Our contribution to a sustainable way of life

Principles for Responsible Investment

ACM is a signatory and follows the principles for responsible investment

ACM - Green Values


“ESG” or “Sustainability” are the buzzwords of our time. But too often they fade away as empty words. At ACM, we aim to live sustainable and have a positive impact on our environment.

We understand a sustainable way of life as an ongoing and integrative process. As a young company, we are always keen to align our processes in such a way that they are in harmony with our ecological, social and corporate ambitions.

ACM is a social company. We see ourselves as more than just a service provider and employer, but rather as a connecting network for our clients and employees.

In the following we have defined what our “Green Values” are.

Sustainable working environment

ACM has its offices in the Oksigen Building Kirchberg Luxembourg. The modern building was opened in 2016 and has a distinctive sustainability concept with controlled lighting, charging stations for e-cars or a direct connection to the tram.

In our office we try to avoid plastic products entirely and encourage the use of only recyclable materials.

ACM is on the way to becoming a “paperless company”. For the majority of our internal and external communications, we already use digital solutions to minimize our paper consumption.

Work-Life Balance

Accelerated by the outbreak of the COVID-19 pandemic, we could offer the flexibility to work from home. It soon became apparent, however, that although the dear colleagues were missing, the work processes could be quickly adapted to the new situation. By eliminating the need to commute to Luxembourg, there is more time for family and friends. Even after the COVID-19 pandemic, the “work from home” option is therefore an integral part of what we offer our employees.

Different life plans place different time obligations and needs on our employees. At ACM, we take this into account by allowing a flexible division of working hours and thus enable our employees to organize their everyday life in a way that it suits their individual needs.


According to a study by the statistical office Statec, Luxembourg has the lowest proportion of women in the total number of employees in Europe, at 38 percent. Even if the proportion of women in the financial sector (46 percent) is above the average, we see a need for further action here. As a sign of good corporate governance, ACM actively promotes gender equality and equal opportunities in the workplace. In our company, we therefore strive for an equal ratio of men and women at all levels.

Luxembourg as a financial centre stands for multicultural diversity. In the heart of Europe people from different cultures and different nationalities meet. At ACM, we see ourselves as part of this diversity.


Many of our employees live in Germany and have to commute to the office in Luxembourg every day. We want to keep our ecological footprint as small as possible and support our employees by assuming the cost of the ticket for cross-border public transport.

Local public transport is free within Luxembourg. This makes Luxembourg the first country in the world in which it is possible to travel by bus and train through the country without a ticket and thus allows us to move around in a climate-friendly way within its borders.

Unfortunately, sometimes a trip by car or plane is inevitable. That is why we support the ClimatePartner Foundation ( in their mission to create a CO2-free atmosphere.

ACM's "Sustainability Risk Policy"

Sustainability Risk Policy


No Consideration of adverse impacts of investment decisions on sustainability factors.
Avega Capital Management S.A. will generally not consider adverse impacts of investment decisions on sustainability factors due to absence of (i) sufficient data/ information and (ii) sufficient quality of such data/information to provide a meaningful assessment on the performance of any potential adverse impact of the investment decisions on sustainability factors in view of the lack of relevant information from target companies/investments.
However, individual financial products managed by Avega Capital Management S.A. may choose to consider PAIs as part of their sustainability strategy. Information on this can be found in the individual prospectuses of these funds. For the majority of the financial products, however, PAIs are currently not taken into account.