March 10, 2021. This document summarizes the sustainability-related content for financial advisors:
2. Sustainability Risks:
Sustainability risks are environmental, social or governance events or conditions (= ESG factors) the occurrence of which may have an actual or potential material ad-verse effect on the value of assets or on the financial position, financial performance or cash flows of a company.
ESG factors are:
– “E” Environment: e.g. climate protection, protection of biodiversity, sustainable use
and protection of water and marine resources, transition to a circular
circular economy, pollution prevention and control,
sustainable land use
– “S” Social: e.g., compliance with recognized labor standards (no child labor or forced labor, no discrimination), environmental protection
and forced labor, no discrimination), adequate pay, fair conditions at the workplace, trade union and
conditions at the workplace, freedom of trade union and assembly,
– “G” governance: e.g., tax honesty, measures to prevent
corruption, sustainability management, enabling whistle blowing,
Ensuring employee rights, data protection,
transparency of information vis-à-vis consumers, corporate quality management sys-tems
quality management systems
3. Strategies for the inclusion of sustainability risks and sustainability factors in insurance consulting (according to Art. 3 para. 2 Disclosure Regulation)
3.1 Our sustainability strategies are based on the report ‘The European Green Deal’ of the European Commission, the Paris Agreement and the recommendations of the Brundtlandt Commission.
3.2 We broker health, accident or life insurance and insurance investment products within the scope of our business license and in accordance with the policies defined in our product distribution arrangements.
3.3 Our insurance partners for health insurance and insurance investment products are nationally and internationally active insurance companies.
3.4 We regularly receive information about any sustainability factors and sustainability risks of the insurance products from our insurance partners or request this information at regular intervals.
3.5 As soon as our insurance partners have integrated the available sustainability in-formation into the pre-contractual information on the insurance products, the customer automatically receives this information in the course of our consultation. The available sustainability information is thus always part of the consultation. On this basis, the customer can make a well-informed decision.
3.6 We strive to systematically consider sustainability factors and sustainability risks in insurance consulting, especially when we can offer multiple insurance products that can be considered to cover a customer’s wants and needs.
4. Negative impact on sustainability (according to Art. 4 para.5 a and b Disclosure Ordinance)
4.1 Our insurance partners are financial market participants within the meaning of Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 No-vember 2019 on sustainability-related disclosure requirements in the financial services sector.
4.2 Therefore, according to Art. 4 (1) of this Regulation, they are obliged to make the following information available on their homepage:
– if they take into account the main adverse impacts of investment decisions on sustainability factors, a statement on strategies for the
Maintain due diligence on those impacts, given their size, the nature and scope of their activities, and the types of financial products they provide; or
– if they do not consider adverse impacts of investment decisions on sustainability factors, clear reasons why they do not do so, including, where appropriate, information on whether and when they intend to
consider such adverse impacts.
4.3 We ensure that customers receive the required pre-contractual information and that these topics are part of the consultation by using the insurance companies’ calculation programs when brokering insurance products.
4.4 We consider the main adverse effects on sustainability factors solely on the basis of the information provided by the insurance companies. We do not separately verify this information.
5. Compensation policy – inclusion of sustainability risks (according to Art. 5 para.1 Disclosure Regulation)
5.1 Our remuneration policy complies with the legal remuneration regulations according to § 1 para. 3 of the Code of Conduct for Insurance Mediation: general remuneration regulations for all insurance lines, § 9 para. 3 of the Code of Conduct for Insurance Mediation: special regulations for remuneration in the distribution of insurance invest-ment products as well as Art 8 DelVO (EU) 2017/2359: regulations on the assessment of incentives and incentive schemes in the distribution of insurance investment products.
5.2 We aim for remuneration models that favorably influence sustainability factors and avoid remuneration that is not consistent with the inclusion of sustainability factors and sustainability risks. In doing so, we pursue the goal of contributing to a more environ-mentally sound, socially responsible and better managed economy through the sale of sustainable insurance investment products.
5.3 Our compensation models do not provide any incentive to recommend a particular insurance product to the customer, even though there is a product that meets the needs and wishes just as well, but is more suitable in terms of sustainability.
6. Document History
Version Status Description of changes
001 10.03.2021 Initial creation