DWS Investments Hong Kong Limited (“DWS HK”) has been a registered investment adviser
with the Securities and Exchange Commission (“SEC”) since 2006 and with the Hong Kong
Securities and Futures Commission since 1999. DWS HK is a wholly owned subsidiary of
DWS Group GmbH & Co KGaA (“DWS Group”), a German partnership limited by shares. DWS
Group is a separate publicly listed financial services firm and an indirect majority-owned
subsidiary of Deutsche Bank AG (“DBAG”), a multi-national financial services company
(together with its affiliates, directors, officers, and employees, the Deutsche Bank Group).
DWS HK is part of the global investment management business of DWS Group and its
affiliates. DWS HK provides advisory services which include research reports and analysis
conducted for listed securities in certain APAC locations and may also include
recommendations on transacting such securities. This service is provided to DWS HK’s
affiliated advisers, which in turn provide advisory services to their U.S. clients and non-U.S.
clients. DWS HK also provides discretionary investment advisory and management services
with respect to separately managed accounts, as well as private equity funds focused on
sustainable investments strategies.
DWS HK is appointed as sub-manager or sub-advisor of investment funds that are domiciled in
the Cayman Islands, Japan, Luxembourg, Singapore, and Taiwan. DWS HK also acts as
discretionary investment manager of separately managed accounts, including under sub-
delegation arrangement from DWS Investment Management Americas, Inc. (“DIMA”).
A dealing desk was established within DWS HK in Q1 2016, which provides order execution
services to DWS affiliates including affiliated advisors. The DWS HK dealing desk assumes
responsibility for APAC securities and associated spot FX dealing to improve trade execution
performance through leveraging local market expertise. The DWS HK dealing desk acts
as agent for each DWS affiliate whereby selection and instructions to brokers are on behalf of
the fund and / or institutional client accounts of each DWS affiliate.
DWS HK may in its discretion tailor its investment services for a client, and the clients may in
certain circumstances impose restrictions on investing in certain securities or types of
securities.
DWS HK complies with the requirements of the U.S. Investment Advisers Act of 1940 (the
“Advisers Act”) only with respect to U.S. clients. Non-U.S. clients will not be subject to the
protections of the Advisers Act.
This brochure, including any brochure supplement, is intended for DWS HK’s clients to whom
DWS HK provides investment advisory services. Investors in any DWS HK-advised fund
should rely solely on the fund’s prospectus or offering materials, and may therefore refer to this
brochure, or any brochure supplement, for information purposes only.
Following a federal court order issued on June 17, 2020 and relating to certain regulatory
settlements entered into by an affiliate outside of the DWS Group, DWS HK relies on an order
issued by the SEC under the Investment Company Act on October 20, 2020, permitting it to
continue to provide investment advisory services to investment companies registered under
the Investment Company Act.
Asset under management
DWS HK offers both discretionary and non-discretionary advisory services. As of December
31, 2023, there were discretionary regulatory assets under management of $3,308 million and
$145 million non-discretionary regulatory assets under management.
Environmental, social and governance considerations
DWS HK 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 within the investable universe of Active
Investment strategies managed by DWS HK, DWS HK 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 key assessment scores and
additional information from DWS’s proprietary ESG tool (also referred to as the “ESG Engine”).
Certain pooled vehicles advised by DWS HK 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 of such pooled investment vehicles. 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, affordable and clean energy), and/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, DWS HK 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 DWS HK pooled investment
vehicles, details relating to when and if ESG factors are considered by DWS HK are disclosed
in the offering documents for such vehicles.
Because investors can differ in their views of what constitutes positive or negative ESG
characteristics, DWS HK may invest in issuers that do not reflect the ESG beliefs and values of
other investors. DWS HK’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 DWS HK views considerations of ESG 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
DWS HK’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. DWS
HK’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). 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 better positioned 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, DWS HK’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.