DWS Investment S.A. DWS Portfolio

Sales Prospectus and Management Regulations January 31, 2021 DWS Investment S.A. currently manages the following investment funds in accordance­ with Part I of the Law of December 17, 2010, on undertakings for collective investment (As of: 01/31/2021): Investment fund in the legal form of a fonds commun de placement (FCP) AL DWS GlobalAktiv+ DWS Eurorenta DWS Vermögensmandat* ARERO – Der Weltfonds DWS Floating Rate Notes DWS Vorsorge* ARERO – Der Weltfonds – Nachhaltig DWS Garant 80 FPI DWS Vorsorge Geldmarkt DB Advisors Strategy Fund DWS Global Value DWS World Protect 90 DJE Gestión Patrimonial 2026 DWS India DWS Zeitwert Protect DWS Advisors Emerging Markets DWS Multi Asset Income Kontrolliert Global Emerging Markets Balance Portfolio Equities – Passive DWS Multi Asset PIR Fund Multi Opportunities DWS Concept ARTS Balanced DWS Multi Opportunities Multi Style – Mars DWS Concept ARTS Conservative DWS Osteuropa Südwestbank Vermögensmandat* DWS Concept ARTS Dynamic DWS Portfolio* Vermögensfondsmandat flexibel DWS Concept DJE Alpha Renten Global DWS Russia (80% teilgeschützt) DWS Concept DJE Responsible Invest DWS Strategic Balance Zurich* DWS ESG Euro Bonds (Long) DWS Strategic Defensive Zurich Vorsorge Premium II DWS ESG Euro Bonds (Medium) DWS Top Balance DWS ESG Euro Money Market Fund DWS Top Dynamic DWS ESG European Equities DWS Türkei DWS ESG Multi Asset Dynamic DWS USD Floating Rate Notes * Umbrella FCP Investment company with variable capital (SICAV) DB Advisors SICAV DWS Concept DWS Invest db Advisory Multibrands DWS Fixed Maturity DWS Invest II db PBC DWS FlexPension DWS Strategic db PrivatMandat Comfort DWS Funds Xtrackers DB PWM DWS Garant Xtrackers II DB Vermögensfondsmandat DWS Institutional Contents

A. Sales Prospectus – General Section 2 General regulations 2 Management Company 2 Depositary 2 Risk warnings 3 Investment principles 7 Risk management 12 Potential conflicts of interest 12 Prevention of money laundering and data protection 13 Legal status of the investors 14 Units 14 Costs 16 Liquidation of the fund / Amendment of the Management Regulations 18 Taxes 18 Selling restrictions 18 Investor profiles 20 Performance 20

B. Sales Prospectus – Special Section 21 DWS Euro Ultra Short Fixed Income Fund 21

C. Management Regulations 24

Legal structure Umbrella FCP according to Part I of the Law of December 17, 2010, on undertakings for collective investment.

General information

The legally dependent investment fund described of February 8, 2008”) and implementing Direc­ shall not be liable if and ­insofar as information in this Sales Prospectus is a Luxembourg tive 2007/16/EC2 (“­Directive 2007/16/EC”) in or representations are ­supplied that diverge investment fund (fonds commun de placement) Luxembourg law. from the Sales Prospectus or Management organized as an umbrella fund under Part I of the With regard to the provisions contained in Regulations. Luxembourg Law on collective investment under­ ­Directive 2007/16/EC and in the Grand-Ducal takings of December 17, 2010 (“Law of 2010”), Regulation of February 8, 2008, the guidelines and in compliance with the provisions of Directive of the Committee of European Securities Regu­ 1 Replaced by the Law of 2010. 2014/91/EU (amending Directive 2009/65/­EC lators (CESR) set out in the document “CESR’s 2 Commission Directive 2007/16/EC of March 19, 2007, (“UCITS Directive”)), Commission Delegated guidelines concerning eligible assets for invest­ implementing Council Directive 85/611/EEC on the Regulation (EU) 2016/438 of December 17, 2015, ment by UCITS”, as amended, provide a set of coordination of laws, regulations and administrative pro­ supplementing Directive 2009/65/EC of the Euro­ additional explanations that are to be observed visions relating to undertakings for collective ­investment pean Parliament and of the Council with regard to in relation to the financial instruments that are in transferable securities (UCITS) as regards the clarifica­ obligations of depositaries (“UCITS Regulation”), ­applicable for UCITS falling under the UCITS tion of certain definitions. 3 See CSSF circular 08/339 in the currently applicable as well as the provisions of the Grand-­Ducal ­Directive, as amended.3 version: CESR’s guidelines concerning eligible assets for Regulation of February 8, 2008, relating to It is prohibited to provide any information or investment by UCITS – March 2007, Ref.: CESR/07-044; certain definitions of the Law of December 20, to make any representations other than those CESR’s guidelines concerning eligible assets for invest­ 2002, on Undertakings for ­Collective Invest­ contained in the Sales Prospectus and in the ment by UCITS – The classification of hedge fund indices ment, as amended,1 (“­Grand-­Ducal ­Regulation Management Regulations. DWS Investment S.A. as financial indices – July 2007, Ref.: CESR/07-434.

1 A. Sales Prospectus – General Section

General regulations and at its own expense. DWS Investment GmbH through a nominee may at any time, by means is an investment company under German law. of a declaration, require of DWS Investment S.A. The Management Regulations of the fund are The contract can be terminated by either of the or the transfer agent that they themselves be attached to this Sales Prospectus. The Sales parties with three months’ notice. registered as unitholders if all the authentication Prospectus and the Management Regulations requirements are met. form a coherent unit and therefore complement Fund management encompasses the daily each other. implementation of the investment policy and Special note direct investment decisions. The designated fund The fund DWS Portfolio is a so-called umbrella manager may delegate all or part of fund man- The Management Company draws the attention of fund as defined by article 181 of the Law of 2010. agement services under its supervision, control investors to the fact that any investor may assert The investor may be offered one or more sub- and responsibility and at its own expense. his or her investor rights in their entirety directly funds at the discretion of the Management Com- against the fund only if the investor himself has pany. The aggregate of the sub-funds produces The fund manager may also engage investment subscribed to the fund’s units in his or her own the umbrella fund. Each unitholder participates in advisors at its own expense, control and respon- name. In cases where an investor has invested in the fund via the sub-fund. sibility. The investment advisory function encom- a fund through an intermediary that invests in its passes in particular the analysis and recommen- name but on behalf of the investor, not all investor The Sales Prospectus, the key investor informa- dation of suitable investment instruments for the rights can necessarily be asserted directly by the tion document and the Management Regula- assets of the fund. The fund manager is not investor against the fund. Investors are advised to tions, as well as the semiannual and annual bound by investment recommendations of the inform themselves about their rights. reports are available free of charge from the investment advisor. Any investment advisors Management Company and from the paying appointed by the fund manager are listed in the agents. The Management Company will provide special section of the Sales Prospectus. The Depositary the unitholders with other important information designated investment advisors possess any in an appropriate form. necessary regulatory approvals. The Management Company has, in accordance with the depositary agreement, appointed State Announcements to unitholders can be viewed (ii) Administration, registrar and transfer agent Street Bank International GmbH, acting through on the Management Company’s website at State Street Bank International GmbH, Luxem- www.dws.com. If provided for in a country of The Management Company DWS Investment S.A. bourg branch, as the Depositary as defined by distribution, announcements are additionally assumes the function of central administration. the Law of 2010. published in a newspaper or other publication The function of central administration particularly medium specified by law. Where required by includes fund accounting, the calculation of net State Street Bank International GmbH is a limited law in Luxembourg, publications will continue asset value, the subsequent monitoring of invest- liability company established under German law, to be published in at least one Luxembourg ment limits, as well as the function as domiciliary which has its registered office at Brienner Str. daily newspaper and, where appropriate, in the agent, registrar and transfer agent. It may under 59, 80333 Munich, Germany, and is registered Recueil Electronique des Sociétés et Associa- its own responsibility and at its own expense at the Munich registry court under the number tions (RESA) of the Commercial Register. transfer parts of this function to third parties. HRB 42872. It is a credit institution that is super- vised by the European Central Bank (ECB), the In view of its function as registrar and transfer German Federal Financial Supervisory Authority Management Company agent, DWS Investment S.A. has entered into a (BaFin) and the Deutsche Bundesbank. sub-transfer agent agreement with State Street The fund is managed by DWS Investment S.A., Bank International GmbH. Under this agreement, State Street Bank International GmbH, Luxem- Luxembourg (“Management Company”), which State Street Bank International GmbH will, in bourg branch, is authorized as a depositary by complies with the conditions set out in ­Chapter 15 particular, assume the tasks of administering the the CSSF in Luxembourg and specializes in of the Law of 2010 and thus with the provisions of global certificate deposited with Clearstream depositary and fund management services as the UCITS Directive. Banking AG, Frankfurt/Main. well as other similar services. State Street Bank International GmbH, Luxembourg branch, is The Management Company was established on (iii) Distribution registered in the Luxembourg Trade and Compa- April 15, 1987, and published in the Mémorial C nies Register under the number B 148.186. State on May 4, 1987. The subscribed and paid-in DWS Investment S.A. acts as the main Street Bank International GmbH is part of the capital amounts to EUR 30,677,400. The activity distributor. State Street corporate group, whose ultimate of investment fund management includes the parent company is State Street Corporation, tasks listed in Annex II to the Law of 2010, which DWS Investment S.A. may enter into nominee which is listed on the stock exchange in the is not exhaustive. agreements with credit institutions, Profession- United States. als of the Financial Sector (“PSF”) and/or com­ The Management Company may delegate one or parable companies under foreign law that are more tasks to third parties under its supervision obliged to identify unitholders. These nominee Functions of the Depositary and control, in accordance with the provisions of agreements entitle the institutions to distribute The relationship between the Management the Luxembourg Law of 2010 and Commission units and to be entered in the unit register as Company and the Depositary is governed by the de Surveillance du Secteur Financier (“CSSF”) nominee themselves. The names of the nomi- terms and conditions of the depositary agree- Regulation 10-04 and any circulars issued in nees can be requested at any time from DWS ment. The Depositary was entrusted with the respect thereof. Investment S.A. The nominee accepts purchase, following main tasks under the depositary sale and exchange orders from the investors it is agreement: (i) Investment management responsible for and arranges for the necessary changes in the unit register. In this respect, the –– ensuring that the sale, issue, redemption and The Management Company has concluded a nominee is in particular obliged to observe any cancellation of units takes place in accor- fund management agreement on behalf of the special conditions of purchase. Unless there are dance with applicable law and the Manage- fund with DWS Investment GmbH, Frankfurt/ mandatory legal or practical reasons to the ment Regulations; Main, under its own responsibility and control contrary, an investor who has acquired units

2 –– ensuring that the value of the units is deter- The Depositary has delegated these depositary Unit classes with the suffix “N” are open to mined in accordance with applicable law and duties set out in article 22 (5) (a) of the UCITS private investors. the Management Regulations; Directive to State Street Bank and Trust Com- –– carrying out the instructions of the Manage- pany, with registered office at One Lincoln Distribution policy ment Company, insofar as they do not violate Street, Boston, Massachusetts 02111, USA, For unit classes with the suffix “C”, income is applicable law and the Management which it has appointed as its global sub-deposi- reinvested (reinvesting units). Unit classes with Regulations; tary. As global sub-depositary, State Street Bank the suffix “D” indicate a distribution of income –– ensuring that, in transactions relating to the and Trust Company has appointed local sub-­ (distributing units). assets of a sub-fund, consideration is paid depositaries within its global custody network. within the customary time limits; Minimum investment –– ensuring that the income of a sub-fund is Information on the depositary functions that A minimum investment of EUR 10,000,000.00 used in accordance with applicable law and have been delegated and the identification of the applies for the purchase of units of the “I” unit the Management Regulations; respective agents and sub-agents is available at class. The Management Company reserves the –– monitoring the cash and cash flows of a the registered office of the Management right to deviate from these provisions in justified sub-fund; ­Company or on the following website: http:// individual cases. Subsequent purchases may be –– holding the assets of a sub-fund in custody, www.statestreet.com/about/office-locations/ made in any amount. including financial instruments to be held in luxembourg/subcustodians.html custody, reviewing ownership and keeping records of other assets. Unit classes Risk warnings The investor may be offered one or more unit Liability of the Depositary classes within the sub-fund at the discretion of Investing in the units involves risks. Risks may In the event of a loss of a financial instrument the Management Company. include or be associated with equity and bond held in custody which is determined in accor- market risks, interest rate, credit, counterparty dance with the UCITS Directive and in particular All unit classes of a sub-fund shall be invested default, liquidity and counterparty risks, as well article 18 of the UCITS Regulation, the Deposi- together in accordance with the investment as exchange rate, volatility and political risks. tary shall immediately return to the Management objectives of the respective sub-fund, but they Each of these risks can also occur together with Company operating in the name of the fund any may differ from each other, in particular with other risks. Some of these risks are briefly financial instrument of the same type or refund regard to their fee structure, the minimum discussed below. Potential investors should have the corresponding amount without delay. investment requirements for initial and subse- experience with the instruments that can be quent subscriptions, the currency, the distribu- used within the framework of the planned The Depositary shall not be liable if it can prove tion policy, the conditions to be met by investors investment policy. Investors should also be that the loss of a financial instrument held in or other specific characteristics, such as hedging, aware of the risks associated with investing in custody is attributable to external events that as determined in each case by the Management the units and should only make an investment cannot reasonably be controlled and the conse- Company. decision when they have received comprehen- quences of which could not have been avoided sive advice from their legal, tax and financial despite all reasonable efforts under the UCITS The net asset value per unit is calculated individ- advisors, auditors or other advisors on (i) the Directive. ually for each unit class issued for a particular suitability of an investment in the units, taking sub-fund. The respective sub-fund does not keep into account their personal financial and tax In the event of the loss of financial instruments a separate portfolio for the individual unit situation and other circumstances, (ii) the in­­ held in custody, unitholders may assert liability classes. formation contained in this Sales Prospectus claims against the Depositary directly or indi- and (iii) the investment policy of the relevant rectly through the Management Company, The Management Company reserves the right to sub-fund. provided that this does not lead to duplication of offer only one unit class or only certain unit claims for recourse or unequal treatment of the classes for sale to investors in certain jurisdic- It should be noted that a sub-fund’s invest- unitholders. tions so as to comply with the applicable laws, ments also contain risks as well as opportuni- customs or business practices there. Further- ties for price increases. The units of the fund The Depositary shall be liable to the fund for all more, the Management Company reserves the are securities whose value is determined by other losses incurred by the fund as a result of right to adopt principles that apply to certain the price fluctuations of the assets contained its negligent or intentional failure to comply with investor categories or transactions in respect of in the respective sub-fund. Accordingly, the its obligations under the UCITS Directive. the acquisition of certain unit classes. value of the units may rise or fall relative to the purchase price. The Depositary shall not be liable for indirect or The unit classes NC and IC are currently offered consequential damages or special damages or for the fund. The unit classes are denominated in Consequently, no assurance can be given that losses resulting from or in connection with the euro. Further information on unit classes that are the objectives of the investment policy will performance or non-performance of tasks and currently launched is available on the Internet at be achieved. duties by the Depositary. www.dws.com. Market risk Delegation Description of the suffixes The price or market performance of financial The Depositary shall have the broadest powers The fund currently generally offers unit classes products depends, in particular, on the perfor- to delegate all or part of its depositary functions, with different characteristics, which can be mance of the capital markets, which in turn are but its liability shall not be affected by the fact identified by the suffixes described below. affected by the overall economic situation and that it has entrusted all or part of the assets it is the general economic and political framework in to hold in custody to a third party. The liability of Investor type individual countries. Irrational factors such as the Depositary shall remain unaffected by the The suffix “I” indicates the investor type for sentiment, opinions and rumors can also have an delegation of its depositary functions under the which the unit class is intended. Unit classes effect on general price performance, particularly depositary agreement. with the suffix “I” are exclusively offered to on a stock exchange. institutional investors as defined by article 174 (2) of the Law of 2010.

