Firm Description
Invesco Asset Management Deutschland GmbH Page 6 of 36
Invesco Asset Management Deutschland GmbH (“IAMD”)
Invesco Asset Management Limited (“IAMD”) is an indirect wholly owned subsidiary of Invesco Limited (“Invesco Ltd”). Further information about Invesco Ltd can be found below. The principal activity of IAMD is the provision of investment management services on a discretionary basis to pension plans, investment companies, banks, insurance companies and holding companies. IAMD also acts as investment advisor for a number of mutual funds on a sub-advised basis. IAMD is authorized and regulated by the German Federal Financial Supervisory Agency (Bundesanstalt für Finanzdienstleistungsaufsicht - BaFin), as well as supervised by the German Federal Bank. Additionally, IAMD is registered with the United States Securities and Exchange Commission as a registered investment adviser.
History
Invesco Asset Management Deutschland GmbH (“IAMD”) was founded in 1987.
Types of Advisory Services
IAMD operates the following investment centers:
Invesco Quantitative Strategies team (”IQS”)
The Invesco Quantitative Strategies team (“IQS”) is an investment team which was founded in 1983 in the US and was extended to European and global products in 1999 and 2001. The IQS team applies a global functional team approach utilizing quantitative techniques. The investment team is committed to adding value for clients through systematic application of factor investing incorporated into a number of key client offerings such as market neutral, directional long/short and enhanced index strategies. IQS provides a full range of investment capabilities for institutional clients including pension funds, insurance companies and holding companies worldwide and also sub-advises on a range of mutual pooled funds.
Invesco Real Estate Team (IRE)
Invesco Real Estate ("IRE") is the property investment management arm of IAMD. It operates in Germany as a branch of IAMD. IRE has been providing full service investment solutions in Europe since 1996. Invesco Asset Management Deutschland GmbH Page 7 of 36 Expertise ranges from fund management and structuring finance, acquisitions and asset management. As part of a network of offices around the globe, IRE is ideally placed to provide a wide range of cross border real estate investment products and services to international institutional clients. IRE manages real estate assets on a separate account and a pooled fund basis. The choice of vehicle depends on the investor’s requirement and investment goals. IRE currently manages real estate investment solutions for clients via a range of fund strategies investing in the office, retail, industrial and hotel sectors and in all European property markets.
Asset Management
IAMD is an investment management company that manages segregated institutional accounts and other mutual pooled funds on a sub-advised basis. As of 12/31/2018, IAMD manages approximately USD 24.3 billion in assets for approximately 137 mandates. please register to get more info

Description

Invesco Quantitative Strategies team

Institutional Segregated Accounts
Where IAMD manages segregated institutional accounts, management and performance fees are charged. Management fees are negotiated with the client and charged on a monthly basis or quarterly subject to agreement. Where applicable, performance fees are charged on an annual basis although subject to agreement can be charged quarterly.
Sub-Advised Accounts
Where IAMD provides investment management services on a sub-advised basis i.e. on behalf of another investment adviser within the Invesco group, IAMD receives 40% of the net management and performance- based fees charged (net management fees are fees net of any rebates). Management fees are paid out of fund assets to the fund’s investment adviser (or its affiliates) for managing the fund’s investment portfolio. Invesco Asset Management Deutschland GmbH Page 8 of 36 Clients are therefore not invoiced and do not have fees deducted from their accounts. Fees are not charged in advance of any investment management service being provided. Fees are agreed at the point of completing the Investment Management Agreement for an institutional mandate. Description

The annual performance fee of IQS is based on a percentage of the investable assets according to the following schedule: First 50 mln USD 0.24% to 1.00% Next 50 mln USD 0.22% to 1.00% Next 100 mln USD 0.18% to 1.00% Next 200 mln USD 0.15% to 1.00%

The fee structure above is applicable for products with tracking errors between 1% and 5%. Invesco bases its fees on a percentage of assets under management and/or on performance (performance-based fees). Fees are negotiable.

Invesco Real Estate IRE’s fees are not standard and are based on assets under management and calculated either based on the net or the gross asset value. Property acquisition, disposal and performance fees may also be charged. Fund fees vary and are set out clearly in each fund prospectus. Please refer to the relevant fund prospectus for further information. Fees on separate accounts are negotiated with the client and agreed up front in the investment management agreement. Negotiations are dependent on a number of variables including:
• Size of mandate
• Risk return criteria
• Return targets
• Level of discretion
• Scope (geography) Fees may be reassessed and agreed with the client at the end of the mandate or if there is a change to the mandate or the scope of work. Invesco Asset Management Deutschland GmbH Page 9 of 36
Fee Billing
Investment management fees and, where applicable, performance fees are billed at the end of the relevant period (i.e. monthly, quarterly or yearly) unless otherwise defined in a particular contract or being nonrecurring fees like property acquisition, disposal and performance fees. Fees are not payable before the service is provided. Payment in full is expected upon invoice presentation unless otherwise defined in a particular contact.
Other Fees
Custodians may charge transaction fees on purchases or sales of certain mutual funds and exchange-traded funds. These transaction charges are usually small and incidental to the purchase or sale of a security. The selection of the security is more important than the nominal fee that the custodian charges to buy or sell the security. IAMD in its sole discretion, may waive its minimum fee and/or charge a lesser performance fee based upon certain criteria e.g. historical relationship, type of assets, anticipated future earning capacity, anticipated future additional assets, dollar amounts of assets to be managed, related accounts, account composition, negotiations with clients, etc.
Past Due Accounts and Termination of Agreement
Contracts are terminable by any of the two parties within 30 days prior to written notice unless otherwise specifically defined in the agreement. Depending on the competitive peer group for similar strategies, the strength of the client relationship and potential for asset growth going forward, fees are agreed upfront and may be reassessed at the end of the contract period or in exceptional circumstances; for instance, where the mandate is at risk due to underperformance, lower fees may be considered. Fees may be reassessed at the end of the mandate, or in the case of a change to the mandate or the scope of service rendered. Invesco Asset Management Deutschland GmbH Page 10 of 36
Potential Conflicts Generated from Varying Fee Structures
IAMD does not operate a standard charging structure. IAMD undertakes discretionary portfolio management and real estate related investment services for more than one client or fund and different fee structures (e.g. performance related fees and fixed annual management charges) may exist for client portfolios, which may potentially represent incentive for allocation.
How are Conflicts Addressed
IAMD has strict allocation procedures in place to ensure fair allocation of securities and properties. In addition, when carrying out client transactions, IAMD will combine orders where this is in the best interest of the clients as a whole. Any exception that could occur over the course for IRE activities are justified and duly documented as per the Conflict of Interest Dealing Policy.
Performance-Based Fees
Invesco Quantitative Strategies

