Overview
DWS Investment Management Americas, Inc. (“DIMA”), a Delaware corporation, is an investment
adviser registered with the Securities and Exchange Commission (“SEC”). DIMA is part of the global
investment management business of DWS Group GmbH & Co. KGaA (“DWS Group”), a separate publicly
listed financial services firm that is an indirect majority-owned subsidiary of Deutsche Bank AG, a multi-
national financial services company (together with its affiliates, directors, officers, and employees, the
“Deutsche Bank Group”). DIMA is an indirect, wholly-owned subsidiary of DWS Group.
DIMA is also registered as a Portfolio Manager in several Canadian provinces: British Columbia,
Newfoundland and Labrador, Ontario, and Quebec. DIMA has offered its products and services to
clients, across a range of asset classes, investment strategies, and products since its reorganization in
1984, although various predecessors have been registered with the SEC since 1940. In order to provide
financial services in Australia, DIMA relies on an exemption from the requirement to hold an Australian
financial services license under the Corporations Act 2001 (Cth). DIMA is regulated by the SEC under
U.S. laws, which differ from Australian laws.
This brochure, including any brochure supplement, is intended for those clients to whom DIMA
provides investment advisory services. Investors in any DIMA-advised fund should rely on the fund’s
prospectus or offering materials, and may therefore refer to this brochure, or any brochure
supplement, for informational purposes only.
Advisory Services
DIMA offers a range of advisory services to clients, with capabilities of tailoring investment strategies to
meet the individual needs of clients. DIMA’s advisory services are tailored according to investment
policies and guidelines that are either pre - established by its client or established at the inception of
the adviser-client relationship (as amended from time to time) in cooperation with the client. Each
private commingled fund and registered investment company (the “DIMA Advised Funds”) managed by
DIMA is managed in accordance with its investment guidelines, restrictions and is generally not tailored
to address the specific investment objectives or circumstances of any fund shareholder or fund investor.
Accordingly, an investment in such vehicle does not, in and of itself, create an advisory relationship
between the shareholder or investor and DIMA. DIMA uses both quantitative and/or qualitative
processes to manage portfolios in accordance with their stated portfolio investment guidelines and
restrictions. The separately managed accounts (or separate accounts) and pooled investment vehicles
such as mutual funds, collective trusts and private investment funds that are sponsored, managed, or
advised by DIMA are collectively referred to in this Brochure as “Advisory Accounts.”
Additionally, DIMA may bring together investment professionals throughout the platform to discuss
and debate geographic markets, industry sectors, asset classes and investment styles to leverage the
global capabilities of DWS. The outcome of these discussions and debates provides directional guidance
to inform individual portfolio managers in implementing an investment strategy, including through the
use of lead portfolios.
Institutional Separately Managed Accounts
DIMA provides discretionary and non-discretionary investment advisory services to institutional
investors, including [certain] qualified institutional family offices, who generally enter into an
Investment Advisory Agreement (“IAA”) with DIMA (unless DIMA is appointed as a subadvisor). DIMA
provides services to both U.S. and non-U.S. clients.
Ultra-high net worth clients may access certain DMA strategies through a separately managed account
(“SMA”) sub-advisory program (“SMA Program”) sponsored by a DIMA affiliate, under which DIMA may
be appointed as sub-advisor. DIMA requires a minimum account size such for certain of its investment
strategies, which varies among SMA Programs. For institutional SMAs, DIMA is responsible for
establishing that the client is a sophisticated institutional account, understanding the investment
objectives, and investment restrictions.
Model Portfolio Programs
For certain investment strategies, DIMA may provide non-discretionary or discretionary investment
advice in the form of model portfolios to unaffiliated or affiliated advisers who may use such model
portfolios to assist in the development of their own investment recommendations or who may make
such model portfolios available to clients through investment platforms. DIMA currently provides
model portfolios on a non-discretionary and discretionary basis to various sponsors of model portfolio
programs who utilize such recommendations in connection with the management of their client
accounts. As a general matter, program sponsors that receive model portfolios from DIMA on a non-
discretionary basis and/or the independent advisers that may participate in such programs are
responsible for exercising their own judgment in deciding whether DIMA’s model portfolio
recommendations are appropriate for their client accounts. Sponsors of model portfolio programs are
typically responsible for implementing trades in their client accounts. With respect to model portfolios
provided to affiliated advisers, DIMA may execute securities transactions for such advisers. Such
transactions will be treated like any other orders for purposes of DIMA’s order execution policies as set
forth in Item 12 – Brokerage Practices. In accordance with Rule 3a-4 under the Investment Company
Act, clients who participate in model portfolio programs generally have the ability to impose
reasonable restrictions on the management of their accounts.