3 Market risk associated with correction with essentially favorable tax conse- Custody risk sustainability risks quences for preceding fiscal years during which Custody risk describes the risk resulting from the Environmental, social or corporate governance he held an investment in the sub-fund, because basic possibility that in the event of insolvency, risks may affect the market price. Market prices he redeemed or sold his units before the end of violations of due diligence or improper conduct can therefore change if companies do not do a fiscal year in which a material error occurred. on the part of the Depositary or a sub-depositary, business sustainably and do not make invest- the assets held in custody could be partially or ments in sustainable changes. The strategic In addition, a correction of tax data for earlier completely withdrawn from access by the fund, alignments of companies that do not take sus- fiscal years can result in a situation where tax- to its detriment. tainability into account may also have a negative able income or tax benefits are assessed for tax effect on the market price. The reputational risk purposes in a different assessment period to the Company-specific risk that arises from companies failing to act in a actually applicable one and that this has a nega- The price performance of the securities and money sustainable way may also have negative conse- tive effect for the individual investor. market instruments held directly or indirectly by quences. Finally, physical damage caused by the fund is also dependent on company-specific climate change or measures to switch over to a Tax risks from hedging transactions factors, for example, on the economic situation of low-carbon economy may have negative effects for major investors the issuer. If the company-specific factors deterio- on the market price. The possibility that investment income tax on rate, the market value of the respective security German dividends and income from domestic may fall significantly and permanently, irrespective Creditworthiness risk dividend rights similar to equities that the invest­or of any generally positive stock market The creditworthiness (ability and willingness to originally generates may not be creditable or development. pay) of the issuer of a security or money market refundable in whole or in part cannot be ruled out. instrument held directly or indirectly by the The investment income tax is fully offset or Concentration risk sub-fund may subsequently decline. As a rule, refunded if (i) the investor holds German equities Additional risks may arise from a concentration this leads to price declines of the respective and German dividend rights similar to equities for of investments in particular assets or markets. security that exceed the general market 45 days without interruption within a period of The assets of the sub-fund then become particu- fluctuations. 45 days before and after the investment income larly heavily dependent on the performance of was payable (91 days in total) and (ii) bears no less these assets or markets. Country or transfer risk than 70% of the risk of a decline in value of the A country risk exists when a foreign borrower, units or dividend rights without interruption Risk of changes in interest rates despite ability to pay, cannot make payments at throughout that entire 45-day period (“45-day Investors should be aware that an investment in all, or not on time, because of the inability or rule”). Moreover, in order to receive an investment units may involve interest rate risks which may unwillingness of its country of domicile to exe- income tax credit, there may not be an obligation arise in the event of fluctuations in the interest cute transfers. This means that, for example, to directly or indirectly pay the investment income rates in the currency applicable to the securities payments to which the respective sub-fund is to another person (e.g., through swaps, securities or sub-fund. entitled may not occur, or may be in a currency lending transactions, repurchase agreements). For that is no longer convertible due to restrictions this reason, hedging or forward transactions that Legal and political risks on currency exchange. directly or indirectly hedge the risk arising from Investments for the fund may be undertaken in German equities or German dividend rights similar jurisdictions in which Luxembourg law does not Settlement risk to equities may be detrimental. Hedging transac- apply, or where, in the case of disputes, the Especially when investing in unlisted securities, tions on value and price indices are considered to place of jurisdiction is outside Luxembourg. Any there is a risk that settlement via a transfer be indirect hedges. To the extent that the sub-fund resulting rights and obligations of the Manage- system is not executed as expected because a is to be considered a related party of the investor ment Company for the account of the fund may payment or delivery did not take place in time or and enters into hedging transactions, these can differ from those in Luxembourg to the detriment as agreed. result in these being attributed to the investor, and of the fund or the investor. the investor therefore failing to comply with the Changes in the tax framework, 45-day rule. Political or legal developments, including changes tax risk to the legal framework in these jurisdictions, may The information provided in this Sales Prospec- In the event that investment income tax is not not be detected by the Management Company, tus is based on our understanding of current tax withheld from corresponding income that the or may be detected too late, or they may lead to laws. It is addressed to persons subject, without investor originally generates, hedging transac- restrictions in terms of acquirable assets or limitation, to individual or corporate income tax tions of the sub-fund can result in these being assets that have already been acquired. These in Germany. However, no responsibility can be attributed to the investor and the investor being consequences can also arise when the legal assumed for potential changes in the tax struc- required to remit the investment income tax to framework for the Management Company and/or ture through legislation, court decisions or the the tax office. the administration of the fund in Luxembourg orders of the tax authorities. changes. Currency risk In the case of a correction with tax conse- If the assets of the sub-fund are invested in Operational risk quences that are essentially unfavorable for currencies other than the fund currency, the The fund may be exposed to a risk of loss result- the investor, changes to the sub-fund’s taxation sub-fund will receive income, repayments and ing, for example, from inadequate internal pro- bases for earlier fiscal years made because proceeds from such investments in these other cesses and from human error or system failures these bases are found to be incorrect (e.g., currencies. If the value of these currencies falls at the Management Company or external third based on external tax audits) can result in the in relation to the sub-fund currency, the value of parties. This risk may adversely affect the perfor- investor having to bear the tax burden resulting the fund is reduced. mance of a sub-fund and thus also adversely from the correction for earlier fiscal years, even affect the net asset value per unit and the capital though he may not have held an investment in invested by the investor. the sub-fund in the relevant fiscal year at the time the material error occurred. Conversely, the investor may no longer benefit from a

4 Risks from criminal acts, therefore occur. At the same time, the probability Risks of investing in shortcomings, natural disasters that the issuer will meet these obligations is lower contingent convertibles or failure to take sustainability than for other bonds or debt instruments. This in Contingent convertibles (“CoCos”) are a form of into account turn leads to high price volatility of these hybrid financial instrument. From the perspective The fund may become a victim of fraud or other instruments. of the issuer, they act as a capital buffer and criminal acts. It may suffer losses due to errors contribute to the fulfillment of certain regulatory by employees of the Management Company or Risk of default capital requirements. Under their terms and of external third parties, or be damaged by In addition to the general trends on the capital conditions of issue, CoCos are either converted outside events such as natural disasters or markets, the price of an investment is also into shares or their principal amount is written pandemics. These events may be caused or affected by the particular developments of the down upon the occurrence of certain trigger exacerbated by failure to take sustainability into respective issuers. The risk of a decline in the events linked to regulatory capital thresholds. account. The Management Company strives to assets of issuers cannot be entirely eliminated, The conversion event can also be triggered by minimize operational risks and possible associ- for example, even through the most careful the supervisory authorities, independently of the ated financial consequences that could adversely selection of securities. trigger events and outside of the control of the affect the value of a sub-fund’s assets as much issuer, if the supervisory authorities call into as reasonably possible, and has set up processes Risks associated with question the long-term viability of the issuer, or and procedures to identify, manage and minimize derivative transactions of companies related to the issuer, as a going such risks. Buying and selling options, as well as the conclu- concern (conversion/write-down risk). sion of futures contracts or swaps (including total Inflation risk return swaps), involves the following risks: Following a trigger event, the recovery of the All assets are subject to a risk of devaluation capital invested depends essentially on the config- through inflation. –– Price changes in the underlying can cause a uration of the CoCo. CoCos can use one of the decrease in the value of the option or future, following three methods to recover their fully or Key individual risk and even result in a total loss. This can have a partially written-down nominal value: Conversion The exceptionally positive performance of certain negative effect on the value of the fund’s into shares, temporary write-down or permanent funds during a particular period is also attribut- assets. Changes in the value of the asset write-off. In the case of a temporary write-down, able to the abilities of the individuals acting on underlying a swap or a total return swap can the write-down is completely discretionary, taking behalf of such funds, and therefore to the correct also result in losses for the fund’s assets. into account certain regulatory restrictions. Any decisions made by their respective fund manage- –– Any necessary back-to-back transactions coupon payments after the trigger event are ment. Fund management personnel can change, (closing of position) incur costs that can based on the reduced nominal value. A CoCo however. New decision-makers might not be as reduce the value of the sub-fund’s assets. investor may therefore, under certain circum- successful. –– The leverage effect of options, swaps, stances, incur losses ahead of equity investors futures contracts and other derivatives may and other holders of debt instruments in respect Amendment of the investment policy alter the value of the sub-fund’s assets more of the same issuer. The risk associated with the fund may change in strongly than the direct purchase of underly- terms of content due to a change in the invest- ings would. In accordance with the minimum requirements set ment policy within the statutorily and contractu- –– The purchase of options entails the risk that out in the EU Capital Requirements Directive IV / ally permissible investment spectrum for the the call options are not exercised because Capital Requirements Regulation (CRD IV/CRR), sub-fund. the prices of the underlyings do not change the configuration of the terms and conditions of as expected, meaning that the sub-fund loses CoCos can be complex and can vary depending on Amendment to the Management the option premium it paid. If options are the issuer or the bond. Regulations; liquidation or merger sold, there is the risk that the sub-fund may The Management Company reserves the right to be obliged to buy assets at a price that is Investment in CoCos is associated with some amend the fund’s Management Regulations. In higher than the current market price, or additional risks, such as: addition, it may, in accordance with the provi- obliged to deliver assets at a price which is sions of the Management Regulations, com- lower than the current market price. In that a) Risk of falling below the specified trigger pletely liquidate the fund or merge it with case, the sub-fund suffers a loss amounting (trigger level risk) another fund. For the investor, this entails the to the price difference less the option pre- risk that the holding period planned by the mium received. The probability and the risk of a conversion or of investor will not be realized. –– Futures contracts also entail the risk that the a write-down are determined by the difference sub-fund’s assets may incur losses due to between the trigger level and the capital ratio of Credit risk market prices not having developed as the CoCo issuer currently required for regulatory Bonds or debt securities entail credit risk with expected at maturity. purposes. respect to the issuer, for which the issuer’s credit rating can be used as a measure. Bonds or debt Risk associated with the acquisition of The mechanical trigger is at least 5.125% of the instruments issued by issuers with a lower rating investment fund units regulatory capital ratio or higher, as set out in the are usually considered to be securities with a When investing in units of target funds, it should issue prospectus of the respective CoCo. Espe- higher credit risk and a higher probability of default be borne in mind that the fund managers of the cially in the case of a high trigger, CoCo investors by the issuer than those issued by issuers with a individual target funds operate independently of may lose the capital invested as, for example, in better rating. If an issuer of bonds or debt securi- one another, and it is therefore possible that the case of a write-down of the nominal value or ties encounters financial or economic difficulties, several target funds will be engaged in similar or a conversion into equity capital (shares). this may affect the value of the bonds or debt mutually opposing investment strategies. This can securities (which may fall to zero) and the pay- result in a cumulative effect of existing risks, and ments made on these bonds or debt securities any opportunities might be offset. (which may fall to zero). In addition, some bonds or debt instruments are also classified as subordi- nated in the financial structure of an issuer. In the event of financial difficulties, serious losses can

5 At sub-fund level, this means that the actual risk The CoCo investor can only resell the CoCo in a that the counterparty might no longer be able to of falling below the trigger level is difficult to secondary market, which is associated with meet its contractual obligations. These risks can assess in advance because, for example, the corresponding market and liquidity risks. affect the performance of the respective sub- capital ratio of the issuer may only be published fund, and can thus also adversely affect the net quarterly and therefore the actual gap between f) Equity capital and subordination risk asset value per unit and the capital invested by the trigger level and the capital ratio is only (risk of a reversal of the capital structure) the investor. known at the time of publication. In the case of conversion to shares, CoCo in­­ When OTC (over-the-counter) transactions are b) Risk of suspension of the coupon payment vestors become shareholders when the trigger entered into, the fund may be exposed to risks (coupon cancellation risk) occurs. In the event of insolvency, claims of relating to the creditworthiness of its counterpar- shareholders have subordinate priority and are ties and their ability to meet the terms of such The issuer or the supervisory authority can dependent on the remaining funds available. contracts. For example, the sub-fund may use suspend the coupon payments at any time. Any Therefore, a conversion of the CoCo may lead to futures, options and swap transactions or other lost coupon payments are not made up for when a total loss of capital. derivative techniques, such as total return swaps, coupon payments are resumed. For the CoCo in which the sub-fund is subject to the risk that the investor, there is a risk that not all of the coupon g) Risk of concentration on a sector counterparty will not fulfill its obligations under the payments expected at the time of acquisition will respective contract. be received. Due to the special structure of CoCos, the risk of concentration on one sector may arise due to the In the event of a counterparty’s bankruptcy or c) Risk of a change to the coupon uneven distribution of risks with regard to finan- insolvency, the respective sub-fund may suffer (coupon resetting risk) cial securities. By law, CoCos are part of the significant losses due to a delay in liquidating capital structure of financial institutions. positions, including the loss of value of the If the CoCo is not called by the CoCo issuer on investments while the sub-fund enforces its the specified call date, the issuer can redefine h) Liquidity risk rights. It is also possible that the use of the the terms and conditions of issue. If the issuer agreed techniques may be terminated through does not call the CoCo, the amount of the cou- CoCos entail a liquidity risk in a tense market bankruptcy, illegality or changes in the law in pon can be changed on the call date. situation. This is due to the special investor base comparison with those in force at the time of and the lower total market volume compared conclusion of the agreements. d) Risk due to prudential requirements with that of normal bonds. (risk of a reversal of the capital structure) Sub-funds may, among other things, enter into i) Income valuation risk transactions on OTC and interdealer markets. A number of minimum requirements in relation The participants in these markets are typically to the equity capital of banks were defined in Due to the fact that CoCos can be called on a not subject to financial supervision in the same CRD IV. The amount of the required capital buffer flexible basis, it is not clear which date should be way as the participants in regulated markets are. differs from country to country in accordance used for calculating the income. There is a risk on A sub-fund that invests in swaps, total return with the respective valid regulatory law appli­ each call date that the maturity of the bond will swaps, derivatives, synthetic instruments or cable to the issuer. be postponed and the income calculation must other OTC transactions in these markets then be adjusted to the new date, which can lead assumes the counterparty’s credit risk and is also At sub-fund level, the different national require- to a different yield. subject to the counterparty’s default risk. These ments have the consequence that the conversion risks can be materially different from those of as a result of the discretionary trigger or the j) Unknown risk regulated market transactions, which are secured suspension of the coupon payments can be by guarantees, daily mark-to-market valuations, triggered accordingly depending on the regulatory Due to the innovative nature of CoCos and the daily settlement and corresponding segregation law applicable to the issuer and that an additional highly changeable regulatory environment for and minimum capital requirements. Transactions uncertainty factor exists for the CoCo investor, or financial institutions, risks may arise that cannot concluded directly between two counterparties the investor, depending on the national conditions be foreseen at the present time. do not benefit from this protection. and the sole judgment of the respective compe- tent supervisory authority. For further information, please refer to the state- The sub-fund is also subject to the risk that the ment from the European Securities and Markets counterparty will not execute the transaction as Moreover, the opinion of the respective competent Authority (ESMA/2014/944) dated July 31, 2014, agreed, due to a discrepancy in the terms of the supervisory authority, as well as the criteria of regarding potential risks associated with investing contract (irrespective of whether or not it is in relevance for the opinion in the individual case, in contingent convertible instruments. good faith) or due to a credit or liquidity problem. cannot be conclusively assessed in advance. This may result in losses for the respective Liquidity risk sub-fund. This counterparty risk increases for e) Call risk and risk of the competent Liquidity risks arise when a particular security contracts with a longer maturity period, as ­supervisory authority preventing a call is difficult to sell. Only those securities that events may prevent a settlement, or if the sub- (­prolongation risk) can be resold at any time shall be acquired for fund has focused its transactions on a single a sub-fund. However, difficulties may occur in counterparty or a small group of counterparties. CoCos are perpetual long-term debt securities selling individual securities at the desired time that are callable by the issuer at certain call dates during certain phases or in certain market seg- If the counterparty defaults, a sub-fund may be defined in the issue prospectus. The decision to ments. In addition, there is a risk that securities subjected to opposing market movements during call is made at the discretion of the issuer, but it traded in a rather narrow market segment will be the execution of substitute transactions. A does require the approval of the issuer’s compe- subject to considerable price volatility. sub-fund may conclude a transaction with any tent supervisory authority. The supervisory author- counterparty. It can also conclude an unlimited ity makes its decision in accordance with appli­ Counterparty risk number of transactions with a single counter- cable regulatory law. The fund may incur risks in the context of a party. The ability of a sub-fund to conclude contractual relationship with another party (a transactions with any counterparty, the lack of a so-called “counterparty”). Here there is a risk meaningful and independent evaluation of the

6 counterparty’s financial characteristics and the longer be sufficient to fully cover the sub-fund’s In the context of environmental issues, the absence of a regulated market for concluding claim to delivery or retransfer with respect to the Management Company considers the following agreements can increase the sub-fund’s loss counterparty. aspects in particular in connection with climate potential. change: Sustainability risk – Environmental, Risks associated with the use Social and Governance (ESG) Physical climatic events or conditions of securities lending and Sustainability risk is an event or a condition repurchase agreements relating to environmental, social or governance –– Isolated extreme weather events If the counterparty to a securities lending or factors whose occurrence can have actual or –– Heat waves repurchase agreement defaults, the sub-fund may potential material negative effects on the value –– Droughts suffer a loss in such a way that the proceeds from of an investment. A sustainability risk can either –– Floods the sale of the securities held by the sub-fund in be a standalone risk or influence other risks and –– Storms connection with the securities lending or repur- materially contribute to risk, e.g., price risks, –– Hailstorms chase agreement are less than the collateral liquidity risks or counterparty risks, or operational –– Forest fires provided. In addition, the sub-fund may also suffer risks. –– Avalanches losses as a result of bankruptcy or similar pro- –– Long-term climate changes ceedings against the counterparty of the securi- These events or conditions are broken down –– Decreasing snow volumes ties lending or repurchase agreement or any other into the categories of Environmental, Social and –– Changes in the frequency and volume type of non-performance of the return of the Governance (ESG) and relate to the following of precipitation securities, e.g., loss of interest or loss of the topics, among others: –– Volatile weather conditions respective securities, as well as default and –– Rising sea levels enforcement costs in relation to the securities Environmental –– Changes in ocean currents lending or repurchase agreement. It is assumed –– Changes in winds that the use of acquisitions with repurchase –– Climate protection –– Changes in land and soil productivity options or a reverse repurchase agreement and –– Adaptation to climate change –– Reduced water availability (water risk) securities lending agreement will not have a –– Protection of biological diversity –– Ocean acidification material impact on the performance of the sub- –– Sustainable use and protection of water –– Global warming with regional extremes fund. However, the investment may have a signifi- and marine resources cant effect, either positive or negative, on the net –– Transition to a closed-loop economy, Transitional events or conditions asset value of the sub-fund. waste minimization and recycling –– Avoidance and reduction of –– Prohibitions and restrictions Risks associated with the acceptance environmental pollution –– Withdrawal from fossil fuels of collateral –– Protection of healthy ecosystems –– Other political measures associated with The sub-fund receives collateral for derivative –– Sustainable use of land the transition to a low-carbon economy transactions, securities lending transactions and –– Technological change associated with the repurchase agreements. Derivatives, lent securi- Social transition to a low-carbon economy ties and securities sold under repurchase agree- –– Changes in customer preferences and ments can increase in value. In that case, the –– Compliance with recognized labor behavior collateral provided might no longer fully cover the standards (no child labor or forced labor, sub-fund’s delivery or retransfer claim against the no discrimination) Sustainability risks may lead to a material counterparty. –– Compliance with occupational safety deterioration in the financial profile, liquidity, and health protection profitability or reputation of the underlying The sub-fund can invest cash collateral in blocked –– Appropriate remuneration, fair conditions investment. If the sustainability risks have not cash accounts, in high-quality government bonds in the workplace, diversity as well as been anticipated and taken into account in the or in money market funds with short-term ma­­ ­opportunities for training and development valuation of the investment, this may have a turity structures. However, it is possible for the –– Freedom to belong to a trade union and significant negative effect on the expected/ credit institution holding bank balances to freedom of assembly estimated market price and/or the liquidity of default. Government bonds and money market –– Assurance of sufficient product safety, the investment and therefore the sub-fund’s funds can perform negatively. When the transac- including health protection returns. tion is ended, the collateral thus invested might –– The same requirements of companies in the no longer be fully available, even though collat- supply chain eral must be returned by the sub-fund in the –– Inclusive projects and consideration of the Investment principles amount originally granted. In that case, the concerns of communities and social sub-fund can be obligated to top up the collateral minorities Investment policy to the amount granted, thereby compensating The respective sub-fund assets shall be invested for the loss incurred through the investment. Governance in accordance with the principle of risk diversifi- cation and the investment policy principles in the Risks associated with the –– Honesty in tax matters special section of the Sales Prospectus, and in management of collateral –– Measures to prevent corruption accordance with the investment opportunities The management of this collateral requires the –– Sustainability management by the and restrictions set out in article 4. deployment of systems and the definition of ­management board certain processes. The failure of these processes –– Management board compensation as well as human or system failure at the Manage- ­dependent on sustainability ment Company or external third parties in connec- –– Facilitation of whistle blowing tion with the management of collateral may result –– Assurance of workers’ rights in the risk that the collateral could depreciate or no –– Assurance of data protection –– Disclosure of information