IQS charges performance related fees: A fixed fee of 0.10% - 0.40% plus 10% - 20% of the outperformance above benchmark is charged. A high watermark is applied. Performance fees are negotiable. please register to get more info

Invesco Quantitative Strategies
Clients include: institutional investors including corporate bodies, pension funds, public bodies, banks and other sophisticated investors as well as mutual funds on a sub-advised basis. Invesco Asset Management Deutschland GmbH Page 11 of 36 The minimum account size is EUR 25 million for segregated accounts of assets under management, although account minimums are negotiable. For a segregated account the total expenses of our asset management activities would be the above-mentioned management fee. In the case of a sufficient number of investors, pooled accounts may be set-up with the minimum account size of EUR 5 million per Client. The pooled account fee includes administration charges, custodian fees etc.
Invesco Real Estate
IAMD manages funds and segregated accounts on both a direct and sub- advised basis. Clients include: international institutional clients including insurance companies, pension funds, banks, asset managers and fund of funds. Minimum investment into a fund is typically €5-10m although there is discretion to waive this. The minimum investment for a separate account is not typically below €50-100m. please register to get more info

Risk of Loss
Invesco Quantitative Strategies

Methods of Analysis
IQS employs a quantitative, bottom-up multi factor model in the investment process. The buy/sell decisions are a function of the optimization process, a process whereby statistical inputs based on research gathered by the investment team are utilized to generate an optimal portfolio. The inputs to the optimization process include: the multi factor rating from the Stock Selection Model, the risk exposures for each stock from the Risk Model, transaction cost estimates, and client guidelines. After a final review performed by a member of the portfolio management or research team the portfolio is traded.
Investment Strategies
The team is committed to adding value for clients through systematic application of factor investing. Risk and return are the focus of the team’s efforts. Suitable stocks are selected based on a multi factor model using momentum, quality and value factors. Invesco Asset Management Deutschland GmbH Page 12 of 36 A highly efficient and systematic process to capture the insight contained in these factors is utilized in the portfolios. To preserve the value added through the Multi Factor Model, transaction costs are minimized where possible. Central to the investment process are IQS’s proprietary models, which are designed to consistently capture added value. The models are flexible and have been applied successfully across various styles, capitalization ranges, benchmarks, risk levels and geographic regions. Rigorous risk control is a key element of all strategies offered by Invesco Quantitative Strategies. The following outlines the properties of the main strategies offered by Invesco Quantitative Strategies:


Invesco Enhanced Index
An Enhanced Index strategy is a broadly diversified portfolio, structured to generate excess returns versus the respective equity benchmark from a large number of small active positions. Excess return targets with a low tracking error are the primary attraction of this strategy.
Invesco Quantitative Core Equity
A Quantitative Core strategy is a broadly diversified portfolio, structured with the aim of generating excess returns from a large number of small active positions. Excess return targets with moderate tracking error are the primary attraction of this strategy.
Invesco Global Balanced Solutions
A Global Balanced Solution is a portfolio that typically embraces at least two asset classes and generally aims to achieve predefined long-term outcomes in terms of return and risk profiles through the combination of strategic and tactical asset allocation with risk control mechanisms that seek to limit downside exposure.

