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Related Links

Conformity Declaration according to the Investment Ordinance (AnlV) as well as to the Supervisory Ordinance for Pension funds (PFAV)

Sustainable Finance Disclosure Reporting (SFDR)

SFDR (Regulation (EU) 2019/2088 on sustainability-related disclosures in the financial services sector) will come into effect on 10 March 2021. At this time, certain firms including credit institution providing portfolio management services will need to be compliant with several requirements of the regulation, inter alia:  

  • Article 3 – Transparency of sustainability risk policies -- imposes an obligation on financial market participants (FMPs) to “publish on their websites information about their policies on the integration of sustainability risks in their investment decision-making process”.
  • Article 5 – Transparency of how remuneration policies are consistent sustainability risk integration.
  • Article 6 - Transparency of the integration of sustainability risks.

SFDR only applies to Securities Finance Cash Re-Investment as these are portfolio management activities and our SSGA business more broadly.

For further information and applicable disclosures please refer to the following links:

What is MiFID?

On 3 January 2018 a material part of the German implementation act on the revised Directive on Markets in Financial Instruments II (MiFID II) and the accompanying regulations entered into force. Compared to MIFID I, the new directive MiFID II contains a large number of new rules on trading in financial instruments. This includes overarching issues relating to financial market infrastructure, for example the regulation of trading venues, as well as revised regulations for financial market participants regarding the distribution of financial instruments to investors.

MiFID II is complemented by the Markets in Financial Instruments Regulation (MiFIR) which is directly applicable and focuses on market transparency of transactions in financial instruments.

In Germany, MiFID II was transposed into national law by the Second Financial Markets Amendment Act (Zweites Finanzmarktnovellierungsgesetz – 2nd FiMaNoG). The 2nd FiMaNoG contains extensive amendments in particular to the German Securities Trading Act (Wertpapierhandelsgesetz – WpHG), as well as to other regulatory frameworks, such as the German Stock Exchange Act (Börsengesetz – BörsG) and the German Banking Act (Kreditwesengesetz – KWG).


Order Execution Policies

Order Execution Policy Global Delivery Germany, October 2021

Order Execution Policy Global Markets, October 2021

The current version of the Order Execution Policy of State Street Bank International GmbH, London branch is available under this link

RTS 28 Disclosures

Agent Fund Trading RTS 28 Disclosure 2021

Cash Sweep Service Germany RTS 28 Disclosure 2021

Agent Fund Trading Germany RTS 28 Disclosure 2020

Cash Sweep Service Germany RTS 28 Disclosure 2020

Currency Management RTS-28 Disclosure 2020

Currency Management RTS-28 Disclosure 2019

Conflicts of Interest Information

Summary of the Conflicts of Interest Policy, Germany, January 2018