7 Consideration of sustainability risks a separate verification of the rating by a DWS the relevant register of the European Securities in the investment process Investment GmbH committee determines that the and Markets Authority (“ESMA”). The Manage- The sub-fund management distinguishes investment is suitable nonetheless. During its ment Company has laid down robust written between the methods of ESG integration, verification, the committee will take into account plans for each benchmark that stipulate meas­ smart integration and customized approaches by further criteria such as development prospects ures that would take effect if the benchmark individual sub-fund managers when considering with regard to ESG criteria, the exercise of voting were to change materially or were no longer sustainability risks in making investment deci- rights and general economic development pros- made available. sions for the sub-fund. For each sub-fund, the pects. In the case of existing investments, if the method used by the sub-fund management to investment receives the lowest rating due to an A clarification is provided in the special section consider sustainability risks in making invest- updated analysis of the database, this rating is of the Sales Prospectus to indicate whether the ment decisions is disclosed in the special section verified by the committee. If the committee sub-fund is actively or passively managed, and of the Sales Prospectus. determines that the investment is still suitable, whether the sub-fund replicates a benchmark the investment does not have to be sold. If the index or is managed with the help of such an ESG integration: committee confirms the updated rating, the index. In the latter case, information is provided Besides the usual financial data, the sub-fund investments in question are sold. for the sub-fund as to the amount of latitude management takes sustainability risks into Investments excluded based on a rating by the available to deviate from the benchmark. account when making investment decisions. This database and the committee are no longer consideration applies to the entire investment included. Investments receiving a low, but Techniques for efficient process, i.e., for both the fundamental analysis of permitted, rating based on the database are portfolio management investments and for the decision itself. reviewed in particular for potential sustainability In accordance with CSSF circular 14/592, tech- In the fundamental analysis of investments, ESG risks. niques for efficient portfolio management may criteria are taken into account in particular in the In the fundamental analysis of investments, ESG be used for the sub-funds. These include, among proprietary market analysis. criteria are taken into account in particular in the other things, all forms of derivative transactions, In addition, ESG criteria are integrated into the proprietary market analysis. including total return swaps, as well as securities entire investment research process. This includes In addition, ESG criteria are integrated into the financing transactions, specifically securities identifying global sustainability trends, financially entire investment research process. This includes lending and repurchase agreements (securities relevant ESG topics and challenges. identifying global sustainability trends, financially financing transactions). Transactions other than Furthermore, risks that could arise from the relevant ESG topics and challenges. those mentioned here, such as margin lending effects of climate change or risks arising from the Furthermore, risks that could arise from the transactions, buy-sell-back and sell-buy-back violation of internationally accepted guidelines are effects of climate change or risks arising from transactions, are not currently being used. If the subjected to a special review. The internationally the violation of internationally accepted guide- Management Company makes use of these recognized guidelines include, in particular, the ten lines are subjected to a special review. The securities financing transactions in the future, principles of the United Nations Global Compact, internationally recognized guidelines include, in the Sales Prospectus will be amended the ILO Core Labor Standards, the UN Guiding particular, the ten principles of the United accordingly. Principles on Business and Human Rights and the Nations Global Compact, the ILO Core Labor OECD Guidelines for Multinational Enterprises. Standards, the UN Guiding Principles on Busi- The use of total return swaps and securities In order to take ESG criteria into consideration, ness and Human Rights and the OECD Guide- financing transactions shall be in accordance the sub-fund management also uses a special lines for Multinational Enterprises. with legal requirements, in particular Regulation database for investment decisions which collates If an investment is made in a company following (EU) 2015/2365 of the European Parliament and ESG data from other research companies as well the ESG-integrated fundamental analysis, these of the Council of November 25, 2015, on the as its own research results. investments continue to be monitored taking into transparency of securities financing transactions If an investment is made in a company following account ESG aspects. In addition, a dialog is and re-use and amending Regulation (EU) the ESG-integrated fundamental analysis, these sought with the companies regarding improving No. 648/2012 (SFT Regulation). investments continue to be monitored taking into corporate governance and stronger consideration account ESG aspects. In addition, a dialog is of ESG criteria. This occurs, e.g., through involve- Use of derivatives sought with the companies regarding improving ment as a shareholder in the company, in particu- Subject to an appropriate risk management corporate governance and stronger consideration lar through the exercise of voting rights and other system, the respective sub-fund may invest in of ESG criteria. This occurs, e.g., through involve- shareholder rights. any and all derivatives permitted under the Law ment as a shareholder in the company, in particu- of 2010 that are based on assets that may be lar through the exercise of voting rights and other Benchmarks acquired for the sub-fund or on financial indices, shareholder rights. A sub-fund can use an index or a combination of interest rates, exchange rates or currencies. In indices as a benchmark. Reference will be made particular, these include options, financial futures Smart integration: to such indices if the aim of the sub-fund is to and swaps (including total return swaps), as well Besides the usual financial data, the sub-fund replicate an index. They may also be used in as combinations thereof. These can be used not management takes both ESG criteria and sus- expressly or indirectly defining the portfolio only for hedging but may also be part of the tainability risks into account when making invest- composition, the targets and/or measurement investment strategy. ment decisions and excludes certain invest- of performance. ments. This consideration applies to the entire Trading in derivatives is conducted within the investment process, i.e., for both the fundamen- In accordance with Regulation (EU) 2016/1011 of confines of the investment limits and provides tal analysis of investments and for the decision the European Parliament and of the Council of for the efficient management of the sub-fund’s itself. June 8, 2016, on indices used as benchmarks in assets, while also managing investment matur- The sub-fund management uses a special data- financial instruments and financial contracts or to ities and risks. base which collates both ESG data from other measure the performance of investment funds research companies and its own research results. and amending Directives 2008/48/EC and After analyzing the data, this database allocates 2014/17/EU and Regulation (EU) No. 596/2014 the investments one of six possible ratings. If the and having regard to the transition period, a investment falls into the lowest category, the sub-fund may only use reference indices if the investment is not suitable for the sub-fund, unless benchmark or its administrator is registered in

8 Swaps OTC derivative transactions The sub-fund may enter into securities lending The Management Company may conduct the The Management Company may conduct both transactions only if they comply with the follow- following swap transactions for the account of those derivative transactions admitted for trading ing rules: the sub-funds within the scope of the invest- on a stock exchange or included in another ment principles: organized market and over-the-counter (OTC) (i) The sub-fund may only lend securities transactions. A process for accurate and inde- through a standardized system operated by a –– interest rate, pendent assessment of the value of OTC deriva- recognized clearinghouse or through a securi- –– currency, tives will be employed. ties lending program operated by a top-rated –– equity, financial institution that specializes in such –– total return or Securities lending and transactions and is subject to prudential rules –– credit default swaps. repurchase agreements considered by the CSSF to be equivalent to (securities financing transactions) those laid down in Community law. Swap transactions are exchange contracts in A sub-fund is authorized to transfer securities (ii) The borrower must be subject to prudential which the parties swap the assets or risks from its assets to a counterparty for a certain rules considered by the CSSF to be equiva- underlying the respective transaction. period of time in exchange for appropriate market lent to those laid down in Community law. consideration. The fund shall ensure that all (iii) The counterparty risk arising from one or Total return swaps securities transferred in the context of a securi- more securities lending transaction(s) with A total return swap is a derivative in which one ties lending operation can be returned at any respect to a single counterparty (which, for counterparty transfers to another counterparty time and that all securities lending agreements the avoidance of doubt, may be reduced by the total return of a reference liability including entered into can be terminated at any time. the use of collateral) may not exceed 10% of income from interest and fees, gains and losses the assets of the respective sub-fund when from price fluctuations, and credit losses. a) Securities lending transactions the counterparty is a financial institution within the scope of article 41 (1) (f) of the If a sub-fund makes use of the possibility of Provided that the investment guidelines of the Law of 2010, or 5% of its assets in all other using total return swaps or other derivatives with sub-fund contain no further restrictions in the cases. comparable characteristics in order to substan- special section below, the sub-fund may con- tially implement the investment strategy, infor- clude securities lending transactions. The res­ The Management Company shall disclose the mation on this, such as the underlying strategy pective restrictions on these transactions can total value of the lent securities in the annual and or the counterparty, can be found in the special be found in CSSF circular 08/356, as amended. semiannual reports. section of this Sales Prospectus and in the Securities lending transactions may only be annual report. carried out with regard to the assets permitted Securities lending transactions may also be under the Law of 2010 and the sub-fund’s invest- conducted synthetically (“synthetic securities Swaptions ment guidelines. lending”). In a synthetic securities loan, a secu- Swaptions are options on swaps. A swaption rity contained in the sub-fund is sold to a coun- is the right, but not the obligation, to conduct a These transactions may be entered into for one terparty at the current market price. The sale is, swap transaction, the terms of which are pre- or more of the following purposes: (i) reduction however, subject to the condition that the sub- cisely specified, at a certain point in time or of risk, (ii) reduction of cost and (iii) generation of fund simultaneously receives from the counter- within a certain period. additional capital or income with a level of risk party a securitized unleveraged option giving the that is consistent with the risk profile of the sub-fund the right to demand delivery at a later Credit default swaps sub-fund and with the risk-spreading rules appli- date of securities of the same kind, quality and Credit default swaps are credit derivatives that cable to it. As a rule, up to 80% of the securities quantity as the sold securities. The price of the enable the transfer of a volume of potential credit of the sub-fund may be transferred to counter- option (the “option price”) is equal to the current defaults to other parties. As compensation for parties in the course of securities lending trans- market price received from the sale of the accepting the credit default risk, the seller of the actions. However, the Management Company securities less (a) the securities lending fee, risk pays a premium to its counterparty. reserves the right to lend up to 100% of the (b) the income (e.g., dividends, interest pay- sub-fund’s securities to counterparties, depend- ments, corporate actions) from the securities In all other aspects, the information for swaps ing on market demand. whose return can be demanded upon exercise of applies accordingly. the option and (c) the exercise price associated An overview of the current actual extent to with the option. The option will be exercised at Securitized financial instruments which the securities have been transferred by the exercise price during the term of the option. The Management Company may also acquire the way of a loan can be found on the Management If the security underlying the synthetic securities financial instruments described in the preceding if Company’s website at www.dws.com. Securities loan is to be sold during the term of the option in they are securitized. The transactions pertaining to lending transactions may be conducted with order to implement the investment strategy, financial instruments may also be just partially respect to the assets of the sub-fund provided such a sale may also be executed by selling the contained in such securities (e.g., warrant-linked (i) that the transaction volume is kept at an option at the then prevailing market price less bonds). The statements on opportunities and risks appropriate level at all times or that the sub-fund the exercise price. apply accordingly to such securitized financial can require the return of the lent securities in a instruments, but with the condition that the risk of manner that enables them to meet their redemp- Securities lending transactions may also be loss in the case of securitized financial instru- tion obligations at all times and (ii) that these entered into with respect to individual unit ments is limited to the value of the security. transactions do not jeopardize the management classes, taking into account their respective of the sub-fund’s assets in accordance with specific characteristics and/or investor profiles, sub-fund’s investment policy. The risks associ- with any right to income and collateral under ated with these transactions shall be controlled such securities lending transactions arising at within the framework of the risk management the level of the relevant unit class. process of the Management Company.

9 b) Repurchase agreements (iv) The securities acquired by the sub-fund under duration of the agreement (taking into account a repurchase agreement must conform to the interest, dividends, other possible rights and any Unless otherwise provided for in the following investment policy and investment restrictions agreed discounts or minimum transfer amounts). special section, a sub-fund may (i) enter into of the fund and must be limited to: repurchase agreements, which consist of the To secure its obligations, a sub-fund can accept purchase and sale of securities with a clause –– short-term bank certificates or money all collateral that corresponds to the regulations granting the right to or imposing the obligation market instruments according to the of CSSF circulars 08/356, 11/512 and 14/592, as on the seller to repurchase from the buyer the definition in Directive 2007/16/EC of amended. securities sold at a price and at terms specified March 19, 2007; by the two parties in their contractual arrange- –– bonds issued or guaranteed by an OECD I. In the case of a securities loan, this collateral ment and (ii) enter into reverse repurchase member country or its local authorities or shall have been received before or at the time of agreements, which consist of forward trans­ by supranational institutions and authori- the transfer of the lent securities. If the securi- actions that at maturity impose on the seller ties at EU, regional or international level; ties are lent via intermediaries, the transfer of (counterparty) the obligation to repurchase the –– units of a UCI investing in money market the securities can take place before receipt of securities sold, and on the sub-fund the obliga- instruments that calculates a net asset the collateral as long as the respective intermedi- tion to return the securities received under the value daily and has a rating of AAA or an ary ensures the orderly completion of the trans- transaction (collectively the “repurchase equivalent rating; action. Such intermediary can provide collateral agreements”). –– bonds issued by non-governmental in place of the borrower. issuers that provide adequate liquidity; These transactions may be entered into for one and II. In general, collateral for securities lending or more of the following purposes: (i) achieving –– equities listed on or trading in a regulated transactions, reverse repurchase agreements additional income and (ii) short-term secured market in a member state of the Euro- and transactions with OTC derivatives (not investment. As a rule, up to 50% of the securi- pean Union or on a stock exchange in an including currency futures) must be provided in ties held in the sub-fund may be transferred to a OECD member country, as long as these one of the following forms: transferee in exchange for consideration (in the equities are contained in a major index. case of repurchase agreements) and securities –– liquid assets such as cash, short-term bank can be accepted within the scope of the respec- The Management Company shall disclose in its deposits, money market instruments accord- tively applicable investment limits against cash annual and semiannual reports the total amount ing to the definition in Directive 2007/16/EC (in the case of reverse repurchase agreements). of the open repurchase agreements as of the of March 19, 2007, letters of credit and However, the Management Company reserves respective reporting date. first-demand guarantees that are issued by the right, depending on market demand, to also top-rated credit institutions not affiliated with transfer up to 100% of the securities or cash Repurchase agreements may also be entered the counterparty, or bonds issued by an held in the sub-fund by way of a repurchase into with respect to individual unit classes, taking OECD member country or its local authorities agreement. Information on the proportion of into account their respective specific characteris- or by supranational institutions and authori- assets under management that are likely to be tics and/or investor profiles, with any right to ties at local, regional or international level, used in these transactions can be obtained from income and collateral under such repurchase irrespective of their residual term to maturity; the Management Company. agreements arising at the level of the relevant –– units of a UCI investing in money market unit class. instruments that calculates a net asset value A sub-fund can act either as purchaser or seller in daily and has a rating of AAA or an equivalent individual repurchase agreements or in a series of Choice of counterparty rating; continuing repurchase transactions. Its involve- The conclusion of OTC derivative transactions, –– units of a UCITS that invests predominantly ment in such transactions is, however, subject to including total return swaps, securities lending in the bonds and equities listed under the the following rules: transactions and repurchase agreements, is only next two indents; permitted with credit institutions or financial –– bonds (irrespective of their residual term to (i) The sub-fund may not buy or sell securities services institutions on the basis of standardized maturity) issued or guaranteed by top-rated using a repurchase agreement unless the master agreements. The counterparties, indepen- issuers with appropriate liquidity; or counterparty in that transaction is subject to dent of their legal form, must be subject to –– equities admitted to or trading in a regulated prudential rules considered by the CSSF to ongoing supervision by a public body, be finan- market in a member state of the European be equivalent to those laid down in Commu- cially sound and have an organizational structure Union or on a stock exchange in an OECD nity law. and the resources they need to provide the member country, as long as these equities (ii) The counterparty risk arising from one (or services. In general, all counterparties have their are contained in a major index. more) repurchase agreement(s) with respect headquarters in member countries of the Organi- to a single counterparty (which, for the sation for Economic Co-operation and Develop- III. Collateral that is not provided in the form of avoidance of doubt, may be reduced by the ment (OECD), the G20 or Singapore. In addition, cash or units of UCIs/UCITS must have been use of collateral) may not exceed 10% of the either the counterparty itself or its parent com- issued by a legal entity that is not affiliated with assets of the sub-fund when the counter- pany must have an investment-grade rating by the counterparty. party is a financial institution within the scope one of the leading rating agencies. of article 41 (1) (f) of the Law of 2010, or 5% All non-cash collateral received should be highly of its assets in all other cases. Collateral management for OTC liquid and traded at a transparent price on a (iii) During the term of a repurchase agreement derivative transactions and techniques regulated market or within a multilateral trading in which the fund acts as the purchaser, it for efficient portfolio management system so that it can be sold in the short term at cannot sell the securities that are the object A sub-fund may receive collateral for OTC deriva- a price close to the valuation established prior to of the contract until the right to repurchase tives and reverse repurchase agreements to the sale. The collateral received should also these securities has been exercised by the reduce counterparty risk. Within the scope of its comply with the provisions of article 56 of the counterparty, or until the repurchase term securities lending operations, the fund must UCITS Directive. has expired, except to the extent that the receive collateral of a value equal to at least 90% fund has other means of coverage. of the total value of the securities lent for the