Invesco Market Neutral
A Market Neutral Strategy is a diversified portfolio, structured with the aim of generating positive absolute returns from active positions. The investment strategy with a neutral net market exposure allows shorting to also benefit from expected underperformers and to additionally enhance the absolute return character.
Invesco Low Volatility
A Low Volatility strategy is a broadly diversified equity portfolio, constructed with the aim of generating attractive returns whilst delivering a risk level that is below the risk level of the equity market whilst being fully invested in equities. Invesco Asset Management Deutschland GmbH Page 13 of 36
Risk of Loss
Investing in securities involves risk of loss that clients should be
prepared to bear.
The following risks apply to all IQS strategies and will be managed by IQS and/or its fund managers, unless otherwise stated, on behalf of their investors. All investment programs have certain risks that are borne by the investor. Our investment approach constantly keeps the risk of loss in mind. Investors face the following investment risks among others:
• Interest-rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate. For example, when interest rates rise, yields on existing bonds become less attractive, causing their market values to decline.
• Market Risk: The price of a security, bond, or mutual fund may drop in reaction to tangible and intangible events and conditions. This type of risk is caused by external factors independent of a security’s particular underlying circumstances. For example, political, economic and social conditions may trigger market events.
• Inflation Risk: When any type of inflation is present, a dollar today will not buy as much as a dollar next year, because purchasing power is eroding at the rate of inflation.
• Currency Risk: Overseas investments are subject to fluctuations in the value of the dollar against the currency of the investment’s originating country. This is also referred to as exchange rate risk.
• Reinvestment Risk: This is the risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (i.e. interest rate). This primarily relates to fixed income securities.
• Business Risk: These risks are associated with a particular industry or a particular company within an industry. For example, oil- drilling companies depend on finding oil and then refining it, a lengthy process, before they can generate a profit. They carry a higher risk of profitability than an electric company, which generates its income from a steady stream of customers who buy electricity no matter what the economic environment is like.
• Liquidity Risk: Liquidity is the ability to readily convert an investment into cash. Generally, assets are more liquid if many traders are interested in a standardized product. For example, Treasury Bills are highly liquid, while real estate properties are not.
• Financial Risk: Excessive borrowing to finance a business’ operations increases the risk of profitability, because the company must meet the terms of its obligations in good times and bad. During periods of financial stress, the inability to meet loan Invesco Asset Management Deutschland GmbH Page 14 of 36 obligations may result in bankruptcy and/or a declining market value.
• Credit or counterparty risk is the risk of loss if a fund’s counterparty fails to meet its financial obligations. This is managed daily by fund managers and equity dealers monitoring and selecting reputable brokers through whom to execute trades. In addition, the selection process for each new Counterparty means that checks are conducted by the firm’s Finance team to assess their financial standing. Exposure to each Counterparty is also limited through certain UCITs requirements, which are monitored through post- trade compliance reports. Further details on approved counterparties and their selection are set out in IAMD’s Trade Execution Policy.
• Legal and documentation risk is the risk of not having contractual certainty if issues arise on the assets of the funds or with funds’ counterparties. This is managed by Invesco’s Operations, Legal and Transaction Processing teams where required, specifically for new counterparty set ups either for cash equities or cash fixed income trading or for Over-the-Counter (OTC) derivatives by ensuring relevant documentation is in place. There is a robust account opening process in place for all counterparties which should mitigate any legal risk. Where OTC instruments, are used, then appropriate documentation is reviewed and signed by Invesco’s Legal team.
• Regulatory risk is the risk of loss from not complying with relevant regulations. Compliance of the funds with relevant regulations is monitored daily by fund managers at a pre-trade level and by Invesco’s Compliance Team at a post trade level. If any breaches are discovered, these are raised and resolved through the BWise incident reporting process. If any of these breaches result in losses to the funds or relevant investors, these are made good by IAMD under the Invesco Continental European Error Policy. Details of all applicable investment restrictions are contained within either, the relevant Fund Manual or Prospectus/Investment Policy Guidelines.
Trading of Securities
Our investment strategy does not involve frequent trading of securities in normal market conditions.
Invesco Real Estate
Methods of Analysis & Investment Strategies
Invesco Asset Management Deutschland GmbH Page 15 of 36 IRE implements a variety of different strategies depending on the nature of the mandate and the common theme is that they are all invested in private (unlisted) European real estate. IRE is research led and the real estate market research provides the basis for the strategic view which is then supplemented by the “on the ground” execution by the local European transaction and asset management teams. IRE’s investment philosophy is underpinned by two fundamental principles – to maximize the predictability and consistency of investment returns and to control risk at every step of the investment process and portfolio design. This is achieved through a systematic approach that incorporates top-down economic and market research as well as in-depth bottom-up analysis based on the knowledge and skills of our experts in our well-established platform of local offices across Europe. IRE’s investment mandates are spread across geography, risk return spectrum and sectors. This provides experience and access to most European markets across a range of strategies. IRE’s experience and resources for managing both direct real estate and deal structuring and financing provides the ability to adopt different strategies depending on the mandate. However, at the core of all investments is the belief that it is the real estate that will ultimately underpin returns and therefore transactions will only be undertaken if the fundamental real estate investment is a sound one.
Risk of Loss
Direct Real Estate IRE has several methodologies and systems in place to manage risk and to ensure consistent application of IREs investment philosophy and process. The first process is our House View. On a semi-annual basis, our investment teams undertake a formal review of our House view and submit this to the investment committee for approval. The House View combines the empirical and anecdotal evidence from our investment disciplines, research, asset management and acquisitions and sets forth where we see the best relative value from both a property type allocation and market selection standpoint – two very key decisions in providing strong relative returns. Portfolio management then incorporates the House View into the clients’/funds’ investment plans and is charged with implementation. In addition, IRE utilizes a team-oriented investment process. The team includes members from Portfolio Management, Research, Acquisitions, Underwriting, Closing Services, and Asset Management. Each member of the investment team must sign-off on an investment. A potential Invesco Asset Management Deutschland GmbH Page 16 of 36 investment may be vetoed at any time by one member of the team. The investment review process requires unanimous preliminary and final investment committee approval. We believe it is extremely important to provide several independent checks throughout our due diligence of each potential investment, and it is important to provide structural controls within the ownership documents which limit risk exposure. To further manage and minimize risk within the account, IRE will take the following measures:
• Purchase assets in IRE’s qualified markets
• Acquire assets that possess institutional-quality physical and locational attributes that provide reasonable assurance of an adequate pool of potential purchasers upon sale of the property
• Structure the investment to maximize the account’s control
• Place restrictions on the maximum size of any one investment
• Diversify the strategies employed within the program
• Put all investments through IRE’s rigorous investment and due diligence process
• Carefully monitor leverage levels and maturities consistent with the risk expectations
• Carefully monitor tenant and industry exposure
• IRE’s Asset Management resources establish processes throughout the holding period to mitigate risk and maximize value of each investment Individual accounts are also governed by the account documents which include the investment guidelines. The account’s portfolio management team reviews compliance to guidelines as part of the quarterly reporting process. Any potential issues related to investment guidelines would be shared with the account's Advisory Committee as well as Compliance. Should a revision be needed, the change would be reflected as an amendment to the account document and all investors would be notified of the change. All account management personnel are Invesco employees and subject to Invesco Compliance policies. For a comprehensive discussion on risk factors of the account, see the “Risk Factors & Potential Conflicts of Interest” section in the offering Memorandum.
Trading of Securities
It is not possible to trade real estate frequently, assets are typically held on average for 5 years. Invesco Asset Management Deutschland GmbH Page 17 of 36 please register to get more info

