DWS International GmbH (DWS International) is a registered investment adviser with the
Securities and Exchange Commission (“SEC”) and has offered its products and services to
clients, across a range of asset classes, investment strategies, and products since its
formation in December 1983. DWS International is part of the global investment management
business 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 (“DB AG”), a multi-national financial services
company (together with its affiliates, directors, officers, and employees). DWS International is a
direct subsidiary of DWS Group. The current shareholder structure is depicted below:
DWS International has established six branches (Netherlands, Italy, Spain, France, Sweden
and Austria) to date in which investment advisory services are being performed, as well as
places of business in Frankfurt (principial office), Berlin, Cologne and Munich, Germany.
DWS International provides discretionary and/or non-discretionary services to a variety of
client types, including one or more affiliated investment advisers. In addition, its activities with
respect to the non-U.S. clients are subject generally to regulation by the Federal Financial
Supervisory Authority, or such other regulatory organizations in Germany, as may have
jurisdiction over such German activities.
DWS International is an asset manager providing global capabilities with local expertise to
deliver a comprehensive line-up of investment products across a range of asset classes and
investing styles. DWS International’s advisory services are conform to investment policies and
guidelines that are established at the inception of the adviser-client relationship (as amended
from time to time) in cooperation with the client.
Since March 2018, DWS International was classified as a CRR-Investment firm. As of 26 June
2021, DWS International qualifies as an “investment firm” pursuant to the Markets in Financial
Instruments Directive (“MiFID”) or “investment services institution” in the meaning of the
German Investment Institutions Act (‘WpIG’).
Further, per November 2021 the company returned the license to execute placement business
as this activity was no longer pursued.
DWS International complies with the U.S. Investment Advisers Act of 1940 (the “Advisers Act”)
and the Investment Company Act of 1940 (the “Investment Company Act”) only with respect to
its U.S. clients. Non-U.S. clients will not be subject to the protections of the Advisers Act and
the Investment Company Act.
This brochure, including any brochure supplement, is intended for DWS International’s direct
advisory clients. Investors in any DWS International 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 International 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.
Types of investments
DWS International provides investment advice concerning “financial instruments,” including
without limitation, stocks (equity and fixed income), subscription rights, repurchase
agreements, mortgage-backed and asset-backed securities, convertible securities, foreign
debt securities (both sovereign and corporate), currencies, and derivatives. Derivatives include
derivative contracts (e.g. futures, forwards, options and swaps) and derivative securities (e.g.,
Treasury Strips and “structured securities”). To the extent consistent with client guidelines,
derivatives may be used to hedge various market or portfolio risks, to manage the effective
maturity or duration of fixed-income portfolios, as a substitute for or alternative to the
instruments available in the securities, currency, or other markets, or to enhance portfolio
returns.
Asset under management
As of December 31, 2023, DWS International had a total of $ 4 43,312,023,335.02
discretionary and $1,659,888,397.69 non-discretionary client Assets under Management.
Environmental, social and governance considerations
DWS International seeks to incorporate in its investment process environmental, social and
governance (“ESG”) risks and opportunities that could have 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, DWS International 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 DWS International advised funds, other pooled investment vehicles and separately
managed account strategies advised by DWS International 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 DWS International 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, DWS International 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 International
advised funds or other pooled investment vehicles, details relating to when and if ESG factors
are considered by DWS International 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 International may invest in issuers that do not reflect the ESG beliefs and
values of other investors. DWS International’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 International 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 International’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 International’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 DWS
International’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, DWS International’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.