10 IV. If collateral provided in the form of cash OTC derivative transactions The sub-fund shall ensure that it is able to assert exposes the sub-fund to a credit risk with its rights in relation to the collateral if an event respect to the administrator of this collateral, Overcollateralization level 102% to 133% occurs requiring the execution of these rights, such exposure shall be subject to the 20% meaning that the collateral shall be available at all restriction indicated in article 43 (1) of the Law of In securities lending transactions, it is some- times, either directly or through the intermediary 2010. In addition, such cash collateral may not be times possible to apply a full valuation if the of a top-rated financial institution or a wholly-­ held in custody by the counterparty unless it is counterparty’s credit quality and the collateral are owned subsidiary of that institution, in a form legally protected from the consequences of a excellent, whereas higher discounts can be that allows the sub-fund to appropriate or make default of the counterparty. applied for lower-rated equities and other securi- use of the assets provided as collateral if the ties, taking into account the counterparty’s credit counterparty does not comply with its obligation V. Non-cash collateral may not be held in cus- quality. Securities lending transactions are usu- to return the securities lent. tody by the counterparty unless it is adequately ally overcollateralized in accordance with the segregated from the counterparty’s own assets. following schedule: XI. Reinvestment of cash collateral may occur exclusively in high-quality government bonds or VI. Collateral that is provided must be adequately Securities lending transactions in money market funds with short-term maturity diversified in terms of issuers, countries and structures. Cash collateral can additionally be markets. If collateral fulfills a series of criteria Overcollateralization level invested by way of a reverse repurchase agree- such as standards for liquidity, valuation, credit for government bonds with ment with a credit institution if the recovery of quality of the issuer, correlation and diversifica- excellent credit ratings 103% to 105% the accrued balance is assured at all times. tion, it can be offset against the gross commit- Overcollateralization level Securities collateral, on the other hand, is not ment of the counterparty. If collateral is offset, for government bonds with permitted to be sold or otherwise provided as its value may be discounted by a certain percent- lower investment-grade ratings 103% to 115% collateral or pledged. age depending on the price volatility of the Overcollateralization level security. This discount (or “haircut”) is intended for corporate bonds with XII. A sub-fund that receives collateral for at to compensate for short-term fluctuations in the excellent credit ratings 105% least 30% of its assets should examine the value of the commitment and the collateral. As a Overcollateralization level associated risk as part of regular stress tests rule, no discounts are applied to cash collateral. for corporate bonds with conducted under normal and exceptional liquidity lower investment-grade ratings 107% to 115% conditions in order to assess the consequences The criterion of adequate diversification in terms Overcollateralization level of changes in market value and the liquidity risk of issuer concentration is considered to be for blue chips and mid-caps 105% associated with the collateral. The liquidity stress fulfilled if the sub-fund receives from a counter- testing strategy should contain guidelines cover- party, for efficient portfolio management or for VIII. The discounts applied are reviewed for ing the following aspects: transactions with OTC derivatives, a collateral appropriateness on a regular basis, at least once basket whereby the maximum total value of the each year, and are adjusted accordingly if a) the concept for analyzing the stress test open positions with respect to a particular issuer necessary. scenario, including calibration, certification does not exceed 20% of the net asset value. If and sensitivity analysis; the fund has various counterparties, the various IX. The sub-fund (or its representatives) perform a b) empirical impact assessment approach, different collateral baskets should be aggregated daily valuation of the collateral received. Should including back-testing of liquidity risk to calculate the 20% limit for the total value of the value of collateral previously provided appear assessments; the open positions with respect to an individual to be insufficient in view of the amount to be c) reporting frequency and reporting thresholds/ issuer. covered, the counterparty must provide additional loss tolerance threshold(s); and collateral at very short notice. If appropriate, d) loss-mitigation measures, including haircut VII. The Management Company pursues a safety margins shall apply to take into account the strategy and gap-risk protection. strategy for the valuation of discounts for assets exchange-rate or market risks associated with the it accepts as collateral (“haircut strategy”). The assets accepted as collateral. Use of financial indices discounts applied to collateral are governed by: If provided for in the special section of this Sales Collateral that is admitted for trading on a stock Prospectus, the objective of the investment a) the counterparty’s creditworthiness, exchange or admitted to or included in another policy of a sub-fund may be to replicate a specific b) the liquidity of the collateral, organized market is valued at the previous day’s index or to replicate an index through the use of c) the price volatility of the collateral, closing price or, if it is already available at the leverage. on the following basis: d) the credit quality of the issuer, and/or time the valuation takes place, at the closing e) the country or market in which the collateral price of the same day. The valuation is performed –– the composition of the index is sufficiently is traded. in such a way as to obtain a value for the collat- diversified; eral that is as close as possible to the market –– the index represents an adequate benchmark For collateral provided in connection with OTC value. for the market to which it refers; and derivative transactions, a discount of at least 2% –– the index is published in an appropriate is generally applied, e.g., for short-dated govern- X. Collateral is held in custody by the Depositary manner. ment bonds with outstanding credit ratings. or a sub-depositary. Cash collateral in the form of Consequently, the value of such collateral must bank balances may be held in blocked accounts If an index is replicated, then the frequency of exceed the value of the collateralized claim by at at the Depositary of the sub-fund or, with the adjustment of the composition of the index least 2% so that an overcollateralization level of Depositary’s consent, at another credit institu- depends on the index to be replicated. The at least 102% is reached. A correspondingly tion, provided that this other credit institution is adjustment is usually made semiannually, quar- higher discount of currently up to 33% (and a subject to supervision by a supervisory authority terly or monthly. Replication and adjustment of correspondingly higher overcollateralization level and is not associated with the guarantor. the composition of the index may give rise to of 133%) is applied for securities with longer costs that can reduce the value of the fund’s maturities or securities of lower-rated issuers. assets. OTC derivative transactions are usually over­ collateralized within the following range:

11 Risk management Potential conflicts of interest believes that such conflicts can be handled appropriately and assumes that the Counterparty A risk management process is used for the Within the scope of and in accordance with the possesses the aptitude and competence to sub-funds that allows the Management Com- applicable conflict management procedures and perform such valuations. pany to monitor and measure at any time the risk measures, the members of the Management associated with the investment positions and Company, Management Board members and In accordance with the respective terms agreed, their contribution to the overall risk profile of the Supervisory Board members of the Management DB Group Members may, in particular, act as a investment portfolio. Company, the management, the fund manager, Management Board members and Supervisory the designated distributors and the persons Board members, sales agent or sub-agent, The Management Company monitors each authorized to carry out the distribution, the Depos- depositary, sub-depositary, fund manager or sub-fund accordance with the requirements of itary, the investment advisor (if applicable), the investment advisor, and may offer to provide CSSF Regulation 10-04 and the Luxembourg or administrative office, the unitholders, as well as all financial and banking transactions to the Man- European Directives adopted from time to time, subsidiaries, affiliated companies, representatives agement Company. The Management Company in particular CSSF circular 11/512 of May 30, or agents of the aforementioned entities and is aware that conflicts of interest may arise due 2011, and the “Guidelines on Risk Measurement persons (“Associated Persons”): to the functions that DB Group Members per- and the Calculation of Global Exposure and form in relation to the Management Company. In Counterparty Risk for UCITS” of the Committee 1. conduct among themselves or for the fund respect of such eventualities, each DB Group of European Securities Regulators (CESR/10-788) financial and banking transactions or other Member has undertaken to endeavor, to a rea- and CSSF circular 14/592 of September 30, 2014. transactions, such as derivatives, securities sonable extent, to resolve such conflicts of For the fund, the Management Company shall lending and securities repurchase agree- interest equitably (with regard to the Members’ ensure that the total risk associated with deriva- ments, or enter into the corresponding respective duties and responsibilities), and to tive financial instruments in accordance with contracts, including those that are directed at ensure that the interests of the Management article 42 (3) of the Law of 2010 does not exceed the fund’s investments in securities or at Company and of the unitholders are not ad­­ 100% of the net assets of the fund and that the investments by an Associated Person in a versely affected. The Management Company is market risk of the fund does not exceed a total company or undertaking, such investment of the view that DB Group Members possess of 200% of the market risk of the non-derivative being a constituent part of the fund’s assets, the required aptitude and competence to per- reference portfolio (in the case of a relative VaR) or be involved in such contracts or form such duties. or not more than 20% (in the case of an absolute transactions; VaR). The Management Company is of the view that 2. for their own accounts or for the accounts of the interests of the Management Company and The risk management approach used for each third parties, invest in units, securities or the above-mentioned entities may be in conflict sub-fund is specified in the special section of the assets of the same type as the components with each other. The Management Company has Sales Prospectus for the sub-fund. of the fund’s assets and trade in them; taken appropriate measures to avoid conflicts of interest. In the event of unavoidable conflicts In general, the Management Company endeav- 3. in their own names or in the names of third of interest, the Management Company will ors to ensure that investments made in a sub- parties, participate in the purchase or sale of endeavor to ensure that conflicts of interest are fund through derivatives do not exceed twice the securities or other investments in or from the handled fairly and resolved in favor of the fund. value of the sub-fund’s assets (hereinafter fund through or jointly with the Management It is a principle of the Management Company to referred to as “leverage”), unless otherwise Company or the Depositary, or a subsidiary, take all reasonable steps to establish organiza- stated in the special section of the Sales Pro- an affiliated company, representative or agent tional structures and to apply effective adminis- spectus. The leverage effect is calculated using of these. trative measures to enable the identification, the “sum of notionals” approach (absolute handling and monitoring of the conflicts in ques- (notional) amount of each derivative divided by Assets of the fund in the form of liquid assets or tion. In addition, the Company’s management is the current net value of the portfolio). Derivatives securities may be deposited with an Associated responsible for ensuring that the systems, in the portfolio are taken into account when Person in accordance with the legal provisions controls and procedures of the Management calculating the leverage effect. Collateral is not governing the Depositary. Liquid assets of the Company for the identification, monitoring and currently reinvested and is therefore not taken fund assets may be invested in certificates of resolution of conflicts of interest are appropriate. into account. deposit issued by an Associated Person or in bank deposits offered by an Associated Person. Transactions with or between Associated However, this leverage varies depending on Banking or comparable transactions may also be ­Persons may be conducted for the fund with market conditions and/or changes in positions conducted with or through an Associated Person. respect to the fund assets, provided that such (also to hedge the fund against unfavorable Companies in the Deutsche Bank Group and/or transactions are in the best interests of the market movements). Therefore, despite constant employees, representatives, affiliated companies investors. monitoring by the Management Company, the or subsidiaries of companies in the Deutsche target ratio could be exceeded at some point. Bank Group (“DB Group Members”) may be Specific conflicts of interest in relation The expected leverage indicated is not to be counterparties in the Management Company’s to the Depositary or sub-depositaries considered as an additional risk limit for each derivative transactions or derivatives contracts The Depositary is part of an international group sub-fund. (“Counterparty”). In addition, in some cases a of companies and operations which, in the Counterparty may be required to value such ordinary course of business, is also active for a In addition, the sub-fund may borrow 10% of its derivative transactions or contracts. These valua- large number of clients and for its own account, net assets if this borrowing is temporary. tions can be used as a basis for calculating the which may lead to actual or potential conflicts value of certain assets of the fund. The Manage- of interest. Conflicts of interest arise when the A correspondingly greater overall exposure can ment Company is aware that DB Group Mem- Depositary or a company affiliated with it exer- therefore significantly increase the opportunities bers may possibly be involved in a conflict of cises activities under the depositary agreement and risks of an investment (see in particular the interest if they act as a Counterparty and/or or separate contractual or other arrangements. risk information in the section “Risks associated provide such information. The valuation will be These activities include: with derivative transactions”). adjusted and carried out in a manner that is verifiable. However, the Management Company

12 (i) the provision of nominee, management, (1) conflicts arising from the choice of sub-­ Prevention of money laundering registration and transfer agent, research, depositaries and the allocation of assets and data protection securities lending, investment management, among multiple sub-depositaries which, in financial advisory and/or other advisory addition to objective evaluation criteria, are Combating money laundering services to the fund; influenced by (a) cost factors such as the The transfer agent may require such proof of (ii) the execution of banking, sales and trading lowest fees charged, discounts and similar identity as it considers necessary for compliance transactions, including foreign exchange, incentives, and (b) the broad mutual busi- with the anti-money laundering legislation in derivative, credit, brokerage, market making ness relationships in which the Depositary force in Luxembourg. If there are doubts as to or other financial transactions with the fund, may operate on the basis of the economic the identity of an investor or if the transfer agent either as a principal and in its own interest value of the broader business relationship; does not have sufficient information to establish or on behalf of other clients. (2) affiliated or non-affiliated sub-depositaries the identity, the transfer agent may request acting on behalf of other clients and in their further information and/or documents in order to In connection with the above activities, the own interest, which may lead to conflicts of establish the identity of the investor beyond Depositary or its affiliated companies: interest with the interests of the client; doubt. If the investor refuses or fails to provide (3) affiliated or non-affiliated sub-depositaries the requested information and/or documents, the (i) will seek to make a profit from these activi- maintaining only indirect relationships with transfer agent may refuse or delay the entry of ties, and are entitled to receive and retain clients, and considering the Depositary to the investor’s data in the Company’s register of any profits or remunerations of any kind. be their counterparty, which may encourage unitholders. The information provided to the They are not required to notify the fund of the Depositary to act in its own interest or transfer agent shall be obtained solely for the the nature or amount of any such profits or in the interest of other clients to the detri- purpose of complying with anti-money launder- compensation, including but not limited to ment of clients; and ing legislation. fees, costs, commissions, income shares, (4) sub-depositaries potentially having market-­ spreads, markups, markdowns, interest, based creditor rights with respect to clients’ The transfer agent is also obligated to verify the reimbursements, discounts or other bene- assets, which they may be interested in origin of the funds collected by a financial institu- fits received in connection with such enforcing if they do not receive payment for tion, unless the financial institution in question is activities; securities transactions. subject to a mandatory proof of identity procedure (ii) may buy, sell, issue, trade or hold securities that is equivalent to the verification procedure or other financial products or instruments as In the performance of its duties, the Depositary under Luxembourg law. The processing of sub- principals in their own interest, in the inter- shall act honestly, fairly, professionally, inde- scription applications may be suspended until the est of their affiliated companies or for their pendently and in the sole interest of the fund transfer agent has duly established the origin of other clients; and its unitholders. the funds. (iii) may trade in the same or the opposite direction to the transactions carried out, The Depositary shall functionally and hierarchi- Initial or follow-up unit subscription applications including on the basis of information in their cally separate the performance of its depositary can also be submitted indirectly, i.e., via the possession but not available to the fund; tasks from the performance of its other duties, distributors. In this case, the transfer agent may (iv) may provide the same or similar services to which may be in conflict. The internal control waive the aforementioned required proof of other clients, including competitors of the system, the various reporting lines, the allocation identity under the following circumstances or fund; of tasks and reporting to management enable under the circumstances which are considered (v) may obtain creditor rights from the fund, potential conflicts of interest and matters related sufficient under Luxembourg’s anti-money which they may exercise. to the depositary function to be properly identi- laundering legislation: fied, managed and monitored. The fund may engage in foreign exchange, spot –– if a subscription application is processed or swap transactions on behalf of the sub-fund Furthermore, in the case of sub-depositaries through a distributor under the supervision through an affiliated company of the Depositary. used by the Depositary, contractual restrictions of the competent authorities, whose rules In such cases, the affiliated company acts as shall be imposed by the Depositary in order to provide for an identification verification the principal and not as a broker, contractor or take account of some of the potential conflicts; procedure for customers which is equivalent trustee of the fund. The affiliated company will the Depositary shall exercise due diligence and to that laid down in Luxembourg anti-money seek to generate profits through these transac- supervise the sub-depositaries in order to ensure laundering legislation and to which the tions and is entitled to retain profits and not a high level of service for its clients. The Deposi- distributor is subject; notify the fund. The affiliated company shall tary shall also provide regular reports on the –– if a subscription application is processed enter into such transactions under the terms activities of its clients and the portfolios held by through a distributor whose parent company and conditions agreed with the fund. its clients, with the underlying functions subject is under the supervision of the competent to internal and external control audits. Finally, the authorities, whose rules provide for an identi- If the cash of the fund is deposited with an Depositary shall separate the performance of its fication verification procedure for customers affiliated company which is a bank, a potential depositary duties internally from its own activi- which is equivalent to that laid down in conflict arises with respect to the interest (if ties and comply with a code of conduct that Luxembourg anti-money laundering legisla- any) credited or charged by the affiliated com- obliges employees to act ethically, honestly and tion, and if the law applicable to the parent pany to this account and the fees or other transparently in dealing with clients. company, or the parent company’s group benefits it could derive from holding such cash guidelines, impose equivalent obligations on as a bank rather than as a trustee. Current information on the Depositary, its duties, its subsidiaries or branches. any conflicts that may arise, the depositary The Management Company may also be a functions delegated by the Depositary, the list of For countries that have ratified the Financial client or counterparty of the Depositary or its agents and sub-agents, and any conflicts of Action Task Force’s (FATF) recommendations, it is affiliated companies. interest arising from such delegation shall be generally assumed that natural or legal persons made available to unitholders on request by the operating in the financial sector are required by Conflicts arising from the use of sub-depositar- Depositary. the respective competent supervisory authorities ies by the Depositary may be assigned to four in these countries to carry out identification general categories:

13 verification procedures for their clients which are If an investor is classified as a beneficial owner Units equivalent to the verification procedure pre- as defined by the Law of 2019, the fund is scribed under Luxembourg law. obliged, pursuant to the Law of 2019 and subject Bearer units securitized by to criminal sanctions, to collect and transmit global certificates Distributors may provide a nominee service to information. Likewise, the respective investor is The Management Company may decide to issue investors who purchase units through them. himself obliged to provide information. If an bearer units securitized by one or more global Investors may decide, at their own discretion, investor is not able to check whether or not he is certificates. whether to take advantage of this service, in classified as a beneficial owner, he can contact which the nominee holds the units in its name the fund via the following e-mail address to seek These global certificates shall be issued in the for and on behalf of the investors; the investors clarification: [email protected]. name of the Management Company and depos- are entitled to demand direct ownership of the ited with the clearinghouses. The transferability units at any time. Notwithstanding the foregoing Data protection of the bearer units securitized by a global certifi- provisions, investors are free to make invest- The personal data of investors in the application cate shall be subject to the applicable statutory ments directly with the Management Company forms and other information collected in connec- provisions in force as well as the rules and without using the nominee service. tion with the business relationship with the procedures of the clearing house responsible for Management Company will be collected, stored, the transfer. Investors receive the bearer units Luxembourg Register of Beneficial compared, transferred and otherwise processed securitized by a global certificate by entering Owners (transparency register) and used (“processed”) by the Management them in the custody accounts of their financial The Luxembourg Law of January 13, 2019, on Company and/or other companies of DWS, the intermediaries, which are held directly or indi- the introduction of a Register of Beneficial Depositary and the financial intermediaries of the rectly at the clearing houses. Such bearer units Owners (the “Law of 2019”) entered into force investors. These data are used for the purposes securitized by a global certificate are freely on March 1, 2019. The Law of 2019 obliges all of account management, money laundering transferable in accordance with the provisions entities registered in the Luxembourg Trade and investigations, tax assessment in accordance contained in this Sales Prospectus, the regula- Companies Register, including the fund, to with EU Directive 2003/48/EC on taxation of tions applicable on the respective stock exchange collect and store certain information on their savings income in the form of interest payments and/or the regulations of the respective clearing- beneficial owners. The fund is furthermore and the development of business relationships. house. Unitholders who do not participate in obliged to enter the collected information in the such a system may only transfer bearer units Register of Beneficial Owners, which is adminis- For this purpose, the data may also be communi- securitized by a global certificate via a financial tered by the Luxembourg Business Register cated to companies commissioned by the Man- intermediary participating in the settlement under the supervision of the Luxembourg Minis- agement Company in order to support the activi- system of the relevant clearinghouse. try of Justice. In this respect, the fund is obliged ties of the Management Company (e.g., client to monitor the existence of beneficial owners communication agents and paying agents). Payments of distributions for bearer units securi- continuously and in relation to particular circum- tized by global certificates shall be made by way stances and to notify the Register. of crediting the securities account opened with Legal status of the investors the relevant clearinghouse by the financial inter- Article 1 (7) of the Law of November 12, 2004, mediaries of the unitholders. on combating money laundering and terrorist The Management Company invests the capital financing defines a beneficial owner, inter alia, as invested in the fund in its own name for the All units within a unit class have the same rights. any natural person that ultimately owns or con- collective account of investors (unitholders) in The rights of unitholders in different unit classes trols a company. In this case, this includes any accordance with the principle of risk diversifica- within the respective sub-funds may differ, natural person in whose ownership or under tion in securities, money market instruments and provided that this has been clarified in the sales whose control the fund ultimately lies by way of other eligible assets. The invested capital and the documentation for the respective units. The directly or indirectly holding a sufficient quantity assets acquired form the fund assets, which are differing configuration of different unit classes is of units or voting rights or a participation, includ- held separately from the Management Compa- specified in the respective special section of the ing in the form of bearer units, or by means of ny’s own assets. Sales Prospectus. Units are issued by the Com- another form of control. pany immediately after the net asset value per The unitholders are joint owners of the fund’s unit has been received for the benefit of the If a natural person has a share of 25% plus one assets in proportion to the number of units they Company. unit or an interest of more than 25% in the fund, hold. Their rights are represented by bearer units this is deemed to be an indication of direct in the form of global certificates. All fund units Due to the Law of July 28, 2014, on the immo­ ownership. If a company that is controlled by one have the same rights. bilization of bearer shares and units (“Law of or more natural persons or if several companies 2014”), a new legal provision was drawn up in that are controlled by the same natural person or With respect to the legal relationship between respect of bearer shares and units (the “units”). persons respectively has or have a share of 25% unitholders, each sub-fund is treated as a sepa- The Law of 2014 makes provisions that units plus one unit or an interest of more than 25% in rate entity. In relation to third parties, the assets issued by Luxembourg stock corporations and the fund, this is deemed to be an indication of of a sub-fund are only liable for the liabilities and partnerships limited by shares (Kommanditge- indirect ownership. payment obligations relating to that sub-fund. sellschaften auf Aktien) as well as by investment The investment restrictions set out in the Man- funds (“fonds commun de placement”) must be Besides the stated reference points for direct agement Regulations apply to each sub-fund deposited and registered with the appointed and indirect ownership, there are other forms of separately, but the investment limits set out in Depositary. Deutsche Bank Luxembourg S.A., control according to which an investor can be the article 4 B. k), sentence 2, shall apply to the 2, Boulevard Konrad Adenauer, 1115 Luxem- classified as a beneficial owner. In this respect, fund as a whole. Additional sub-funds may be bourg, Luxembourg, was appointed as Deposi- an analysis is conducted in the individual case if established and/or one or more existing sub- tary within the meaning of the Law. indications of ownership or control are present. funds may be liquidated or merged at any time. In this case, the sales documentation will be amended accordingly.

14 If the units are not deposited and registered by The Management Company is authorized to issue The Management Company reserves the right, February 18, 2016 at the latest, the Law of 2014 new units on an ongoing basis. The Management taking into account the principle of equal treat­ makes provisions for the mandatory deletion of Company does, however, reserve the right to ment of all unitholders, to dispense with mini­ the units. A capital reduction takes place due to suspend or permanently discontinue the issue of mum redemption amounts (if provided for). the deletion of these units. The corresponding units. In this case, payments already made will be amount is deposited with the “Caisse de Consig­ refunded immediately. The unitholders will be The Management Company, having regard to the nation” until a person that can legally prove his or informed immediately of the termination and fair and equal treatment of unitholders and taking her ownership demands reimbursement. resumption of the issue of units. into account the interests of the remaining unitholders of the sub-fund, may decide to defer Calculation of the NAV per unit Units can be purchased from the Management redemption requests as follows: To calculate the unit value, the value of the Company and the paying agents. If the Manage­ assets belonging to the fund, less the liabilities ment Company no longer issues new units, units If redemption requests are received with respect of the fund, is determined on each valuation date can only be acquired via the secondary market. to a Valuation Date (the “Original Valuation and divided by the number of units in circulation. Date”) whose value, individually or together with An example calculation for determining the issue other requests received with respect to the Details on the calculation of the unit value and price is as follows: Original Valuation Date, exceeds 10% of the net asset valuation are laid down in the Management asset value of a sub-fund, the Management Regulations. Net fund assets EUR 1,000,000.00 Company reserves the right to defer all redemp­ ÷ Number of units tion requests in full with respect to the Original On public holidays that are bank business days in in circulation Valuation Date to another Valuation Date (the a country that is relevant for the valuation date, on the reporting date 10,000.00 “Deferred Valuation Date”) but which shall be as well as on December 24 and 31 of each year, Net asset value per unit EUR 100.00 no later than 15 Business Days from the Original the Management Company and the Depositary + Initial sales charge Valuation Date (a “Deferral”). currently refrain from determining the net asset (e.g., 5%) EUR 5.00 value per unit. A different calculation of the net Issue price EUR 105.00 The Deferred Valuation Date will be determined asset value per unit is published in suitable by the Management Company taking into newspapers in each country of distribution account, amongst other things, the liquidity (if necessary), as well as on the Internet at Rejection of subscription orders profile of the sub-fund and the applicable market www.dws.com. The Management Company reserves the right, at circumstances. its own discretion, to reject or accept in whole or Issue of units in part subscription orders for units at its own In the case of a Deferral, redemption requests Fund units are issued on each valuation date at discretion. received with respect to the Original Valuation the unit value plus the initial sales charge to be Date, will be processed based on the net asset paid by the purchaser of units in favor of the The Management Company also reserves the value per unit calculated on the Deferred Valua­ Management Company. The initial sales charge right to withhold any excess subscription credit tion Date. All redemption requests received with may be withheld in part or in full by the inter­ until final settlement. If an order is rejected in respect to the Original Valuation Date will be mediaries to compensate for sales activities. If whole or in part, the subscription amount or the processed in full with respect to the Deferred stamp duties or other charges are incurred in a corresponding balance shall be repaid to the first Valuation Date. country in which units are issued, the issue price named applicant at the risk of the person(s) increases accordingly. entitled thereto without interest immediately Redemption requests received with respect to after the decision of non-acceptance has been the Original Valuation Date are processed on a The fund units can also be issued as fractional taken. priority basis over any redemption requests units with up to three decimal places. Fractional received with respect to subsequent Valuation units are rounded to the nearest thousandth Redemption of units Dates. Redemption requests received with according to commercial practice. Such rounding Fund units are redeemed on each valuation respect to any subsequent Valuation Date will be may be to the benefit of either the respective date at the unit value less the redemption fee deferred in accordance with the same Deferral unitholder or the fund. to be paid by the unitholder. No redemption fee process and the same Deferral period described is currently charged. If stamp duties or other above until a final Valuation Date is determined to Newly subscribed units will only be allocated to charges are incurred in a country in which units end the process on deferred redemptions. the respective investor upon receipt of payment are redeemed, the redemption price decreases by the Depositary or the approved correspondent accordingly. In these circumstances, exchange requests are banks. However, the corresponding units will treated as redemption requests. already be taken into account for accounting Unitholders may submit all or a portion of their purposes in the calculation of the net asset value units of all unit classes for redemption. The Management Company will publish infor­ on the value date following the corresponding mation on the decision to start a Deferral and securities settlement and can be canceled until The Management Company has the right to the end of the Deferral for the investors who receipt of payment. If an investor’s units are to carry out substantial redemptions only once the have applied for redemption on the website be canceled due to non-payment or late payment corresponding assets of the sub-fund have been www.dws.com. of these units, this may result in a loss for the sold. In general, redemption requests above 10% fund. of the net asset value of the sub-fund are consid­ The Deferral of the redemption and the exchange ered to be substantial redemptions. The Manage­ of units does not have any effect on the other ment Company is under no obligation to execute sub-funds. redemption requests if any such request pertains to units valued in excess of 10% of the net asset Units can be redeemed with the Management value of the fund. Company and the paying agents. All other pay­ ments to the unitholders shall also be made through the above-mentioned offices.

15 An example calculation for determining the is calculated on the amount to be invested in the –– costs incurred in connection with the acquisi­ redemption price is as follows: new sub-fund. The balance resulting from an tion and sale of assets; exchange, if any, shall be converted into euro and –– extraordinary costs (e.g., litigation costs) Net fund assets EUR 1,000,000.00 paid out to the unitholders, if necessary, pro­ incurred to protect the interests of the ÷ Number of units vided this amount exceeds EUR 10.00 or 1% of unitholders of the sub-fund; the decision to in circulation the exchange amount. The exchange will be cover these costs is made individually by the on the reporting date 10,000.00 effected only on a valuation date. Management Company and must be Net asset value per unit EUR 100.00 reported separately in the annual report; – Redemption fee Market timing and short-term trading –– costs for providing information to the invest­ (e.g., 2.5%) EUR 2.50 The Management Company does not allow any ors of the sub-fund by means of a durable Redemption price EUR 97.50 practices related to market timing and short-term medium, with the exception of the cost of trading and reserves the right to refuse orders if information in the event of fund mergers and The Management Company may, at its sole it suspects that such practices are being used. In measures taken in connection with computa­ discretion, restrict or prohibit ownership of units such cases, the Management Company will take tion errors in the determination of the net of the fund by unauthorized persons (“Unauthor­ all measures necessary to protect the other asset value per unit, or in cases of invest­ ized Persons”). Unauthorized Persons are investors in the fund. ment limit violations. defined as private individuals, partnerships or corporations which, at the sole discretion of the Late trading Income resulting from the use of securities Management Company, are not authorized to Late trading is the acceptance of an order after lending and repurchase agreements should, in subscribe or hold units of the fund or, where expiry of the relevant acceptance periods on the principle, be transferred to the sub-fund’s applicable, of a specific sub-fund or unit class, respective valuation date and the execution of assets – less direct or indirect operational costs. (i) if, in the opinion of the Management Com­ such an order at the price applicable on that date The Management Company has the right to pany, such a unitholding could be detrimental to on the basis of the net asset value. The practice charge a fee for the initiation, preparation and the fund, (ii) if this would result in a breach of of late trading is not permitted because it vio­ execution of such transactions. The Management laws or regulations in force in Luxembourg or lates the provisions of the Sales Prospectus of Company shall, however, receive for the initia­ abroad, (iii) if the fund should subsequently suffer the fund, which stipulate that an order received tion, preparation and execution of securities tax, legal or financial disadvantages which it after the order acceptance period is to be exe­ lending transactions (including synthetic securi­ would not otherwise have suffered, or (iv) if the cuted at the price based on the next applicable ties lending transactions) and securities repur­ aforementioned persons or companies do not net asset value per unit. chase agreements for the account of the sub- meet the conditions for the acquisition of the fund a flat fee of up to one-third of the income units to be fulfilled by the investors. Publication of the issue and from these transactions. The Management redemption prices Company shall bear the costs incurred in connec­ The Management Company may request unithold­ The applicable issue and redemption prices as tion with the preparation and execution of such ers to submit any information or documents it well as all other information for unitholders may transactions, including any fees payable to third deems necessary to determine whether the be obtained at any time from the registered parties (e.g., transaction costs to be paid to the beneficial owner of the units is (i) an Unauthorized office of the Management Company and from Depositary as well as costs for the use of special Person, (ii) a U.S. person or (iii) a person holding the paying agents. In addition, the issue and information systems to secure best execution). units but not meeting the necessary conditions. redemption prices are published in appropriate media (such as the Internet, electronic informa­ Certain costs and fees may arise in connection If the Management Company becomes aware at tion systems, newspapers, etc.) in every country with total return swaps, especially with respect to any time that units are in the beneficial ownership of distribution. Neither the Management Com­ entering into these transactions and/or any of the persons referred to in (i), (ii) and (iii) above pany nor the paying agents shall be liable for increase or decrease in their nominal values. (regardless of whether they are exclusive owners errors or omissions in the price publications. These may be flat fees or variable fees. Further or co-owners), and if the person concerned does information on costs and fees that the sub-fund not comply with the Management Company’s must bear, as well as the identities of the recipi­ request to sell their units and to submit a proof Costs ents and all relationships (if any) existing between of sale to the Management Company within them and the Management Company, the fund 30 calendar days after the Management Company Costs and services received manager or the Depositary, are disclosed in the has issued the request, the Management Com­ The respective sub-fund pays to the Manage­ annual report. Income resulting from the use of pany may, at its own discretion, force the redemp­ ment Company an all-in fee on the net assets of total return swaps is generally transferred to the tion of such units at the redemption price. The the sub-fund based on the net asset value sub-fund’s assets – less direct or indirect opera­ compulsory redemption shall be effected in calculated on the valuation date. The amount of tional costs. accordance with the terms and conditions applica­ the all-in fee is specified in the special section of ble to the units, immediately after the close of the Sales Prospectus. The all-in fee is usually The costs mentioned are listed in the annual business indicated in the Management Company’s withdrawn from the sub-fund at the end of the reports. notification to the Unauthorized Person, and the month. This fee is used in particular to pay for investors shall no longer be deemed to be owners administration, fund management, distribution The Management Company may pass on parts of these units. (if applicable) and the Depositary. of its management fee to intermediaries. Such payments are in compensation for sales services Exchange of units In addition to the all-in fee, the following performed on an agency basis and may consti­ The unitholders may, against payment of an expenses may be charged to the sub-fund: tute a substantial share of the management fee. exchange commission reduced by 0.5 percent­ The annual report contains additional information age points from the initial sales charge (based on –– all taxes imposed on the assets of the sub- on this. The Management Company does not the sub-fund to be acquired) plus any applicable fund and on the sub-fund itself (in particular receive any reimbursement of the fees and issue taxes and duties, exchange part or all of the taxe d’abonnement), as well as any taxes expense reimbursements paid out of the sub- their units for units of a different sub-fund at any that may arise in connection with administra­ fund’s assets to the Depositary and to third time. The exchange commission, which is tive and depositary costs; parties. charged for the benefit of DWS Investment S.A.,