Legal and Disciplinary
The firm and its employees have not been involved in legal or disciplinary events related to past or present investment clients. please register to get more info

IAMD is a registered investment adviser with the Securities and Exchange Commission. IAMD does not recommend or select third party investment advisers for our clients nor does it receive compensation directly or indirectly from those advisers.
Affiliations
Operating under the legal entity IAMD, IQS manages funds and segregated accounts on a sub-advised basis for other Invesco entities, including Invesco Advisers, Inc. an affiliate of IAMD. For further information about this affiliation please refer to filings made with the SEC by Invesco Advisers, Inc. Invesco Real Estate (the property management arm of Invesco) operates in Germany as a branch of IAMD. IAMD has entered into various advisor/sub-advisor arrangements with the following related investment advisers:
• Invesco Asset Management (Japan) Limited
• Invesco Advisers, Inc.
• Invesco Hong Kong Limited
• Invesco Asset Management Limited
• Invesco Asset Management S.A. Invesco Asset Management Deutschland GmbH Page 18 of 36
• Invesco Real Estate s.r.o
• Invesco Australia Limited
• Invesco Management S.A.
• Invesco Real Estate Management S.A.R.L.
• Invesco National Trust Company

Certain other registered investment adviser subsidiaries of Invesco Ltd. (IAMD ultimate parent) may from time to time have other arrangements not specified in this filing. For more information regarding these related persons, please refer to filings made with the SEC by the following related persons: Invesco Capital Management LLC File No. 801-61851 Invesco Senior Secured Management, Inc. File No. 801-38119 IRE (Cayman) Limited File No. 802-74648 Invesco Canada Ltd. File No. 801-62166 Invesco Private Capital, Inc. File No. 801-45224 WL Ross & Co. LLC. File No. 801-67779 Invesco Investment Advisers LLC File No. 801-1669 Invesco Global Real Estate Asia Pacific, Inc. File No. 801-74650 JEMSTEP, Inc. File No. 801-70734 Invesco Capital Markets, Inc. File No. 8-19412 Invesco Distributors, Inc. File No. 8-21323 Invesco Asset Management (India) Private Limited File No. 801-108727
Conflicts
Trades Executed Via Counterparties
IAMD manages the segregated mandates of approved counterparty firms and may, at the same time, use such firms for the execution of investment trades which will result in the payment of commissions. This could incentivize the favoring of a particular broker or client when trading. Dealers have a fiduciary responsibility to obtain best possible results for clients when executing orders and have full discretion for placing deals on Invesco Asset Management Deutschland GmbH Page 19 of 36 behalf of clients with a particular broker to ensure that best execution obligations are met. Fund managers cannot exert any influence and the dealing team is segregated from the fund managers. Invesco has policies and procedures in place to ensure that best execution is achieved. These policies and procedures are subject to monitoring.
Group Funds
A conflict may arise where the guidelines authorize transactions in units or shares of funds within the Group or any company of which IAMD or any other Associate is the manager, operator or adviser. Where permitted by investment guidelines of product managed, Invesco funds may only be purchased on their investment merits or where mandated to do so. IAMD Fund managers must confirm that a purchase of an Invesco fund is driven by investment merit and that there is no non-public information influencing the decision. Invesco funds as investors in other Invesco funds are treated at arm’s length. Mitigation arrangements also include, where appropriate, a full rebate of the management fee in order to avoid “double-dipping”.
Execution/Client Order Handling
IAMD undertakes discretionary portfolio management and real estate related investment services for more than one client or fund and different fee structures (e.g. performance related fees and fixed annual management charges) may exist for client portfolios, which may potentially affect incentive for allocation. IAMD has in place strict allocation procedures to ensure fair allocation of investment opportunities to all clients. In addition, when carrying out client transactions, IAMD will arrange to execute orders in due turn but may combine orders where this is believed to be in the best interest of the clients as a whole. If there is insufficient liquidity for either purchases or sales, Invesco will allocate the orders for the purchase or sale of the security on a pro rata basis based on relative order size. This is subject to monitoring.