Certain model portfolios provided to unaffiliated model portfolio program sponsors on a non-
discretionary basis will include mutual funds and/or exchange traded funds (“ETFs”) that are advised by
DIMA or an affiliate of DIMA. DIMA’s inclusion of such DWS funds and/or ETFs in such model portfolios
raises potential conflicts of interest. To the extent DIMA uses DWS funds and/or ETFs as components in
such model portfolios, it will benefit DIMA and its affiliates by generating management fees and other
fees and compensation for DIMA and its affiliates when intermediary accounts and other persons
utilize such model portfolios. Moreover, the management fees and other fees and expenses of the DWS
funds and/or ETFs so used by DIMA may be higher than the fees and expenses charged by unaffiliated
mutual funds and ETFs. Therefore, DIMA has an incentive to use such DWS funds and/or ETFs as
components in such model portfolios. Clients should review the brochure provided by the managed
account program sponsor for further information regarding the extent to which model portfolios
provided by DIMA include DWS funds and/or ETFs.
In addition, DIMA may have business relationships with investment managers of unaffiliated mutual
funds and ETFs that are included in the model portfolios. For example, certain intermediaries may
distribute other funds or products advised by DIMA or its affiliates. Similarly, some model portfolio
sponsors and intermediaries to whom DIMA provides model portfolios may have other business
relationships with DIMA or its affiliates. In these regards, DIMA may benefit from its relationships with
such other parties when entering into the model portfolio arrangements.
Insurance Asset Management
DIMA offers advisory services focused on insurance companies, a segment of large institutional
investors. DIMA partners with the insurance company client in developing customized investment
policies and guidelines based on their unique objectives, needs and constraints that serves as the basis
for how DIMA manages portfolios for the client. Advisory services are performed in partnership with
the client and include matters such as: asset liability management; liquidity planning; portfolio risk
analyses; and strategic asset allocation that considers regulatory constraints and investment income
goals. These services are performed at the overall client level and may include a variety of asset classes,
including fixed income, public equities, and private offerings, managed and non-managed assets.
DIMA Advised Funds and Other Pooled Vehicles
DIMA also acts in an advisory or sub-advisory capacity to a variety of U.S. DIMA Advised Funds (including
open-end and closed- end funds) and U.S and non-U.S. pooled vehicles for which an affiliate may act as
adviser, sub-adviser, sub-sub-adviser, manager, or distributor. In connection with these funds, certain
DIMA employees may serve as directors, trustees, or officers. These arrangements are disclosed in
each fund's prospectus or offering document in accordance with any disclosure requirements. DIMA
also acts in an administrator capacity to a variety of open-end and closed-end investment companies.
DIMA has sought and obtained a permanent order from the SEC providing exemptive relief under
Section 9 of the Investment Company Act of 1940, as amended (“Investment Company Act’), on which it
relies in connection with the continued provision of investment advisory services to registered
investment companies.
Retail SMAs
DIMA provides investment advisory services to retail SMAs (“Retail SMAs”) in a “dual contract”
capacity. In a dual contract managed account arrangement or program, DIMA has separate agreements
with third-party program sponsors (“Program Sponsor(s)”), which may be either a registered
investment advisor or a broker-dealer/registered investment advisor, and each applicable client. The
agreement between DIMA and the client outlines the scope and limitations of the advisory relationship
between DIMA and the client. In dual contract arrangements, the Program Sponsor also has a direct
contractual relationship with the client and, as noted below, is generally responsible for determining
whether a strategy offered by DIMA is suitable and appropriate for the client based on the client’s
investment objectives, risk tolerance and financial situation. The Program Sponsor’s relationship with
its client can be structured either as a “wrap fee” or “bundled” arrangement or as a non-wrap fee or
“unbundled” arrangement.
In traditional wrap fee programs, a client selects a Program Sponsor that provides a bundle of services
for a single fee. For example, for third-party wrap fee programs that utilize DIMA as portfolio
manager, the Program Sponsor’s bundle of services would typically include the payment of DIMA’s
investment advisory fee, ongoing monitoring, and evaluation of DIMA’s performance, provision of
periodic market commentaries prepared by DIMA, and/or execution of the client’s portfolio transactions.
