DWS Investments Australia Limited (“DIAL”) is a registered investment adviser with the
Securities and Exchange Commission (“SEC”) since July 2002. DIAL 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”). DIAL
is a direct subsidiary of DWS Group.
DIAL primarily performs advisory services for the United States SEC-registered investment
adviser RREEF America L.L.C. (“RREEF”). Pursuant to a master agreement with RREEF, DIAL
is contracted to provide sub-advisory services to RREEF’s funds and institutional clients on a
discretionary or non-discretionary basis. DIAL also separately manages special purpose
vehicles holding equity interests in real estate assets via management investment trust
structures on behalf of non-U.S. investors.
DIAL complies with the U.S. Investment Advisers Act of 1940 (the “Advisers Act”) and the
Investment Company Act of 1940, as amended (“Investment Company Act”) only with respect
to its U.S. clients. Non-U.S. clients of DIAL will not be subject to the protections of the Advisers
Act.
This Brochure, including any Brochure supplement, is intended for DIAL’s direct advisory
clients. Investors in any DIAL-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, DIAL relies on an order
issued by the Securities and Exchange Commission under the Investment Company Act of
1940, as amended (“ICA”) on October 20, 2020, permitting it to continue to provide investment
advisory services to investment companies registered under the ICA.
Client-Imposed Investment Restrictions
DIAL sub-advises real estate securities portfolios on behalf of separately managed accounts of
individual clients. As investment manager, RREEF works closely with these clients to
understand their individual investment goals and objectives and recommends targeted
investment strategies and vehicles. Subject to RREEF’s review, these clients may impose
investment restrictions on RREEF’s investment strategies for their accounts.
With respect to commingled funds (including registered investment companies) sub-advised by
DIAL, individual investors generally do not have an ability to impose restrictions on the
management of such vehicles. Such fund offerings are not tailored to address the specific
investment objectives or circumstances of individual investors.
Assets under Management
As of December 31, 2022, DIAL had $2,498,586,286.54 in assets under management, of
which $1,661,603,299.69 is managed on a discretionary basis, and $836,982,986.85 is
managed on a non-discretionary basis.
Environmental, Social and Governance Considerations
DIAL 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, DIAL 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.
Because investors can differ in their views of what constitutes positive or negative ESG
characteristics, DIAL may invest in issuers that do not reflect the ESG beliefs and values of
other investors. DIAL’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 DIAL 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.
Because of the inherent differences between Liquid Real Assets and DIAL’s illiquid strategies
encompassing Direct Real Estate and Real Estate Debt (the “Illiquid Strategies”), the approach
to incorporating ESG is tailored specifically to the strategy and in accordance with a client’s
investment objectives and requires different tools to be utilized to consider ESG in the
investment process.
Liquid Real Assets – Available ESG Tools
DIAL portfolio managers in the Liquid Real Assets (“LRA”) business may use the DWS
proprietary ESG engine and/or the LRA proprietary ESG models, each as outlined below, to
analyze the ESG attributes of a potential investment.
DWS Proprietary ESG Tool
DIAL’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 EGINEvendors 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.
DIAL’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 DIAL’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. Companies ranked C or better (generally the top 50% of issuers in each peer
group) are deemed to meet the DIAL’s sustainability criteria.
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, DIAL’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.
LRA Proprietary ESG Models
The LRA team has a separate and proprietary process (the “LRA ESG Models”) for using
selected ESG data sources relevant to their strategies. Currently, LRA has two dedicated ESG
strategies, which utilize the ratings and screens of the LRA ESG Models, as documented in the
investment guidelines for those strategies.