In certain circumstances an allocation of a trade may deviate from a pro rata approach. Such instances must be justified, be reasonably be in the best interests of all the affected clients and clearly documented. In addition, from time to time IAMD may, where permitted by mandate, sell an investment from one client to another. These are recorded and monitored. The transfer of real estate investments requires the confirmation by Invesco Real Estate Senior Management and Compliance that conflicts of interests are appropriately considered. Invesco Asset Management Deutschland GmbH Page 20 of 36
Code of Ethics, Participation or Interest in Client
Transactions and Personal Trading
Code of Ethics – Overview
The employees of IAMD have committed to a Code of Ethics (the Code). The IAMD Code of Ethics applies to all employees and includes the following topics:
• Prohibitions related to material, non-public information & inside information;
• Personal securities investing;
• Service as a director and other business opportunities;

This Code also imposes certain personal account dealing restrictions and reporting obligations on employees. Adherence to the Code, both letter and spirit, is a fundamental and absolute condition of employment with IAMD. It is appreciated that no Code of Ethics can address every circumstance that may give rise to a conflict, a potential conflict or an appearance of a conflict of interest. Every Employee should be alert to any actual, potential or appearance of a conflict of interest with Invesco’s clients and to conduct himself or herself with good judgment. Failure to exercise good judgment, as well as violations of this Code, may result in the imposition of sanctions on the Employee, including suspension or dismissal. All Covered Persons are required to comply with applicable laws, rules and regulations and this Code. Covered Persons shall promptly report any violations of law or regulations or any provision of the Code of which they become aware to the Compliance Officer or his/her designee.
Statement of Fiduciary Principles
A statement of fiduciary principles found in the Code of Ethics in force with IAMD denotes that as a fiduciary, IAMD owes an undivided duty of loyalty to its clients. It is IAMD’s policy that all employees conduct themselves so as to avoid not only actual conflicts of interest with IAMD’s clients, but also that they refrain from conduct which could give rise to the appearance of a conflict of interest that may compromise the trust our clients have placed in us. Invesco Asset Management Deutschland GmbH Page 21 of 36 The Code is designed to ensure, among other things, that all employees’ personal securities transactions are conducted in accordance with the following general principles:
• A duty at all times to place the interests of IAMD’s clients first and foremost;
• The requirement that all personal securities transactions be conducted in a manner consistent with the Code and in such a manner as to avoid any actual, potential or appearance of a conflict of interest or any abuse of an employee's position of trust and responsibility; and
• The requirement that employees should not take inappropriate advantage of their positions.

IAMD’s policy is to avoid actual or apparent conflicts of interest but, where they unavoidably occur, to record, manage, and disclose them to prevent abuse and protect our clients, employees and other counterparties. IAMD does not make political contributions with corporate funds. No employee may, under any circumstances, use company funds to make political contributions, nor may represent their personal political views as being those of the company. IAMD does not tolerate bribery. Employees must not offer, give, request, or agree to accept or accept financial or non-financial advantages of any kind where the purpose is to influence a person to behave improperly in their decisions or actions or to reward them for having done so. Legislation as well as internal IAMD policy exist to protect Employees who ‘blow the whistle’ about wrongdoing within the firm. It shall encourage Employees to raise concerns internally in the first instance. IAMD Employees should feel able to raise any such concerns internally, confident that it will be dealt with properly and that all reasonable steps will be taken to prevent victimization. No employee should have ownership in or other interest in or employment by any outside company which does business with IAMD. This does not apply to stock or other investments in a publicly held company, provided that the stock and other investments do not, in the aggregate, exceed 5% of the outstanding ownership interests of such company. IAMD may, following a review of the relevant facts, permit ownership interests which exceed these amounts if management or the Board of Directors, as appropriate, concludes that such ownership interests will not adversely affect Invesco’s business interests or the judgment of the affected staff. Finally, Employees are prohibited from using personal hedging strategies or remuneration or liability related contracts of insurance to undermine any risk alignment effects embedded in their remuneration arrangements. Invesco Asset Management Deutschland GmbH Page 22 of 36
Preclearance of Personal Account Trading and Blackout
Restrictions
All transactions by employees which are subject to preclearance requirements through Compliance are also subject to certain trading restrictions.

Blackout Periods: An employee may not buy or sell, or permit any Covered Account to buy or sell, a security or any instrument if there is conflicting activity in an Invesco Client account.
Non-Investment Personnel.

• may not buy or sell a Covered Security within two trading days after a Client trades in that security; and
• may not buy or sell a Covered Security if there is a Client order on that security currently with the trading desk.
Investment Personnel.

• may not buy or sell a Covered Security within three trading days before or after a Client trades in that security; and
• may not buy or sell a Covered Security if there is a Client order on that security with the trading desk.

Employees of the real estate division have additionally to seek pre- clearance of personal real estate transactions and real estate financing through Compliance.
Conflicts

Fund Managers’ Investments into Funds
Fund Managers can personally invest in the funds that they, or their colleagues, run; this is considered to be a positive aspect and is encouraged by Invesco. However, such investment raises the potential for there to be an incentive for these funds to be managed to meet the personal objectives of the fund manager(s) rather than in the best interests of the other investors, and for the fund manager to favor the fund he has invested in over other funds he manages. In mitigation, Invesco has strict allocation procedures to ensure the fair allocation of stocks. The accordant controls are subject to compliance review. Invesco Asset Management Deutschland GmbH Page 23 of 36
Personal Account Dealing
A conflict may exist as an employee or director of IAMD engages in personal account dealing or is otherwise interested in any company whose securities are held or dealt in on the client’s behalf, in respect of securities or services, whereas IAMD also has a client with an interest which potentially conflicts with such personal dealing activity. IAMD operates personal account dealing procedures which detail requirements for pre-clearance and/or notification, blackout periods and restrictions, and annual declarations. All such transactions are recorded and monitored by the responsible Compliance function.