In non-wrap fee or unbundled arrangements, fees are charged separately for various services. In such
arrangements, DIMA’s investment advisory fees would be charged separately to the client. In DIMA’s
current dual contract arrangements, DIMA’s advisory fees typically are not bundled with fees for
services provided by the Program Sponsor.
In addition to acting as an investment adviser in dual contract programs, DIMA may, from time to time,
act as an investment adviser, on a sub-advisory basis, in “single contract” managed account
arrangements or programs. Such arrangements may either be on a wrap fee or non-wrap fee basis. In
such programs, the Program Sponsor enters into an investment management agreement with each
client with respect to the overall management of the client’s assets. The Program Sponsor identifies
investment managers that it believes are suitable for each client, and either the Program Sponsor or the
client selects an investment manager or managers to manage the client’s assets. If DIMA is selected for
a single contract program, DIMA would enter into an agreement with the Program Sponsor pursuant to
which DIMA would provide investment advice with respect to a portion of the program clients’ assets.
DIMA would not enter into a separate agreement with each client.
The services provided by DIMA to Retail SMA clients in dual contract or single contract arrangements, be
they structured as wrap fee or non-wrap fee programs, may differ from the services provided to its
institutional separate managed accounts and DIMA Advised Funds, which do not participate in such
programs. The investment strategy DIMA uses in managing third-party wrap fee and non-wrap fee
advisory programs is similar to strategies offered to its other clients but may involve fewer securities
holdings due to smaller account sizes and less ability for customization. In addition, DIMA typically
will rely on the Program Sponsor to provide client portfolio reporting. In certain cases, there may be
limitations on DIMA’s ability, in the ordinary course, to communicate directly, on its own initiative, with
the Program Sponsor’s clients without going through the Program Sponsor. While DIMA may
use
information gathered by the Program Sponsor to assess the appropriateness of its investment style to
individual client needs and financial situations, it is the Program Sponsor that is typically responsible
for determining the appropriateness or suitability of the program, including DIMA’s investment
strategy, for the client. In certain programs, the Program Sponsor may restrict DIMA’s access to client
information, including, for example, information about the client’s other investments or risk tolerance
or other information relevant to determining whether DIMA’s investment strategy or certain specific
investments would be appropriate or suitable for the client. As a result, determinations by DIMA as to
the appropriateness or suitability of an investment strategy or a particular investment for such clients
will be made without regard to such information, and such determinations may be different than
would have been had DIMA had access to more fulsome information regarding the client.
In wrap and non-wrap fee advisory programs, DIMA typically has discretion to select broker-dealers in
accordance with its duty to seek best execution. Due to the unique nature of the municipal bond asset
class, DIMA generally will execute transactions at financial institutions other than the Program Sponsor
in its municipal bond strategy accounts (see “Item 8” below for more information). Such transactions
ordinarily occur at net prices, meaning that the broker-dealer’s charge for the trade is built into the
security’s purchase or sale price and is ultimately borne by the client in addition to any charges for
execution otherwise included in a wrap fee sponsor’s overall fee. Each client should evaluate whether
particular wrap programs are appropriate for his or her needs, including the fees charged and services
provided. Depending upon the level of the wrap fee charged by a third- party wrap fee Program Sponsor,
the amount of portfolio activity in a client’s account, the value of the custodial and other services that
are provided under a wrap arrangement and other factors, a wrap fee client should consider whether
the wrap fee would exceed the aggregate cost of such services if they were to be provided separately.
A client paying separate fees in a non-wrap arrangement should consider whether the fees charged by
different parties for custody, advisory services, portfolio management services, securities execution and
other services would exceed the aggregate cost of such services if they were provided in a wrap fee
arrangement. Some broker-dealers serving as custodian charge fees for settling transactions executed
through other broker-dealers. Clients should refer to the Form ADV or other disclosure documents of
the Program Sponsor for additional information regarding fees arrangement for single contract or dual
contract arrangements.
Assets Under Management
As of December 31, 2023, DIMA had discretionary assets under management of $ 171,964,109,090
and non- discretionary assets under management of $1,098,023,230.
Investment Capabilities
Products listed below may be managed by DIMA either directly or through sub-advisory relationships
with affiliated and non- affiliated advisors. See Item 10 – Other Financial Industry Activities and
Affiliations for information regarding certain DIMA arrangements with affiliates related to its advisory
business. DIMA’s investment policies and practices can vary by strategy and/or product type.