16 In addition to the costs mentioned above, addi- Total expense ratio execution capacities provided. The prerequisite tional costs may be incurred by the investor in The total expense ratio is defined as the ratio of for the selection of a broker is that the Manage- some countries in connection with the duties the expenditure incurred by the sub-fund to the ment Company shall always ensure that the and services of local distributors, paying agents average assets of the sub-fund, excluding trans- transactions are executed while taking into or similar entities. These costs are not borne by action costs incurred. The effective total expense account the appropriate market at the appropri- the sub-fund’s assets, but directly by the ratio is calculated annually and published in the ate time for transactions of the appropriate type investor. annual report. The total expense ratio is pub- and size at the best possible conditions. lished in the key investor information document Investment in units of target funds as so-called “ongoing charges.” The Management Company may enter into Investments in target funds can lead to double-­ agreements with selected brokers, traders and charging, as fees are charged both at the level of If the investor is advised on the acquisition of other analysis providers in the context of which the fund and at the level of a target fund. In units by third parties (particularly companies market information and analysis services connection with the acquisition of target fund providing investment services such as credit (research) are acquired from the respective units, the following types of fees are borne institutions and investment firms), or if such third provider. The services are used by the Manage- directly or indirectly by the investors in the fund: parties act as intermediaries for the purchase, ment Company for the purpose of managing the they may report expenses or expense ratios to sub-fund. When availing of these services, the –– the management fee / all-in fee of the target the investor that are not consistent with the Management Company shall comply with all fund; expense information in this Sales Prospectus or applicable regulatory provisions and industry –– the performance-based fee of the target in the key investor information document, and standards. In particular, the Management Com- fund; the charges reported may exceed the total pany shall not accept any services if these –– the initial sales charges and redemption fees expense ratio described here. agreements do not support the Management of the target fund; Company in its investment decision process –– reimbursements of expenses by the target This may be due in particular to regulatory according to reasonably prudent discretion. fund; requirements for the determination, calculation –– other costs. and disclosure of costs by the aforementioned Regular savings plan or third parties, which must be complied with in the withdrawal plans The annual and semiannual reports will contain a course of the national transposition of Directive Regular savings plans or withdrawal plans are disclosure of the initial sales charges and 2014/65/EU of the European Parliament and of offered in certain countries where the fund is redemption fees that have been charged to the the Council on markets in financial instruments licensed for public distribution. Further informa- fund during the reporting period for the acquisi- and amending Directive 2002/92/EC and Direc- tion on this can be obtained at any time on tion and redemption of units of target funds. In tive 2011/61/EU (known as “MiFID 2”). Devia- request from the Management Company or the addition, the annual and semiannual reports shall tions from the expense statement may arise on respective distributors in the countries of distri- disclose the fees charged to the fund by another the one hand from the fact that these third bution of the respective fund. company as a management fee / all-in fee for the parties additionally take into account the costs of target fund units held in the fund. their own services (e.g., a premium or also Compensation policy ongoing commissions for the brokerage or The Management Company is included in the If the assets of the fund are invested in units of a consulting activities, fees for custody account compensation strategy of the DWS Group. All target fund managed directly or indirectly by the management, etc.). In addition, these third matters related to compensation, as well as same Management Company or another com- parties are subject to sometimes differing compliance with regulatory requirements, are pany with which the Management Company is requirements for the calculation of costs incurred monitored by the relevant governing bodies of jointly managed or controlled or connected at fund level, so that, for example, the transac- the DWS Group. The DWS Group pursues a total through a significant direct or indirect invest- tion costs of the sub-funds are included in the compensation approach that comprises fixed and ment, the Management Company or the other third party’s expense statement, although they variable compensation components and contains company shall not charge the fund any initial are not part of the above-mentioned total portions of deferred compensation, which are sales charges or redemption fees for the pur- expense ratio in accordance with the provisions linked both to individual future performance and chase or redemption of units of this other fund. currently applicable to the Management the sustainable development of the DWS Group. Company. Under the compensation strategy, particularly The share of the management or all-in fee attrib- employees of the first and second management utable to the units of affiliated investment funds Deviations in the expense statement may arise level receive a portion of the variable compensa- (double-charging or difference method) can be not only with regard to the cost information prior tion in the form of deferred compensation ele- found in the special section of the Sales to the conclusion of the contract, but also in the ments, which are largely linked to the long-term Prospectus. event of any regular cost information by a third performance of the DWS share price or of the party regarding the existing fund investment as investment products. Repayment to certain investors of part of a permanent business relationship with management fees collected its client. In addition, the compensation policy applies the The Management Company may, at its discre- following guidelines: tion, agree with individual investors the partial Buy and sell orders for securities repayment to these investors of the manage- and financial instruments a) The compensation policy is consistent with ment fees collected. This can be a consideration The Management Company submits buy and sell and conducive to sound and effective risk especially in the case of institutional investors orders for securities and financial instruments management and does not encourage the who directly invest large amounts for the long directly to brokers and traders for the account of assumption of excessive risk. term. The Institutional Sales division of DWS the sub-funds. It concludes agreements with b) The compensation policy is consistent with Investment S.A. is responsible for these matters. these brokers and traders under customary the business strategy, objectives, values and market conditions that comply with first-rate interests of the DWS Group (including the execution standards. When selecting the broker Management Company, the UCITS it man- or trader, the Management Company takes into ages and the investors of these UCITS) and account all relevant factors, such as the credit- includes measures to avoid conflicts of worthiness of the broker or trader and the interest.

17 c) Performance is generally evaluated on a The income of the fund may be subject to with- Foreign Account Tax Compliance Act – multi-year basis. holding tax in countries in which the fund’s “FATCA” d) The fixed and variable components of the assets are invested. In such cases, neither the The provisions of the Foreign Account Tax Com- total compensation are proportionate to each Depositary nor the Management Company is pliance Act (generally known as “FATCA”) are other, with the share of the fixed component obliged to obtain tax certificates. part of the Hiring Incentives to Restore Employ- in the total compensation being high enough ment Act (the “HIRE Act”), which came into to provide complete flexibility with regard to The tax treatment of fund income for investors force in the United States in March 2010. These the variable compensation components, depends on the tax regulations applicable to the provisions of U.S. law serve to combat tax including the possibility of waiving payment investor in each individual case. A tax advisor evasion by U.S. citizens. Accordingly, financial of a variable component. should be consulted for information on the institutions outside of the United States (“foreign individual tax burden on investors (in particular financial institutions” or “FFIs”) are obliged to Further details on the current compensation non-resident taxpayers). make annual disclosures to the U.S. Internal policy are published on the Internet at Revenue Service (“IRS”), on financial accounts https://www.dws.com/footer/Legal-Resources/. held directly or indirectly by “specified” This includes a description of the calculation Selling restrictions U.S. ­persons. In general, for FFIs that do not methods for compensation and bonuses to meet this reporting obligation, known as specific employee groups, as well as the specifi- The units of this fund that have been issued may Non-Participating Foreign Financial Institutions cation of the persons responsible for the alloca- be offered for sale or sold to the public only in (NPFFI), a penalty tax of 30% is applied to tion, including members of the Compensation countries where such an offer or such a sale is certain income from U.S. sources. Committee. The Management Company shall permissible. Unless the Management Company, provide this information free of charge in paper or a third party authorized by it, has obtained and In principle, non-U.S. funds such as this fund form upon request. Moreover, the Management can show permission to do so from the local have FFI status and must conclude an FFI agree- Company provides additional information on regulatory authorities, this Prospectus does not ment with the IRS if they are not classified as employee compensation in the annual report. constitute a solicitation to purchase investment “FATCA-compliant” or, provided an applicable fund units, nor may the Prospectus be used for Model 1 intergovernmental agreement (“IGA”) is the purpose of soliciting the purchase of invest- in effect, do not meet the requirements of the Liquidation of the fund / ment fund units. IGA applicable to their home country either as a Amendment of the Management “reporting financial institution” or as a “non­- Regulations The information contained herein and the units reporting financial institution.” IGAs are agree- of the fund are not intended for distribution in ments between the United States of America The Management Company may liquidate the the United States of America or to U.S. persons and other countries regarding the implementa- fund and individual sub-funds or amend the (individuals who are U.S. citizens or whose tion of FATCA requirements. Luxembourg signed Management Regulations at any time. Details permanent place of residence is in the United a Model 1 agreement with the United States and are set out in the Management Regulations. States of America and partnerships or corpora- a related Memorandum of Understanding on tions established in accordance with the laws of March 28, 2014. This IGA was transposed into the United States of America or of any state, national law in Luxembourg by the law of Taxes territory or possession of the United States). July 24, 2015 (the “FATCA Law”). Accordingly, units will not be offered or sold in In accordance with articles 174–176 of the Law of the United States or to or for the account of The Management Company heeds all require- 2010, the assets of the fund are subject to a tax in U.S. persons. Subsequent transfers of units in or ments resulting from FATCA and, in particular, the Grand Duchy of Luxembourg (the “taxe into the United States or to U.S. persons are those resulting from the Luxembourg IGA as d’abonnement”) of 0.05% p.a. or 0.01% p.a. at prohibited. well as from the national implementation act. It present, payable quarterly on the fund’s net assets may, among other things, become necessary in reported at the end of each quarter. This Prospectus may not be distributed in the this context for the Management Company to United States of America. The distribution of this require new investors to submit the necessary The rate is 0.01% p.a. with regard to: Prospectus and the offering of the units may also documents to prove their tax residency in order be restricted in other jurisdictions. to make it possible to determine on that basis a) sub-funds whose sole purpose is to invest in whether they must be classified as specified money market instruments and time deposits Investors that are considered “restricted per- U.S. persons. with credit institutions; sons” as defined in Rule 2790 of the National b) sub-funds whose sole purpose is to invest in Association of Securities Dealers in the United Investors and intermediaries acting on behalf of time deposits with credit institutions; States (NASD Rule 2790) must report their investors should take note that, according to the c) individual (sub-)funds and individual unit holdings in the fund assets to the Management applicable principles of this fund, units cannot be classes, provided that the investment in Company without delay. offered or sold for the account of U.S. persons these (sub-)funds or unit classes is reserved and that subsequent transfers of units to U.S. for one or more institutional investors. This Prospectus may be used for sales purposes persons are prohibited. If units are held by a U.S. only by persons who have express written authori- person as the beneficial owner, the Management In accordance with article 175 of the Law of zation from the Management Company (granted Company may, at its discretion, enforce a com- 2010, the assets of a sub-fund or unit class may directly or indirectly via authorized distributors) to pulsory redemption of the units in question. also be fully exempted from the taxe d’abonne- do so. Declarations or representations by third ment under certain conditions. parties that are not contained in this Sales Pro- Common Reporting Standard (CRS) spectus or in the documentation have not been In order to facilitate a comprehensive and multilat- The applicable tax rate for the respective sub- authorized by the Management Company. eral automatic exchange of information at global fund is specified in the special section of the level, the OECD was mandated by the G8/G20 Sales Prospectus. These documents are available to the public at countries to develop a global reporting standard. the registered office of the Management This reporting standard has been included in the Company. amended Directive on administrative cooperation (“DAC 2”) of December 9, 2014. EU member

18 states were required to transpose DAC 2 into –– If a request for information is sent to the national law by December 31, 2015; it was natural person concerned for the purposes of enacted in Luxembourg by a law dated the CRS Law, he or she is obliged to respond. ­December 18, 2015 (the “CRS Law”). Failure to respond within the prescribed time limit may result in the account being reported Under the Common Reporting Standard, certain (erroneously or twice) to the Luxembourg tax financial institutions under Luxembourg law are authorities. obliged to carry out an identification of their account holders and to determine where the Every natural person concerned has the right to account holders are tax residents (under this access and have corrected, if necessary, the data same law, investment funds such as this one are submitted to the Luxembourg tax administration generally regarded as financial institutions under for the purposes of the CRS Law. Luxembourg law). For this purpose, a financial institution under Luxembourg law deemed to be Language versions a Reporting Financial Institution must obtain The German version of the Sales Prospectus is self-disclosure in order to determine the status authoritative. The Management Company may, within the meaning of the CRS and/or the tax with regard to fund units sold to investors in residence of its account holders when opening such countries, declare translations into the an account. languages of those countries where the units may be offered for sale to the public to be bind- Luxembourg’s Reporting Financial Institutions ing on itself and on the fund. are, since 2017, obliged to provide the Luxem- bourg tax administration (Administration des contributions directes) with information on holders of financial accounts on an annual basis, for fiscal year 2016 for the first time. This notifica- tion is made annually by June 30 and, in certain cases, also includes the controlling persons resident for tax purposes in a state subject to the reporting requirement (to be established by a Grand-Ducal Regulation). The Luxembourg tax authorities automatically exchange this informa- tion with the competent foreign tax authorities annually.

Data protection In accordance with the CRS Law and Luxem- bourg’s data protection regulations, each natural person concerned (i.e., potentially subject to reporting) must, before their personal data are processed, be informed by the Luxembourg Reporting Financial Institution of the processing of the data.

If the fund is to be classified as a Reporting Financial Institution, it shall notify those natural persons who are subject to reporting as defined in the above explanations of such classification in accordance with Luxembourg data protection regulations.

The Reporting Financial Institution is responsible for the processing of personal data and is the body responsible for processing for the purposes of the CRS Law.

–– The personal data are intended for process- ing in accordance with the CRS Law. –– The data can be reported to the Luxembourg tax authorities (Administration des contribu- tions directes), which may forward them to the competent authority/authorities of one or more reporting countries.

19 Investor profiles

The definitions of the following investor profiles expectations are offset by risks in the equity, returns, can tolerate the substantial fluctuations were created based on the premise of normally interest rate and currency areas, as well as by in the values of investments, and the very high functioning markets. Further risks may arise in credit risks and the possibility of incurring risks this entails. Strong price fluctuations and each case in the event of unforeseeable market losses up to and including the total loss of high credit risks result in temporary or permanent situations and market disturbances due to capital invested. The investor is also willing and reductions of the net asset value per unit/share. non-functioning markets. able to bear a financial loss and is not con- Expectations of high returns and tolerance of risk cerned with capital protection. by the investor are offset by the possibility of “Risk-averse” investor profile incurring significant losses up to and including The sub-fund is intended for the safety-oriented “Growth-oriented” investor profile the total loss of capital invested. The investor is investor with little risk appetite, seeking steady The sub-fund is intended for the growth-­oriented willing and able to bear such a financial loss and performance but at a low level of return. Short- investor seeking capital appreciation primarily is not concerned with capital protection. term and long-term fluctuations of the unit/ from equity gains and exchange rate movements. share value are possible as well as significant Return expectations are offset by high risks in the The Management Company provides additional losses up to the total loss of capital invested. equity, interest rate and currency areas, as well information to distribution agents and distribu- The investor is willing and able to bear such a as by credit risks and the possibility of incurring tion partners concerning the profile of a typical financial loss and is not concerned with capital significant losses up to and including the total investor or the target client group for this finan- protection. loss of capital invested. The investor is willing and cial product. If the investor is advised on the able to bear such a financial loss and is not acquisition of units/shares by distribution agents “Income-oriented” investor profile concerned with capital protection. or distribution partners, or if such agents or The sub-fund is intended for the income-­ partners act as intermediaries for the purchase oriented investor seeking higher returns through “Risk-tolerant” investor profile of units/shares, they may therefore present dividend distributions and interest income from The sub-fund is intended for the risk-tolerant additional information to the investor that also bonds and money market instruments. Return investor who, in seeking investments with strong relates to the profile of a typical investor.

Performance

Past performance is not a guarantee of future the possibility that they will not get back the www.dws.com, in the KIID and factsheets, or in results for the respective sub-fund. The returns original amount invested. the semi-annual and annual reports. and the principal value of an investment may Data on current performance can be found rise or fall, so investors must take into account on the Management Company’s website

20 B. Sales Prospectus – Special Section

DWS Euro Ultra Short Fixed Income Fund

Investor profile Risk-averse Fund currency EUR Fund manager DWS Investment GmbH Performance benchmark – Reference portfolio (risk benchmark) – (absolute VaR) Leverage Maximum of twice the sub-fund’s assets Valuation date Each bank business day in Luxembourg and Frankfurt/Main. A bank business day designates a day on which the banks are open for regular business in Luxembourg and Frankfurt/Main and settle payments. Order acceptance All orders are submitted on the basis of an unknown net asset value per unit. Orders received by the Management Company or the paying agent at or before 1:30 PM Luxembourg time on a valuation date are processed on the basis of the net asset value per unit on that valuation date. Orders received after 1:30 PM Luxembourg time are ­processed on the basis of the net asset value per unit on the next valuation date. Value date In a purchase, the equivalent value is charged two bank business days after issue of the units. The equivalent value is credited two bank business days after redemption of the units. Maturity date No fixed maturity Issue of fractional units Up to three decimal places Guarantee Yes, for the exact scope of the guarantee, cf. the “Guarantee” section below this table. Publication of the filing April 1, 2021 of the Management Regulations in the Trade and Companies Register (RESA) Entry into force of the January 31, 2021 Management Regulations

Unit Unit class Initial issue price Minimum Initial sales charge Redemption fee All-in fee p.a.* Taxe d’abonnement Inception class currency investment (payable by (payable by (payable by (payable by date the unitholder) the unitholder) the fund) the fund) NC EUR DEM 101.00 (incl. None 0% 0% Up to 0.1% p.a. 0.05% May 12, 1997 initial sales charge) IC EUR 10,000 10,000,000.00 0% 0% Up to 0.1% p.a. 0.01% August 13, 2019

* The sub-fund may also be charged with the expenses mentioned in the general section of the Sales Prospectus.

Investment objective and paper, certificates of deposit and time deposits, although the investment focus is on managing investment policy as defined in article 41 (1) a-d and h of the Law credit risks. The sub-fund can therefore be The objective of the investment policy of the of 2010, therefore do not have to be admitted for invested in assets with shorter or longer residual sub-fund DWS Euro Ultra Short Fixed Income trading on a stock exchange or included in a terms to maturity, depending on the market Fund is to generate the greatest possible appre- regulated market. situation. At least 25% of the sub-fund’s assets ciation of capital in the short term while taking are invested in assets that have a residual term into account the opportunities and risks of the Up to a maximum of 30% of the sub-fund’s to maturity that exceeds 24 months. international capital markets. assets (after deduction of liquid assets) may be invested in securities of domestic and foreign Up to 5% of the sub-fund’s assets may be The sub-fund is actively managed and is not issuers that do not satisfy the requirements of invested in asset-backed securities (ABS). The managed with reference to a benchmark. the preceding paragraph. asset-backed securities are based on receivables from leasing, credit card or car financing trans­ At least 70% of the sub-fund’s assets are The investment policy is implemented in parti­ actions, SME (Small & Medium Enterprise) invested in bonds, convertible bonds, fixed rate cular by managing credit risks of various issuers financing or mortgage loans. These must have or floating rate bonds that are traded on stock of government, bank and corporate bonds. The an investment-grade rating. An investment exchanges or in another regulated market that is resulting risk premiums are dependent on eco- instrument is categorized as investment-grade if recognized, open to the public, and operates nomic fluctuations and on the situation specific the lowest rating assigned by the three rating regularly and that is located in a member country to the respective issuer and provide correspond- agencies (S&P, Moody’s and Fitch) is investment-­ of the Organisation for Economic Co-operation ing opportunities to increase returns. The port­ grade. If the investment is downgraded to a and Development (OECD), the G20, the EU or folio management continuously examines these rating lower than Baa3 (by Moody’s) or BBB- (by Singapore, all of which are denominated in or risk premiums and compiles the portfolio based S&P and FITCH), it must be sold within six hedged against the euro, as well as in invest- on the market situation and on their assessment months. If there is no official rating, an internal ment funds and money market instruments. of opportunity vs. risk. Interest rate risks are also rating in line with the DWS internal guidelines Money market instruments such as commercial taken into account in the investment policy, shall be applied.