Inducements and Business Entertainment and Gifts

Non-monetary benefit inducements as gifts and entertainment are received and given that may influence behavior in a way that conflicts with the interests of IAMD’s clients. IAMD has an Inducements (Non- Monetary Benefits) Policy covering gifts, benefits & entertainment (“Inducements Policy”) which details, depending on the investment service provided, what is acceptable or reasonable. Only non-monetary benefits which do not impair IAMD’s duty to act in the best interests of our clients are allowed by the policy. Records are maintained and monitoring undertaken of non-monetary benefits both received and given. In addition, IAMD will make any disclosures necessary under regulations.
Inside Information
A potentially significant conflict that arises on a permanent basis is that some of our staff, to varying degrees, have access to material, non-public information concerning companies which may be price sensitive and about real estate investments which may affect the market price. We mitigate this by explicit disclosure and approval through strict personal account dealing rules and a Code of Ethics which applies to all staff. In addition, periodic compliance monitoring checks are carried out. Our Conflicts of Interest Policy details how conflicts are identified, managed, recorded and disclosed. The section on the investment management process details how we execute trades on behalf of clients to ensure that one client is not favored to the detriment of another. In addition, fund managers are compensated predominantly based on their three year performance returns. This system is designed specifically to avoid short-term risks being taken to achieve performance goals Invesco Asset Management Deutschland GmbH Page 24 of 36 please register to get more info

Selecting Brokerage Firms / Best Execution
Trading counterparties must have undergone the initial approval process and ongoing monitoring of the EMEA Counterparty Risk Committee (ECRC) before IAMD can use them. The decision-making process concerning the routing of an order to a counterparty that achieves the best result will be considered by reference to various Execution Factors: price, costs, speed and likelihood of execution and settlement, size and nature of order and any other consideration relevant to its execution. The choice of relevant venue and the means of accessing that venue are assessed by professional, competent traders weighing the main Execution Factors listed above. It is important to understand that the weightings considered are dynamic and may depend upon several variables and characteristics including the specific security being traded, the order type and market/execution venue conditions. Subject to the weightings given to the Execution Factors referred to above, IAMD considers that the best possible result to the client will be driven by price considerations. Other Execution Factors, particularly size of order and likelihood of execution (both reflections of liquidity) will be considered in so much as they affect price.
Brokerage Fees
IAMD did not enter into any soft dollar arrangements.
Directed Brokerage
Please Note: Client specific instructions are permitted within IAMD. By directing brokerage, clients may be unable to achieve most favorable execution of transactions. Invesco Asset Management Deutschland GmbH Page 25 of 36
Trade Aggregation
Invesco Quantitative Strategies Portfolios are traded in the most cost-effective way. Thus, orders may be pooled at a security level where possible to optimize trading. If aggregated orders are not fully implemented, they are distributed on a pro-rata basis. Trades for clients with directed brokerage arrangements are undertaken after the pooled orders and clients are notified of this fact. The following criteria would serve, among other factors, as basis to optimize the trading activity.
• Client mandate restrictions;
• Regulatory restrictions;
• Certain market practices;
• Investment objectives of Client mandates;
• Subscriptions and redemptions;
• Cash positions;
• Potential trading volumes (or liquidity);
• Potential prices;
• Known commitments
• Other factors that may be pertinent to the trade.

Any such decision would be documented.
Conflicts
Conflicts of interest are avoided and where this is not possible, managed appropriately. A copy of the Conflicts of Interest policy is available upon request. please register to get more info

Invesco Quantitative Strategies:
Periodic Reviews
Account reviews with the client are performed semi-annually by the advisor’s client facing portfolio manager. Account reviews are performed more frequently when market conditions dictate. Invesco Asset Management Deutschland GmbH Page 26 of 36
Review Triggers
Other conditions that may trigger a review are changes in the tax laws, new investment information, and changes in a client's own situation.
Client Reporting
At a minimum level, clients receive full monthly reports. The information and measurements contained in the reports are namely:
• Valuation
• Transactions
• Performance In addition, some clients receive risk measurement reports and other clients, i.e. insurance companies, receive tailor made reports as required by the respective industry standards. Client communication is frequent and statements of assets under management, performance and transactions undertaken are issued at least quarterly, depending on the client's needs. No extra fee is charged for this service. Clients can, subject to agreement, determine the level of reporting they need to satisfy their requirements. These reports will be provided in written format.
Invesco Real Estate

Client Account Reviews
At least every six months each fund/mandate is subject to review by the “Fund Strategy Review Committee” (FSRC). The FSRC is a sub-set of the investment committee. For each review the portfolio manager is required to provide a full update of the fund and its proposed future strategy in accordance with a closely defined set of criteria. Prior to the update, the portfolio manager will have had to liaise with the asset management, research and acquisition teams in order to assess the overall fund strategy, individual asset business plans and then develop proposals for the fund’s future strategy. The proposals are critically reviewed by the FSRC and if accepted, approved. Invesco Asset Management Deutschland GmbH Page 27 of 36
Client Reporting
At a minimum, client reports are delivered in writing on a quarterly basis although at times more frequently. The reports contain the profile of the portfolio plus an associated commentary. please register to get more info

Incoming Referrals
Invesco has received client referrals over the years. The referrals came from current clients, counterparties and other similar sources. In addition, the firm may contract to pay solicitors if, following an invitation from a solicitor to participate in a search process, IAMD agrees to participate in the search and a client appoints IAMD as their appointed portfolio manager. In 2016 the firm started to compensate referring parties for these referrals. These fees typically involve the firm paying a portion of its investment management fee to the solicitors.
Referrals Out
Invesco does not accept referral fees or any form of remuneration from other professionals when a prospect or client is referred to them.
Other Compensation
None please register to get more info

Invesco Quantitative Strategies Team and Invesco Real Estate
The firm does not have custody of U.S. client or investor funds or securities therefore this section is not applicable to the firm. please register to get more info