Principal investment strategies and products currently offered by DIMA include:
ALTERNATIVES
▪ Asset Allocation-Alternatives
▪ Commodities
▪ Commodities with Fixed Income
▪ Commodity Securities
▪ U.S. Real Estate Equity
▪ Global Real Estate Equity
▪ Global Infrastructure
▪ Multi-Asset Allocation
▪ Multi-Asset Income
▪ Multi-Asset Highly Active
LIQUIDITY MANAGEMENT
▪ U.S. Cash Prime
▪ ESG Liquidity/ESG U.S. Cash Prime
▪ U.S. Cash Government
▪ U.S. Cash Municipals
▪ U.S. Cash Municipals State-Specific
EQUITIES
▪ ESG International Core
▪ International Equity Growth
▪ International Equity Value
▪ Global Small Cap
▪ Latin America Equity
▪ Emerging Markets Equity
▪ U.S. Large Cap Core
▪ U.S. ESG Large Cap Core
▪ U.S. Small Cap Core
▪ U.S. Sector Strategy
▪ U.S. Large Cap Growth
▪ U.S. Growth Equity Focus
▪ U.S. Small Cap Growth
▪ U.S. Small & Mid Cap Growth
▪ Global Sector Healthcare
▪ Global Sector Technology
▪ Global Sector Communications
▪ U.S. Large Cap Value (CROCI)
▪ U.S. Large Cap Dividend (CROCI)
▪ U.S. Small & Mid Cap Value (CROCI)
▪ Equity Index
▪ Institutional Managed Equity
FIXED INCOME
▪ Core Fixed-Income
▪ Core Plus Fixed-Income
▪ Core Intermediate
▪ Core Short Duration
▪ U.S. Government
▪ U.S. Mortgage Backed
▪ U.S. High Yield
▪ U.S. High Yield Index
▪ U.S. Corporate Investment Grade
▪ U.S. Corporate Investment Grade Index
▪ U.S. Floating Rate Debt
▪ U.S. Syndicated Loans
▪ U.S. Structured Securities
▪ Global Fixed-Income
▪ Global Short Duration
▪ Global Government Bond Index
▪ Global Inflation Protected Securities
▪ Global High Yield
▪ ESG Global Bond
▪ Canada Fixed Income
▪ Emerging Markets Fixed-Income
▪ Emerging Markets Fixed-Income Index
▪ ESG Fixed-Income
▪ U.S. Municipals
▪ U.S. Municipals Index
▪ U.S. Municipals Long Term
▪ U.S. Municipals Intermediate
▪ U.S. Municipals Short Term
▪ U.S. Municipals State Specific
▪ U.S. Municipals High Yield
▪ ESG U.S. Municipals
▪ Fixed Income Multi Product
▪ Strategic Asset Allocation
▪ Liability Driven Investing
Multi-Manager Strategies/Other Arrangements
DIMA offers a variety of non-U.S. strategies through its sub-advisory relationships with affiliated and
non-affiliated advisers located in the U.S. and outside the U.S. When delegating advisory services
to other advisors, DIMA will have ultimate responsibility to oversee any sub-advisor and to
recommend the hiring, termination, and replacement of a sub-advisor.
Apart from furnishing investment advice to clients, DIMA also provides various investment advisory,
consulting, trading, administrative, and research support services to its affiliates pursuant to
intercompany agreements. DIMA may offer and negotiate, fees regarding its investment advisory,
trading, administrative, and research support services to certain third-party banks, trust companies,
insurance companies and other fiduciaries, and may also render investment advice to specific accounts
of these banks, trust companies, and other fiduciaries that contract with DIMA. DIMA may also provide
certain other services such as investment company administrative services and executing broker
evaluations and selections.
Environmental, Social and Governance Considerations
DIMA seeks to incorporate in its investment process environmental, social and governance (“ESG”) risks
and opportunities that could have a material impact on the financial performance of the issuer, in
accordance with the goals of a particular investment strategy and client investment guidelines, and
further subject to its fiduciary obligations and applicable law, rule and regulation.
For most asset classes and market segments, DIMA portfolio managers have access to ESG research
and grades, including research provided by internal DWS analysts which consider ESG risks and
opportunities, as well as access to ESG quality assessment scores and additional information from
DWS’s proprietary ESG tool (also referred to as the “ESG Engine”).
