30% Club Germany Investor Group: Statement of Intent
As asset owners and asset managers, we are responsible for the stewardship of the investments wemake on behalf of our members and clients. Part of that responsibility includes the assessment of
the leadership of our investee companies.
The German government has committed to increasing the proportion of women on supervisoryboards to 30% by 20301 and introduced a law requiring companies to appoint at least one woman to
the management board.2 Yet this regulation does not apply to all DAX-listed companies and wewould expect it to take time to drive significant and sustainable change. Despite being one of thelargest economies in Europe where the initial talent pool is relatively evenly split3, Germany is lagging
behind its international peers with respect to gender equality at the very top of companies andchange continues to be slow.4
As of August 2023, women accounted for an average of 39% on the supervisory boards of the 40
largest German companies. However, only 22% of management board members on average werewomen and only one company had a female CEO.5 Looking at the MDAX, the proportion of women atthe executive level is even lower: 15.6% of board members are female, and there is not a single
female member on almost half of the boards. Moreover, nationwide, the share of women in the firstand second management levels is significantly lower than their share among all employees.6 It isconcerning that female representation in leadership positions decreases significantly with increasing
decision-making power, confirming a persistent glass ceiling that prevents women from reaching toppositions.
We believe both supervisory and management boards that genuinely embrace cognitive
diversity, as manifested through appropriate gender representation and a broad spectrum of skills
and experience, are more likely to achieve better outcomes for investors. There is increasing
research to support this hypothesis.7 Gender equality importance is also reflected through adedicated UN Sustainable Development Goal (SDG 5 – Gender Equality) making the issue among themost pressing ones to achieve by 2030.
In light of these considerations, 30% Club Germany Investor Group starts a business campaign aiming
to boost the number of women in board seats and executive leadership of DAX40 and MDAX
companies in Germany across various sectors. The main purpose of this Statement of Intent is tosignal the collective voice of the 30% Club Germany Investor Group to companies and the wider
marketplace, and to demonstrate how members are using their ownership rights and undertakestewardship to promote progress on gender diversity. The 30% Club Germany Investor Groupacknowledges the need for better corporate diversity in all its forms and our main objectives are as
follows:

1Gleichstellung von Frauen und Männern | Bundesregieurng (bundesregierung.de)
BMFSFJ - Zweites Führungspositionen-Gesetz - FüPoG II; applicable to management boards with at least 3members.
3
Women and Men in Germany (bmfsfj.de)4
AllBright+Bericht+Herbst+2022_EN.pdf (squarespace.com)
5
As of August 2023, company reported data;
6
Führungspositionen in Betrieben und Verwaltungen - Der Weg nach ganz oben bleibt Frauen oft versperrt(iab.de)
7
Steven Turban, Dan Wu and Leitan (LT) Zhang, “Research: When Gender Diversity Makes Firms MoreProductive”, Harvard Business Review, 11 February 2019.
2

1. Aspirational target of at least 30% by 2030 for DAX40
As members of the 30% Club Germany Investor Group, we expect executive management teams ofthe largest 40 German companies to attribute at least 30% of seats on management boards towomen by 2030. We aspire to include MDAX companies in this target going forward. In addition, weexpect from every DAX40 company to reach at least 30% of women on their supervisory board.
Research shows that critical mass is achieved once the 30% hurdle is passed.8 This is the point at
which the contributions of a minority group are heard and valued, and have an impact on thedecision-making dynamics of leaders. Higher female participation on management board level would
entail an important signalling function for lower levels of management. Yet this percentage target is
an aspirational goal that marks the starting point for wider engagement with companies (seeobjective 3). Instead of focusing on a quota for female participation, we seek to promote equal
opportunities.
2. Disclosure expectations from investee companies
As part of our overall stewardship responsibilities on behalf of our members and clients, we will
actively engage with investee companies on corporate governance issues, including the process used
to identify suitable candidates for executive management teams.
To enable investors to fully understand a company's diversity and inclusion policies as well aspractices and processes, we expect companies to be transparent about the procedures for seeking
and appointing new directors and how this process ensures a diverse leadership committee. We also
call on companies to provide information on how diversity materializes at every level ofmanagement, especially the share of women in the first and second management levels. We believe
this transparency will allow investors and other stakeholders to understand how companies promote
gender diversity. We expect the companies to build a gender diverse pipeline all the way to the top.
In addition, we expect to see evidence of a culture of commitment to gender diversity and inclusion
at the executive management level and across all the layers of the hierarchy. To better address theunderlying challenges in Germany, we will advocate for more transparency regarding the progress in
middle and senior managerial positions, the gender pay gap, paternity leave taken among men, andfamily-friendly company policies.
3. Engagement with investee companies
The engagement objective is to understand and encourage companies to work on the invisible
hurdles that hamper progress. Hence, we call on companies to consider women for operational roles
where they are often underrepresented and encourage companies to develop an internal female
talent pipeline, on which they can revert to for the appointment of a new woman at the executive
management team. Our engagements will target the chairperson of the board as well as CEOs andHead of Human Resources.
We will raise questions where there is evidence that there has been a failure in the nomination
process with respect to executive management diversity. Individually as investors, we may choose tovote against the re-election of the chair of the board or nomination committee, particularly where
there continues to be no evidence of diversity at executive management levels, and engagementwith the company has not led to any satisfactory outcome.
4. Reporting
We are committed to reporting, on a regular basis, examples of engagement activity as well as any

8The Lime Group, “Critical mass and tipping point in change efforts”

voting activity undertaken. The engagement might be reported through case studies where collective
engagement with some or all 30% Club Germany Investor Group members has taken place.
5. Examples of best practices
In addition to putting pressure on companies to perform better on diversity, the 30% Club Germany
Investor Group is keen to highlight examples of companies that are leading the way in this area.
6. Documentation
The 30% Club Germany Investor Group aims to provide companies with a list of key gender metrics
and disclosure expectations, as well as policies, best practices and processes that have provensuccessful in creating a gender diverse and inclusive workplace.
7. Compliance with Applicable Laws
The Investor Group shall comply with all laws, rules and regulations, if any, applicable to it inconnection with the performance of its commitments under this Statement of Intent as long as thenew legal objectives are more stringent than the ones originally set by the Investor Group.
The 30% Club Germany Investor Group does not require or seek collective decision-making or action
with respect to acquiring, holding, disposing and/or voting of securities. Participants are independent
fiduciaries responsible for their own investment and voting decisions and must always act completely
independently to set their own strategies, policies and practices based on their own best interests.
Members do not act or speak on behalf of each other.
The use of particular engagement tools and tactics, including the scope of participation inengagements led by members of the 30% Club Investor Group Germany, is at the discretion ofindividual signatories. The Investor Group facilitates the exchange of public information, but
signatories must avoid the exchange (including one-way disclosure) of non-public, competitivelysensitive information with other members and participants in engagements.
Members may not claim to represent other signatories or make statements referencing othersignatories without their consent. Any decision by signatories to take action with respect toacquiring, holding, disposing and / or voting of securities shall be at their sole discretion and made in
their individual capacities and not on behalf of the 30% Club Investor Group Germany or their othermembers. Members must avoid coordination of strategic behaviour between competitors thatimpacts competition.