Invesco Quantitative Strategies:
Invesco Asset Management Deutschland GmbH Page 28 of 36 For institutional clients with segregated managed accounts, IQS will typically have full discretion for all buying and selling investment decisions made. The discretionary investment decisions must be made in accordance with the investment objectives and restrictions agreed with the client, what can include geographical, asset type, weightings and specific stock restrictions, within the Investment Management Agreement. However, IAMD will consult with the client prior to each trade to obtain concurrence if a blanket trading authorization has not been given. On occasion, clients may choose to retain the discretion to exercise the voting rights attached to their shareholdings rather than delegating this responsibility to the investment manager. A Portfolio may be changed with the approval of the shareholders of the relevant Portfolio by way of Ordinary Resolution. This also applies to changes to the investment policies that are material in their nature, like the following ones:
• active duration exposures relative to benchmark
• currency risk (whether non-base currency positions are fully hedged, partially hedged or un-hedged)
• credit rating limits

For pooled funds offered to retail investors, IAMD will operate with full discretion within the limits set out in the fund’s prospectuses.
Invesco Real Estate
There are different levels of discretion depending on the nature of the account. Some accounts and pooled funds have full discretion although it is more common for there to be some set constraints on the portfolio dependent on the investor’s requirements and investment goal. Such constraints can include, among others:
• Size of the building that can be purchased
• Markets (countries) permitted to buy in Pooled funds are managed with discretion in line with the limits set out in the fund prospectus. There are also mandates which are advisory where all decisions need to be ratified by the client. please register to get more info

Invesco Quantitative Strategies
Invesco Asset Management Deutschland GmbH Page 29 of 36
Options for Clients on Voting
Clients either give us the full discretion to exercise voting rights on their behalf or retain that discretion to make their own arrangements to exercise voting rights. Unless the client designates otherwise, IQS votes proxies for securities over which it maintains discretionary authority consistent with its proxy voting policy. A copy of the Global Proxy Policy is available upon request.
Obtaining Information on Voting
Clients with institutional segregated mandates, or investors in our pooled funds, can request voting information from their usual sales contacts. IAMD will provide the record of votes that will reflect the voting instruction of the relevant fund manager. This may not be the same as votes actually cast as IAMD is entirely reliant on third parties complying promptly with such instructions to ensure that such votes are cast correctly. Accordingly, the provision of information relating to an instruction does not mean that a vote was actually cast, just that an instruction was given in accordance with a particular view taken.
Conflicts
IAMD has a responsibility for making investment decisions that are in the best interests of its clients. As part of the investment management process, IAMD may exercise its voting rights where authorized by clients, or in the collective interests of investors in a fund, to vote in respect of the shares/units for which the clients are beneficial owners. Invesco has adopted safeguards to ensure that our proxy voting is not influenced by interests other than those of our fund shareholders. please register to get more info

Financial Condition
IAMD does not have any financial impairment that will preclude the firm from meeting contractual commitments to clients. Invesco Asset Management Deutschland GmbH Page 30 of 36 A balance sheet is not required to be provided because IAMD does not serve as a custodian for client funds or securities and does not require prepayment of fees of more than $1,200 per client, and six months or more in advance.
Business Continuity Plan
Overview
Invesco Ltd and its entity IAMD has a Business Continuity Program in place that provides a framework supporting detailed steps to mitigate and recover from the loss people, processes, and key assets. A disruptive event is classified as any event that materially limits the operations of Invesco thereof by denying critical infrastructure or business processes. The declaration of a disruptive event is made by designated management on site, at the time, depending on the nature of the event.

Business Continuity is a company-wide approach designed to ensure that critical processes can be maintained in the event of a major internal or external incident. Business Continuity is a standing department within Invesco and its personnel are dedicated full-time to delivering Invesco’s business continuity goals. Invesco has established recovery teams that cover all departments within the company. Each team has responsibilities when it comes to business continuity:

Invesco has established recovery teams that cover all business and organizational areas within the company. Each team has responsibilities when it comes to Business Continuity:


• To participate in Business Continuity plan exercises and maintenance procedures.
• To understand and be able to follow the Business Continuity plan in times of disaster.
• For IT Services teams, to provide the technology needed to support a recovery effort.
• Major components of disaster recovery/ Business Continuity planning include: Incident notification procedures Invesco Asset Management Deutschland GmbH Page 31 of 36 Status Line and Website Recovery Plans Recovery Facilities Pandemic Planning o Planning measures including IT Systems and Data backups o Recovery Exercises
Security Controls Systems
Information Security
Invesco Ltd (“Invesco”) and its entity IAMD have established a Global Security Department to bring physical security and information security together under a single executive with responsibility for both disciplines supported by an intelligence function that would provide timely information about threats to all assets, whether data, systems, facilities, global workforce, and/or the brand itself.