For those strategies that do not seek to implement a specific ESG strategy, the level of consideration
of ESG factors in a strategy’s process will differ from strategy to strategy, from sector to sector, and
from portfolio manager to portfolio manager.
Certain DIMA Advised Funds, other pooled investment vehicles and separately managed account
strategies advised by DIMA are labeled as ESG and/or otherwise incorporate specific ESG considerations
into their investment objectives, strategies, and/or processes (collectively, “ESG-dedicated Strategies”),
in each instance, as described in the offering documents for such DIMA Advised Funds or pooled
investment vehicle or the strategy’s investment guidelines (in the case of SMAs, as dictated by the
Client). These ESG-dedicated strategies utilize ESG research and quality assessment scores, in addition
to traditional financial considerations, in a number of ways, including screening for securities that meet
certain minimum ESG identified thresholds, seeking to identify issuers or securities that support specified
ESG-related initiatives (e.g., climate change mitigation and adaptation, addressing poverty and
unemployment), or screening out issuers that engage in business practices or sectors that are deemed
controversial (e.g., fossil fuels, nuclear energy, tobacco, weapons, gambling, adult entertainment).
In addition to ESG-dedicated Strategies, where appropriate, DIMA will seek to identify and consider
relevant ESG factors when assessing the risk and return of a particular investment in providing advisory
services for certain other strategies. For DIMA Advised Funds or other pooled investment vehicles,
details relating to when and if ESG factors are considered by DIMA are disclosed in the offering
documents for such vehicles.
Because investors can differ in their views of what constitutes positive or negative ESG characteristics,
DIMA may invest in issuers that do not reflect the ESG beliefs and values of other investors. DIMA’s
considerations of ESG risks and opportunities may affect a fund’s exposure to certain companies or
industries, and an ESG-dedicated strategy may forego certain investment opportunities. While DIMA
views considerations of WSG risks and considerations as having the potential to contribute to a client’s
account long-term performance, there is no guarantee that such results will be achieved.
DWS Proprietary ESG Tool
DIMA’s portfolio managers may use output from a proprietary DWS ESG tool that evaluates an issuer’s
performance across a variety of ESG indicators, primarily on the basis of data obtained from multiple
third-party ESG data vendors and public sources and assigns a DWS ESG Quality Grade to each issuer
covered by the ESG tool. An additional DWS internal review process allows for changes to the DWS ESG
Quality Grade. An internal review may occur, for example, if it is deemed that information is not
reflected in the existing ESG grade because new information or insights have emerged that the ESG
data vendors have not yet processed. Examples of information that may be considered in this review
process include, but are not limited to, the announcement of new (or withdrawal from previously
announced) climate-related commitments, or the resolution of legacy (or involvement in new)
controversies. DIMA’s portfolio management may consider application of internal reviews on a given
DWS ESG Quality Grade and use their discretion whether and how to apply.
The DWS ESG Quality Grade seeks to identify ESG leaders and laggards within an industry- and region-
specific peer groups in terms of overall ESG performance (best-in-class approach). Issuers within the
same industry and region-specific peer group are graded on a scale of A (true leader) to F (true laggard).
Issuers with a grade of C or above are deemed to meet DIMA’s sustainability criteria. In calculating the
DWS ESG Quality Grade, the DWS proprietary ESG tool utilizes a proprietary methodology to evaluate
ESG scores from multiple third-party data vendors across a broad range of ESG indicators to arrive at a
consensus overall quality grade intended to reflect which companies may be positioned better to
address, and which companies may be more exposed to future ESG risks, relative to their peers. The
broad range of ESG indicators measured include, among others, assessments of an issuer’s carbon
emissions including its own emissions and those of its products and services, land use and biodiversity,
climate change strategy and vulnerability, product safety and quality, employee management issues
including equal opportunities and non-discrimination, freedom of association and right to collective
bargaining and occupational health and safety, community relations, human rights issues related to
supply chain, business ethics and anti-corruption, and corporate governance matters including
executive pay, board diversity and board independence.
The proprietary DWS ESG tool covers most listed asset classes but there is limited information on high
yield, municipal bonds, emerging markets, IPOs and certain other types of securities due to incomplete
vendor coverage. Through the DWS ESG tool, DIMA’s portfolio management may also access issuer-
specific contextual analysis that provides additional information about an issuer’s ESG risks and
opportunities, risk mitigation actions or plans and other characteristics.