21 Up to 5% of the sub-fund’s assets may be value of the sub-fund) is expected to reach up to Guarantee invested in securities that do not have an invest- 10%. However, depending on market conditions, Following expiration of the guarantee on ment-grade rating at the time of acquisition. the objectives of efficient portfolio management ­December 30, 2008, DWS Investment S.A. However, this rating must be at least B3/B-. The and investors’ interests, this share may rise to as defined a new guarantee for the following refer- baseline is the lowest rating assigned by the much as 20%. The calculation is carried out in ence date: Unlike the half-year frequency three rating agencies (S&P, Moody’s and Fitch). accordance with the CESR/10-788 guidelines. (June 30/December 30) that applied up to then, However, the expected leverage indicated is not the new guarantee was not renewed on the If another asset held in the portfolio is down- to be considered as an additional risk limit for the reference date of June 30, but on the reference graded to a rating lower than B3/B- by at least sub-fund. date of December 30, 2009, instead. The value of one rating agency, it shall be sold within six the new net asset value guarantee based on the months. The baseline is the lowest rating Additional information on total return swaps can reference date was determined on ­December 30, assigned by the three rating agencies (S&P, be found under “Techniques for efficient portfolio 2008, and subsequently published. Moody’s and Fitch). management” and elsewhere in the general section of the Sales Prospectus. The selection of Since the guarantee reference date of The sub-fund may not invest in contingent counterparties for total return swaps is based on ­December 30, 2009, the intention is to define convertibles. the principles described in the “Counterparty a new guarantee on an annual basis. selection” section of the general section. Further In compliance with the investment limits speci- information on counterparties is disclosed in the The respective annual net asset values per unit, fied in the general section of the Sales Prospec- annual report. With regard to specific risk con­ which serve as a basis for defining the guaran- tus, the investment policy shall also be imple- siderations arising from the use of total return teed value, shall be determined on December 30 mented through the use of suitable derivative swaps, investors are referred to the “General risk of each year on which commercial banks are financial instruments. These include, among warnings” section and, in particular, to the open in Luxembourg and Frankfurt/Main. If the others, options, forwards, futures contracts “Risks associated with derivative transactions” reference date is not a date on which banks in futures, futures on financial instruments and section in the Sales Prospectus. Luxembourg and Frankfurt/Main are open, the options on such contracts, as well as privately closest-possible previous date on which com- negotiated OTC contracts on any type of financial Consideration of sustainability risks mercial banks are open in Luxembourg and instrument, including total return swaps and The sub-fund management considers sustainabil- Frankfurt/Main will be used. credit default swaps. ity risks by way of smart integration when mak- ing investment decisions. Additional information If changes in taxes during the guarantee period Credit derivatives may only be acquired for on the way in which sustainability risks are have a detrimental effect on the sub-fund’s hedging purposes. considered in investment decisions is provided in performance, the guarantee will be reduced by the general section of the Sales Prospectus. the amount of this difference per unit, including Securities lending transactions may be entered lost market-based and time-based into in line with the investment policy. Specific risk warning reinvestments. The sub-fund invests in various asset-backed In addition, the sub-fund’s assets may be securities (ABS). These securities may be Investors should be aware that the guaranteed invested in all other permissible assets. exposed to strong market fluctuations. In addi- value refers exclusively to the defined guarantee tion, these securities are extremely illiquid in date. Depending on the concept, the net asset During the reasonable duration of a restructuring times of market uncertainty and may be unsale- value per unit may therefore remain below the of the fixed rate instruments held by the sub- able under certain circumstances. It is therefore respective defined guarantee value up to the fund, the fund manager may also invest up to possible that there may be a total loss or a defined guarantee date. 10% of the sub-fund’s assets in listed or unlisted significant reduction in value of these securities. equities. Furthermore, the fund manager may Despite the diversification within the sub-fund, There is no obligation on DWS Investment S.A. also participate in capital increases or other the possibility that several securities in which the to define another guarantee once a guarantee capital changes (e.g., for convertible or warrant-­ sub-fund invests will be adversely affected at the has expired. linked bonds) that take place as part of a restruc- same time cannot be ruled out. Strong price turing or subsequent to a restructuring. fluctuations for the sub-fund, as well as high If DWS Investment S.A. defines a new guaran- losses in value therefore cannot be ruled out. tee, this does not have to match the amount of The respective risks associated with the invest- the net asset value per unit determined on a ment assets are presented in the general section With respect to the potential illiquidity and the reference date. The exact amount of the guaran- of the Sales Prospectus. still restricted capacity of the ABS market, the teed value and the respective applicable guaran- Management Company specifically points out tee date may be requested from the Manage- This sub-fund does not comply with the provi- that there is a possibility that the calculation of ment Company and the paying agents; they are sions of EU Regulation 2017/1131 on money the NAV may be suspended and also that the also published in the annual and semiannual market funds and is therefore not to be classified redemption of units may be suspended. The reports. Changes to the guarantee (e.g., a as a money market fund. calculation of the issue and redemption price, as change to the adjustment frequency or a deci- well as the issue and redemption of units, may sion to refrain from defining a new guarantee in Additional information be suspended by the Management Company if the future) shall additionally be communicated by If total return swaps are used to implement the and for as long as the immediate sale of sub- the Management Company in appropriate media investment strategy described above, the follow- fund assets to gain the necessary liquidity for and the Sales Prospectus shall be adjusted ing must be taken into account: large-scale redemptions is not in the interests of accordingly. the investors. In such cases, the Management The proportion of the sub-fund’s net assets that Company is only authorized to redeem units at Risk management may be the subject of total return swaps the applicable redemption price if corresponding For the sub-fund’s assets, the absolute value-at- (expressed as the sum of the nominal values of positions of the sub-fund’s assets were sold and risk (VaR) approach is used as the method for the total return swaps divided by the net asset the interests of all investors are safeguarded. market risk limitation.

22 The leverage effect is not expected to exceed twice the value of the sub-fund’s assets. How- ever, the expected leverage indicated is not to be considered as an additional risk limit for the sub-fund.

Investment in units of target funds In addition to the information provided in the general section of the Sales Prospectus, the following applies for this sub-fund:

For investment in affiliated target funds, the portion of the all-in fee attributable to units of affiliated target funds is reduced by the all-in fee / management fee charged by the acquired target fund, if necessary up to the full amount (differ- ence method).

Stock exchanges and markets The Management Company may have the units of the sub-funds admitted for listing on a stock exchange or traded in organized markets; cur- rently the Management Company is not availing itself of this option. The Management Company is aware that – without its consent – as of the date of preparation of this Sales Prospectus, the units of the following sub-funds are being traded or are listed on the following exchanges and markets:

–– Stuttgart Stock Exchange (Börse Stuttgart) –– Munich Stock Exchange (Börse München) –– Düsseldorf Stock Exchange (Börse Düsseldorf) –– Hamburg Stock Exchange (Börse Hamburg) –– Berlin Stock Exchange (Börse Berlin) –– Frankfurt Stock Exchange (Börse Frankfurt)

The possibility that such trading might be discontinued at short notice, or that the units of the sub-funds may be trading or introduced for trading in other markets – including at short notice, where applicable – cannot be excluded. The Management Company has no knowledge of this.

The market price underlying stock exchange trading or trading in other markets is not deter- mined exclusively by the value of the assets held in the sub-fund. Supply and demand are also contributing factors. The market price may therefore deviate from the calculated net asset value per unit. Such organized market also meets the criteria of article 50 of the UCITS Directive.

23 C. Management Regulations

The contractual rights and obligations of the 2. The Management Company manages the c) The sub-fund can invest in securities and Management Company, the Depositary and the fund in its own name, but only in the interest and money market instruments that are admitted unitholders with regard to the fund shall be for the joint account of the unitholders. The for trading on a stock exchange in a country determined in accordance with the following management authority extends in particular to that is not a member state of the European Management Regulations. the purchase, sale, subscription, exchange and Union or traded in another regulated market acceptance of securities and other assets as well in that state that operates regularly and is Article 1 The fund as to the exercise of all rights directly or indi­ recognized and open to the public. 1. DWS Portfolio (the “fund”) is a legally rectly connected with the fund assets. ­dependent investment fund (“fonds commun de d) The sub-fund can invest in newly issued placement”) consisting of securities and other 3. The Management Company may appoint a securities and money market instruments, assets (“fund assets”) that is managed for the fund manager under its own responsibility and provided that joint account of the holders of units (“unithold­ control and at its own expense. ers”) in compliance with the principle of risk –– the terms of issue include the obligation diversification. The unitholders are owners of the 4. The Management Company may appoint to apply for admission for trading on a fund’s assets in proportion to the number of investment advisors and an advisory investment stock exchange or in another regulated units they hold. The assets constituting the committee under its own responsibility and at its market that operates regularly and is fund’s assets are generally held in safe custody own expense. recognized and open to the public, and by the Depositary. –– such admission is procured no later than Article 3 The Depositary one year after the issue. 2. The mutual contractual rights and obligations 1. The Depositary is State Street Bank Interna­ of the unitholders, the Management Company tional GmbH, a limited liability company estab­ e) Each sub-fund can invest in units of undertak­ and the Depositary are governed by these Man­ lished under German law with its registered ings for collective investment in transferable agement Regulations, the current version of office in Munich, acting through State Street securities (UCITS) as defined in the UCITS which, together with any amendments thereto, Bank International GmbH, Luxembourg branch. Directive and/or of other undertakings for is filed with the Trade and Companies Register in State Street Bank International GmbH, Luxem­ collective investment (UCIs) as defined by Luxembourg, and the notice of deposit is pub­ bourg branch, is authorized by the CSSF to act as article 1(2), first and second indents, in the lished in the Recueil Electronique des Sociétés a depositary in Luxembourg. The Depositary was UCITS Directive, with a registered office in a et Associations (RESA) of the Trade and Compa­ appointed by the Management Company. member state of the European Union or in a nies Register. By purchasing a unit, the unit­ non-member state, provided that holder accepts the Management Regulations and 2. The rights and obligations of the Depositary all approved changes to them. are governed by the Law of 2010, these Manage­ –– such other collective investment under­ ment Regulations and the depositary agreement. takings were authorized under laws that 3. The fund is a so-called umbrella fund within provide that they are subject to supervi­ the meaning of article 181 of the Law of 2010. 3. Both the Depositary and the Management sion considered by the CSSF to be equiv­ The investor may be offered one or more sub- Company may terminate the appointment of the alent to that laid down in Community law, funds at the discretion of the Management Depositary at any time by giving three months’ and that cooperation between authorities Company. The aggregate of the sub-funds pro­ written notice. Such termination will be effective is sufficiently ensured; duces the umbrella fund. Each unitholder partici­ when the Management Company, with the –– the level of protection for unitholders of pates in the fund via the sub-fund. authorization of the responsible supervisory the other collective investment undertak­ authority, appoints another bank as Depositary ings is equivalent to that provided for 4. With respect to the legal relationship and that bank assumes the responsibilities and unitholders of an undertaking for collec­ between unitholders, each sub-fund is treated functions as Depositary; until then the previous tive investment in transferable securities, as a separate entity. In relation to third parties, Depositary shall continue to fulfill its responsibili­ and in particular that the rules on asset the assets of a sub-fund are only liable for the ties and functions as Depositary to the fullest segregation, borrowing, lending, and liabilities and payment obligations relating to that extent in order to protect the interests of the short sales of securities and money sub-fund. The investment restrictions set out in unitholders. market instruments are equivalent to the the Management Regulations apply to each requirements of the UCITS Directive; sub-fund separately, but the investment limits Article 4 General investment policy –– the business activity of the other collec­ set out in the article 4 B. k), sentence 2, shall guidelines tive investment undertakings is reported apply to the fund as a whole. Additional sub- The investment objectives and investment policy in annual and semiannual reports to funds may be established and/or one or more of each sub-fund are described in the special enable an assessment to be made of the existing sub-funds may be liquidated or merged section of the Sales Prospectus. The following assets and liabilities, income and opera­ at any time. In this case, the sales documenta­ general investment principles and restrictions tions over the reporting period; tion will be amended accordingly. apply to the fund insofar as no deviations or –– no more than 10% of the assets of the additions to the fund are contained in the special undertaking for collective investment in Article 2 Management Company section of the Sales Prospectus. transferable securities or of the other 1. The Management Company of the fund is collective investment undertaking whose DWS Investment S.A., a public limited company A. Investments acquisition is being contemplated can, under Luxembourg law, with its registered office according to its terms of contract or its in Luxembourg. It was founded on April 15, 1987. a) The sub-fund can invest in securities and articles of incorporation, be invested in The Management Company is represented by its money market instruments that are listed on units of other undertakings for collective Management Board. The Management Board or traded in a regulated market. investment in transferable securities or may entrust one or more of its members and/or other collective investment undertakings. employees of the Management Company with b) The sub-fund can invest in securities and day-to-day management. money market instruments that are traded in f) The sub-fund can invest in deposits with another market in a member state of the credit institutions that are repayable on European Union that operates regularly and is demand or have the right to be withdrawn, recognized, regulated and open to the public. and mature within twelve months or less,

24 provided that the credit institution has its that investments in such instruments are d) The total value of the securities and money registered office in a member state of the subject to investor protection equivalent market instruments of issuers in which the European Union or, if the credit institution to that laid down in the first, the second sub-fund respectively invests more than 5% has its registered office in a country that is or the third preceding indent, and pro- of its net assets may not exceed 40% of the not a member state of the European Union, vided that the issuer is a company whose sub-fund’s net assets. provided that it is subject to prudential rules capital and reserves amount to at least considered by the CSSF to be equivalent to EUR 10 million and which presents and This limitation does not apply to deposits those laid down in Community law. publishes its annual accounts in accor- or OTC derivative transactions made with dance with the Fourth Council Directive financial institutions subject to prudential g) Each sub-fund can invest in derivative finan- 78/660/EEC, or is an entity that, within a supervision. cial instruments (“derivatives”), including group of companies that includes one or equivalent cash-settled instruments, that are several listed companies, is dedicated to Notwithstanding the individual upper limits traded in one of the markets referred to in (a), the financing of the group or is an entity specified in B. (a), (b) and (c) above, the (b) and (c), and/or in derivative financial that is dedicated to the financing of sub-fund may not invest more than 20% instruments that are not traded on a stock securitization vehicles that benefit from of its net assets at any one institution in a exchange (“OTC derivatives”), provided that credit lines to assure liquidity. combination of

–– the underlying instruments are instru- i) Notwithstanding the principle of –– securities or money market instruments ments covered by this paragraph, or are risk-spreading, the respective sub-fund issued by this institution; and/or financial indices, interest rates, foreign may invest up to 100% of its assets in –– deposits made with this institution; exchange rates or currencies that fall securities and money market instruments and/or within the scope of the investment stemming from different issues that are –– OTC derivatives acquired from this policy; issued or guaranteed by a member state institution. –– the counterparties to OTC derivative of the European Union or its local authori- transactions are institutions subject to ties, by an member country of the Organi- e) The limit of 10% specified in B. (a) rises to prudential supervision, and belonging to sation for Economic Co-operation and 35%, and the limit set in B. (d) does not the categories approved by the CSSF; and Development (OECD), a G20 country or apply, if the securities or money market –– the OTC derivatives are subject to reliable Singapore, or by public international instruments are issued or guaranteed by and verifiable valuation on a daily basis institutions of which one or more member and can be sold, liquidated or closed by states of the European Union are mem- –– a member state of the European Union an offsetting transaction at any time at bers, provided that the fund holds securi- or its local authorities; or their fair value at the fund’s initiative. ties that originated from at least six differ- –– a country that is not a member state ent issues and the securities stemming of the European Union; or h) The sub-fund can invest in money market from any one issue do not exceed 30% of –– public international bodies of which one instruments not traded in a regulated market the assets of the sub-fund. or more member states of the European that are usually traded in the money market, Union are members. are liquid and have a value that can be accu- j) The sub-fund may not invest in precious rately determined at any time, provided that metals or precious-metal certificates; should f) The limit specified in B. (a) rises from 10% the issue or issuer of such instruments is itself the investment policy of a sub-fund make to 25%, and the limit set in B. (d) does not subject to regulations for the protection of specific reference to this provision, this apply, in the case of bonds that fulfill the savings and investors, and provided that these restriction shall not apply to 1:1 certificates following conditions: instruments are whose underlying is one single commodity or precious metal and that meet the require- –– they are issued by a credit institution –– issued or guaranteed by a central, ments for securities according to article 2 of that has its registered office in a member regional or local authority or the central Directive 2007/16/EC and article 1(34) of the state of the European Union and which is bank of a member state of the European Law of 2010. legally subject to special public supervi- Union, the European Central Bank, the sion intended to protect the holders of European Union or the European Invest- B. Investment limits such bonds, and ment Bank, a country that is not a mem- –– sums deriving from the issue of such ber state of the European Union or, in the a) No more than 10% of the sub-fund’s net bonds are invested in accordance with case of a federal state, by one of the assets may be invested in securities or the law in assets that, during the whole members making up the federation, or by money market instruments of any one issuer. period of validity of the bonds, are capa- a public international body of which one ble of covering claims attaching to the or more member states of the European b) No more than 20% of the sub-fund’s net bonds, and Union are members; or assets may be invested in deposits made –– such assets, in the event of default of the –– issued by a company whose securities with any one institution. issuer, would be used on a priority basis are traded in the regulated markets for the repayment of the principal and specified in (a), (b) or (c) above; or c) The default risk exposure to a counterparty in payment of the accrued interest. –– issued or guaranteed by an institution that OTC derivative transactions entered into in is subject to supervision according to the the context of efficient portfolio management If the respective sub-fund invests more than 5% criteria stipulated in Community law, or by may not exceed 10% of the fund’s net assets of its assets in bonds of this type issued by any an institution that is subject to and com- if the counterparty is a credit institution as one issuer, the total value of these investments plies with prudential rules considered by defined in A. (f) above. In other cases, the may not exceed 80% of the value of the sub- the CSSF to be at least as stringent as limit is a maximum of 5% of the fund’s net fund’s net assets. those laid down in Community law; or assets. –– issued by other issuers belonging to a category approved by the CSSF, provided