The Information Security program within the Global Security Department is staffed with a designated Chief Information Security Officer who leads dedicated teams of information security and IT security operations professionals with responsibility for overseeing and maintaining all aspects of information security risk globally on a 24*7*365 basis. The program includes the development and implementation of information security policies aligned with industry guidelines (ISO27001/2, NIST) and all applicable statutes, rules or regulations, and includes commercially reasonable administrative, physical and technical safeguards to:
• Protect the privacy, confidentiality, integrity and availability of information assets and the systems that process those assets;
• Protect those assets against accidental, unlawful or unauthorized access; and
• Prevent the damage, destruction, or unauthorized disclosure, distribution, loss, manipulation, modification, and/or transmission of those assets. Invesco’s Information Security program is subject to regular independent assessments, audits, and reviews to evaluate effectiveness and Invesco Asset Management Deutschland GmbH Page 32 of 36 compliance with relevant regulation and legislation relating to the safeguard of investor and employee sensitive information.
Policies
Invesco and its entity IAMD have a well-defined set of information security policies in place addressing areas:
• Information Security
• Risk Assessment
• Acceptable Use
• Physical Security
• Human Resources Security
• Access Control
• Asset Management
• Information Security Incident Management
• Communications & Operations Management
• Business Continuity Management
• Information Systems Acquisition, Development & Maintenance

These securities policies aligning with the ISO 27001/2 framework have been developed, reviewed, and approved to ensure appropriate management of identified risks, alignment with regulatory and industry guidelines, and support Invesco’s business.
Glossary of Terms

IAMD Invesco Asset Management Deutschland GmbH Invesco Invesco Limited
IRE Invesco Real Estate
ISSM Invesco Senior Secured Management, Inc. SEC Securities and Exchange Commission, the US regulator
UCITS Undertakings for Collective Investment in Transferable
Securities Invesco Asset Management Deutschland GmbH Page 33 of 36
Brochure Supplement
(Part 2B of Form ADV)
Education and Business Standards
Generally Invesco would expect its investment professionals to be educated to a first degree standard or to hold a German University degree. In rare exceptions a business related education of a sufficient length and appropriate experience will be accepted. Invesco requires that advisors it employs have a bachelor's degree and further coursework demonstrating appropriate knowledge. Examples of acceptable coursework include: an MBA, a CFP®, a CFA, a ChFC, JD, CTFA, PhD or CPA.
Professional Certifications
Employees have earned certifications and credentials that are required to be explained in further detail. Certified Financial Planner (CFP): Certified Financial Planners are licensed by the CFP Board to use the CFP mark. CFP certification requirements:
• Bachelor’s degree from an accredited college or university.
• Completion of the financial planning education requirements set by the CFP Board (www.cfp.net).
• Successful completion of the 10-hour CFP® Certification Exam.
• Three-year qualifying full-time work experience.
• Successfully pass the Candidate Fitness Standards and background check. Chartered Financial Analyst (CFA): Chartered Financial Analysts are licensed by the CFA Institute to use the CFA mark. CFA certification requirements:
• Hold a bachelor's degree from an accredited institution or have equivalent education or work experience.
• Successful completion of all three exam levels of the CFA Program.
• Have 48 months of acceptable professional work experience in the investment decision-making process.
• Fulfil society requirements, which vary by society. Unless you are upgrading from affiliate membership, all societies require two sponsor statements as part of each application; these are submitted online by your sponsors.
• Agree to adhere to and sign the Member's Agreement, a Professional Conduct Statement, and any additional documentation requested by CFA Institute. Invesco Asset Management Deutschland GmbH Page 34 of 36
Bernhard Langer, CFA
Educational Background:
• Date of birth: 24.6.1964
• M.A. Business Administration, Economics & Banking, University Munich Business Experience:
• Bayerische Vereinsbank 1989 – 1994
• Invesco since 1994 Disciplinary Information: n.a. Other Business Activities: none Additional Compensation: None Supervision: Bernhard Langer is supervised by Gregory McGreevey, Senior Managing Director Investments. He reviews Bernhard’s work through frequent office interactions as well as remote interactions. Greg McGreevey’s contact information: McGreevey, Gregory +1 (404) 479-2932
Uwe Draeger
Educational Background:
• Date of birth: 23.10.1964
• "Diplom-Ökonom", Hochschule für Ökonomie Berlin
• Master of Arts, City of London Polytechnic
• Master of Business Administration, Anglia Business School Cambridge Business Experience:
• Barra 1995 - 2000
• Metzler 2000 – 2005
• Invesco since 2005 Disciplinary Information: n.a. Other Business Activities: None Additional Compensation: None Supervision: Uwe Draeger, Director Investment Office, is supervised by Bernhard Langer, CIO-IQS. He reviews Uwe’s work through frequent office interactions as well as remote interactions. Invesco Asset Management Deutschland GmbH Page 35 of 36 Bernhard’s contact information: Bernhard_Langer@fra.invesco.com +49-69-29807310
Michael Fraikin
Educational Background:
• Date of birth: 15.11.1967
• M.S. Accounting & Finance, London School of Economics
• Bachelor of Arts, Combined European program, University Reutlingen/Middlesex University, London Business Experience:
• Commerzbank 1991 – 1997
• Invesco since 1997 Disciplinary Information: n.a. Other Business Activities: None Additional Compensation: None Supervision: Michael Fraikin is supervised by Bernhard Langer, Chief Investment Officer. He reviews Michael’s work through frequent office interactions as well as remote interactions. Bernhard’s contact information: Bernhard_Langer@fra.invesco.com +49-69-29807310
Alexander Uhlmann, CFA
Educational Background:
• Date of birth: 19.8.1973
• “Diplom Betriebswirt (FH)”, Frankfurt School of Finance & Mgmt. Business Experience:
• Dresdner Bank 1995 - 1997
• Invesco since 1997 Disciplinary Information: n.a. Other Business Activities: None Additional Compensation: None Supervision: Invesco Asset Management Deutschland GmbH Page 36 of 36 Alexander Uhlmann is supervised by Bernhard Langer, Chief Investment Officer. He reviews Alexander’s work through office interactions as well as frequent remote interactions. Bernhard’s contact information: bernhard_langer@fra.invesco.com +49 69 29 807 310 please register to get more info