25 g) The limits specified in B. (a), (b), (c), (d), (e) Law of 2010 or the UCITS Directive, shares m) Notwithstanding the limits specified in B. (k) and (f) may not be combined, and thus that carry voting rights enabling it to exercise and (l), the maximum limits specified in B. (a), investments in securities or money market significant influence over the management of (b), (c), (d), (e) and (f) for investments in equi- instruments issued by any one institution or the issuer. ties and/or debt securities of any one issuer in deposits made with this institution or in are 20% when the objective of the investment this institution’s derivatives shall under no The sub-fund may acquire a maximum of policy is to replicate a certain index or a lever- circumstances exceed 35% of the fund’s aged index on the following basis: net assets. –– 10% of the non-voting shares of any one issuer; –– the composition of the index is suffi- The respective sub-fund can cumulatively –– 10% of the debt securities of any one ciently diversified; invest up to 20% of its assets in securities issuer; –– the index represents an adequate bench- and money market instruments of any one –– 25% of the units of any one fund or any mark for the market to which it refers; group of companies. one sub-fund of an umbrella fund; –– the index is published in an appropriate –– 10% of the money market instruments of manner. Companies that are included in the same any one issuer. group for the purposes of consolidated The limit specified here is 35% where that accounting as defined in EU Directive The investment limits specified in the sec- proves to be justified by exceptional market 83/349/EEC or in accordance with recog- ond, third and fourth indents may be disre- conditions in particular in regulated markets nized international accounting rules, shall be garded at the time of acquisition if at that where certain securities or money market regarded as a single issuer for the purpose time the gross amount of the debt securities instruments are highly dominant. An invest- of calculating the investment limits specified or of the money market instruments, or the ment up to that limit shall be permitted for in this article. net amount of the securities in issue, cannot only one single issuer. be calculated. h) The respective sub-fund may invest no more n) The fund’s overall exposure relating to deriva- than 10% of its net assets in securities and l) The investment limits specified in (k) shall not tives must not exceed the total net value of money market instruments other than those be applied to: its portfolio. The exposure is calculated taking specified in paragraph A. into account the current value of the under­ –– securities and money market instruments lying assets, the counterparty risk, future i) Unless otherwise provided for a particular issued or guaranteed by a member state market movements and the time available to sub-fund in the special section of the Sales of the European Union or its local liquidate the positions. Prospectus, the sub-fund may invest no more authorities; than 10% of its net sub-fund assets in units of –– securities and money market instruments The sub-fund can, as part of its investment other undertakings for collective investment in issued or guaranteed by a country that is strategy and within the limits of B. (g), invest transferable securities and/or collective invest- not a member state of the European in derivatives, provided that the overall risk of ment undertakings as defined in A. (e). Union; the underlyings does not exceed the invest- –– securities and money market instruments ment limits of B. (a), (b), (c), (d), (e) and (f). However, by way of derogation and in accor- issued by public international organiza- dance with the provisions and requirements tions of which one or more member If the sub-fund invests in index-based deriva- of Chapter 9 of the Law of 2010, a sub-fund states of the European Union are tives, these investments are not taken into may, as a feeder, invest at least 85% of its members; consideration as regards the investment assets in units of another UCITS (or its –– shares held by the fund in the capital of a limits specified in B. (a), (b), (c), (d), (e) and (f). sub-funds) recognized in accordance with the company incorporated in a country that is UCITS Directive and which is itself neither a not a member state of the European When a security or money market instrument feeder nor holds units of another feeder. If Union that invests its assets mainly in the embeds a derivative, the latter must be taken the sub-fund acts as a feeder fund, this will securities of issuers having their regis- into consideration when complying with the be reflected in the Sales Prospectus and in tered offices in that country, where under requirements of the investment limits. the key investor information. the legislation of that country such a holding represents the only way in which o) The sub-fund can additionally invest up to For investments in units of another undertak- the fund can invest in the securities of 49% of its assets in liquid assets. In particu- ing for collective investment in transferable issuers of that country. This derogation, lar exceptional cases, it is permitted to securities and/or other collective investment however, shall apply only if in its invest- temporarily have more than 49% invested in undertaking, the asset values of the under- ment policy the company from the coun- liquid assets, if and to the extent that this taking for collective investment in transfer- try that is not a member state of the appears to be justified with regard to the able securities and/or other collective invest- European Union complies with the limits interests of unitholders. ment undertaking in question are not taken specified in B. (a), (b), (c), (d), (e), (f) and into account in relation to the upper limits (g), (l) and (k). Where these limits are C. Exceptions to investment limits specified in B. (a), (b), (c), (d), (e) and (f). exceeded, article 49 of the Law of 2010 shall apply; a) The sub-fund need not comply with the j) If admission to one of the markets specified in –– shares held by one or more investment investment limits when exercising subscrip- A. (a), (b) or (c) is not obtained within the companies in the capital of subsidiary tion rights attaching to securities or money one-year deadline, new issues shall be consid- companies that only conduct certain market instruments that form part of its ered unlisted securities and money market management, advisory or marketing assets. instruments and counted toward the invest- activities with regard to the repurchase of ment limit stated there. units at the request of unitholders in the b) While ensuring compliance with the principle country where the subsidiaries are of risk-spreading, the sub-fund can depart from k) The Management Company may not acquire, located, and do so exclusively on behalf the specified investment limits for a period of for any investment funds managed by it of that investment company or those six months following the date of its which fall within the scope of Part I of the investment companies. authorization.

26 D. Cross-investment between sub-funds Article 5 Unit classes of the valuation, and which the Management The investor may be offered one or more unit Company considers to be a market price. A sub-fund (the “Investing Sub-Fund”) may classes at the discretion of the Management invest in one or several other sub-funds. Any Company. c) In the event that such prices are not in line acquisition by the Investing Sub-Fund of units of with market conditions, or for securities and another sub-fund (the “Target Sub-Fund”) is 1. All unit classes of the sub-fund shall be money market instruments other than those subject to the following conditions (and to all the invested together in accordance with the invest- covered in (a) and (b) above for which there are other required conditions that have been speci- ment objectives of the respective sub-fund, but no fixed prices, these securities and money fied in this Sales Prospectus): they may differ from each other, in particular with market instruments, as well as all other regard to their fee structure, the minimum assets, will be measured at the current market a) the Target Sub-Fund may not invest in the investment requirements for initial and subse- value as determined in good faith by the Investing Sub-Fund; quent subscriptions, the currency, the distribu- Management Company, following generally tion policy, the conditions to be met by investors accepted valuation principles verifiable by b) the Target Sub-Fund may invest no more than or other specific characteristics. auditors. 10% of its net assets in UCITS (including other sub-funds) or other UCIs; 2. The Management Company reserves the d) Liquid assets are valued at their nominal right to offer only one unit class or only certain value plus interest. c) the voting rights associated with the units of unit classes for sale to investors in certain juris- the Target Sub-Fund are suspended for as dictions so as to comply with the applicable e) Time deposits may be valued at their yield long as the units involved are held by the laws, customs or business practices there. value if a contract exists between the Man- Investing Sub-Fund; Furthermore, the Management Company agement Company and the Depositary stipu- reserves the right to adopt principles that apply lating that these time deposits can be with- d) the value of the units of the Target Sub-Fund to certain investor categories or transactions in drawn at any time and that their yield value is held by the Investing Sub-Fund is not consid- respect of the acquisition of certain unit classes. equal to the realized value. ered in the verification of the statutory minimum capital requirement of EUR 3. The existing unit classes are enumerated f) All assets denominated in a currency other 1,250,000.00. individually in the special section of the Sales than that of the sub-fund are translated into Prospectus, as well as in the annual and semian- the currency of the sub-fund at the last E. Loans nual reports. The configuration characteristics of mid-market exchange rate. the unit classes (e.g., type of investor, distribu- Loans may not be taken out by neither the tion policy, initial sales charge, currency of the g) The prices of the derivatives employed by the Management Company nor the Depositary for units, all-in fee, minimum investment or a combi- sub-fund will be set in the usual manner, the account of the respective sub-fund. However, nation of these features) are described in detail which shall be verifiable by the auditor and the fund may acquire foreign currencies by in the general part of the Sales Prospectus and in subject to systematic examination. The means of a “back-to-back” loan. the annual and semiannual reports. criteria that have been specified for pricing the derivatives shall remain in effect for the Notwithstanding the foregoing paragraph, the Article 6 Calculation of the net asset term of each individual derivative. fund may borrow up to 10% of the respective value per unit sub-fund’s assets, provided that such borrowing 1. The currency of the fund is the euro. The h) Credit default swaps are valued according to is on a temporary basis. value of a unit shall be expressed in the currency standard market practice at the present value specified for the fund (“sub-fund currency”), of future cash flows, whereby the cash flows For the account of the fund, neither the Manage- unless a currency other than the sub-fund cur- are adjusted to take into account the risk of ment Company nor the Depositary may grant rency is indicated in the Sales Prospectus for any default. Interest rate swaps are valued at loans or act as a guarantor on behalf of third of the unit classes (“unit class currency”). It is their market value, which is determined parties. calculated for the respective sub-fund on each based on the yield curve for each swap. bank business day in Luxembourg and Frankfurt/ Other swaps are valued at an appropriate This shall not prevent the acquisition of securi- Main (“valuation date”), unless otherwise speci- market value, determined in good faith in ties, money market instruments or other financial fied in the Sales Prospectus. accordance with recognized valuation meth- instruments that are not yet fully paid in. ods that have been specified by the Manage- The calculation is made by dividing the net ment Company and approved by the fund’s F. Short sales sub-fund assets by the number of units of fund auditor. in circulation on the valuation date. If unit classes Neither management companies nor depositar- are offered in the sub-fund, the net asset value i) The target fund units contained in the sub- ies that operate on behalf of investment funds per unit will be calculated individually for each fund are valued at the most recent available may engage in short sales of securities, money unit class issued of the sub-fund. The net assets redemption price that has been determined. market instruments or other financial instru- of the sub-fund are calculated according to the ments referred to in A. (e), (g) and (h). following principles: 2. An income adjustment account is maintained for the sub-fund. G. Encumbrance a) Securities and money market instruments listed on a stock exchange are valued at the The respective sub-fund’s assets may only be most recent available price paid. Article 7 Suspension of the pledged as collateral, transferred, assigned or calculation of the net asset otherwise encumbered to the extent that such b) Securities and money market instruments value per unit transactions are required by a stock exchange or not listed on a stock exchange but traded on The Management Company has the right to regulated market or imposed by contractual or another organized securities market are suspend the calculation of the net asset value other terms and conditions. valued at a price no lower than the bid price per unit, if and while circumstances exist that and no higher than the ask price at the time make this suspension necessary and if the suspension is justified when taking into

27 consideration the interests of the unitholders, in 5. Unitholders are entitled at any time to Article 12 Costs and services particular: request the redemption of their units. The received redemption price is the unit value less a redemp- The respective sub-fund pays to the Manage- –– while a stock exchange or other regulated tion fee of up to 2.5% in favor of the Manage- ment Company an all-in fee of up to 0.25% p.a. market on which a substantial portion of the ment Company. The amount of the redemption on the net assets of the fund based on the net securities or money market instruments of fee for each sub-fund is specified in the respec- asset value calculated on the valuation date. The the fund are traded is closed (excluding tive special section of the Sales Prospectus. The amount of the all-in fee is specified in the normal weekends and holidays) or when exact amount is specified in the special section special section of the Sales Prospectus. The trading on that stock exchange or the corre- of the Sales Prospectus. The redemption price all-in fee is usually withdrawn from the sub-fund sponding regulated market has been sus- may also be decreased by fees or other charges at the end of the month. This fee is used in pended or restricted; incurred in the respective countries of particular to pay for administration, fund –– in an emergency, if the Management Com- distribution. management, distribution (if applicable) and the pany is unable to access its fund investments Depositary. or cannot freely transfer the transaction value Article 9 Restrictions on the of its purchases or sales or calculate the net issue of units In addition to the all-in fee, the following asset value per unit in an orderly manner. 1. The Management Company may at any time expenses may be charged to the sub-fund: and at its discretion reject a subscription appli- Investors who have applied for redemption of cation or temporarily limit, suspend or perma- –– all taxes imposed on the assets of the fund units will be informed promptly of the suspen- nently discontinue the issue of units, or may and on the fund itself (in particular the taxe sion and will then be notified immediately once redeem units at the redemption price, if such d’abonnement), as well as any taxes that the calculation of the net asset value per unit is action should appear necessary in consideration may arise in connection with administrative resumed. Investors will be paid the redemption of the interests of the unitholders or the public, and depositary costs; price valid at that time after the resumption. or to protect the fund or the unitholders. –– costs incurred in connection with the acquisi- tion and sale of assets; Any suspension of the calculation of the net In this case, the Management Company or the –– extraordinary costs (e.g., litigation costs) asset value per unit will be published on the paying agent will promptly refund payments on incurred to protect the interests of the Management Company’s website and in subscription applications that have not yet been unitholders of the fund; the decision to cover accordance with the regulations of the country executed. these costs is made individually by the Man- of distribution. agement Company and must be reported 2. The suspension of the issue of units will be separately in the annual report; Article 8 Issue and redemption published on the Management Company’s –– costs for providing information to the invest­ of fund units website and in accordance with the regulations ors of the sub-fund by means of a durable 1. All fund units have the same rights. If the of the country of distribution. medium, with the exception of the cost of Management Company decides to issue unit information in the event of fund mergers and classes, all units within a unit class shall have the measures taken in connection with computa- same rights. The fund units are securitized in Article 10 Restrictions on the tion errors in the determination of the net global certificates. Investors are not entitled to redemption of units asset value per unit, or in cases of invest- receive delivery of definitive securities. 1. The Management Company is entitled to ment limit violations. suspend the redemption of units if exceptional 2. The issue and redemption of units are per- circumstances so require and the suspension is Income resulting from the use of securities formed by the Management Company and all justified in the interest of the unitholders. lending and repurchase agreements should, in paying agents. principle, be transferred to the sub-fund’s assets – 2. The Management Company has the right to less direct or indirect operational costs. The 3. The Management Company may redeem carry out substantial redemptions only once the Management Company has the right to charge a units unilaterally against payment of the redemp- corresponding assets of the sub-fund have been fee for the initiation, preparation and execution of tion price, insofar as this appears necessary in sold as detailed in the general section of the such transactions. The Management Company the interests of all unitholders or to protect the Sales Prospectus. shall, however, receive for the initiation, prepara- Management Company or the fund. tion and execution of securities lending transac- 3. The Management Company or the paying tions (including synthetic securities lending trans- 4. Units are issued on each valuation date at the agent is obligated to transfer the redemption price actions) and securities repurchase agreements for issue price. The issue price is the unit value plus, to the country of the applicant only if this is not the account of the sub-fund a flat fee from the where applicable, an initial sales charge of up to prohibited by law – for example by foreign income from these transactions, the amount of 1% in favor of the Management Company. The exchange regulations – or by other circumstances which is generally set out in the general section of amount of the initial sales charge for each sub- beyond the control of the Management Company the Sales Prospectus. The Management Company fund is specified in the respective special section or the paying agent. shall bear the costs incurred in connection with of the Sales Prospectus. The exact amount is the preparation and execution of such transac- specified in the special section of the Sales 4. The suspension of the redemption of units tions, including any fees payable to third parties Prospectus. The Management Company may will be published on the Management Compa- (e.g., transaction costs to be paid to the Deposi- pass on the initial sales charge to intermediaries ny’s website and in accordance with the regula- tary as well as costs for the use of special infor- as remuneration for sales services. The issue tions of the country of distribution. mation systems to secure best execution). price may be increased by fees or other charges incurred in the respective countries of distribu- Article 11 Fiscal year and audit Investment in units of target funds tion. Fractional units can be issued. If fractional The fiscal year commences on January 1 and Investments in target funds can lead to double-­ units are issued, the Sales Prospectus will ends on December 31 of each year. charging, as fees are charged both at the level of specify the exact number of places after the the fund and at the level of a target fund. In decimal point to which the fractions are rounded. The fund’s annual financial statements shall be connection with the acquisition of target fund Fractional units entitle the holder to participate in audited by an auditor appointed by the Manage- units, the following types of fees are borne any distributions on a pro-rata basis. ment Company. directly or indirectly by the investors in the fund:

28 –– the management fee / all-in fee of the bonus units. Any remaining fractions of units shall be announced by the Management Com- target fund; may be paid out in cash or credited. Distributions pany in the Trade and Companies Register –– the performance-based fee of the not claimed within the deadlines stipulated in (RESA) and in at least two daily newspapers of target fund; article 18 shall lapse in favor of the fund. sufficiently broad circulation, including at least –– the initial sales charges and redemption fees one Luxembourg newspaper. of the target fund; 2. The Management Company may elect to pay –– reimbursements of expenses by the out interim distributions for the fund in accor- The liquidation of a sub-fund shall be published in target fund; dance with the law. the manner provided for in the Sales Prospectus. –– other costs. Article 14 Amendment of the 5. Upon liquidation of the fund or sub-fund, the The annual and semiannual reports will contain Management Regulations issue of units is discontinued. Unless otherwise a disclosure of the initial sales charges and 1. The Management Company may, with the determined by the Management Company, the redemption fees that have been charged to the consent of the Depositary, amend the Manage- redemption of units is also discontinued at this fund during the reporting period for the acquisi- ment Regulations in whole or in part at any time. time. If the Management Company decides to tion and redemption of units of target funds. In continue to allow redemptions, it will be ensured addition, the annual and semiannual reports shall 2. Amendments to the Management Regula- that all unitholders are treated equally. disclose the fees charged to the fund by another tions shall be filed in the Trade and Companies company as a management fee / all-in fee for the Register and shall enter into force immediately 6. On the instructions of the Management target fund units held in the fund. after filing, unless otherwise specified. A notice Company or, where appropriate, the liquidators of filing will be published in the Trade and Com- appointed by the Management Company or by If the assets of the fund are invested in units of a panies Register (RESA). the Depositary in agreement with the Supervi- target fund managed directly or indirectly by the sory Authority, the Depositary will distribute the same Management Company or another company Article 15 Publications proceeds of liquidation, less any liquidation costs with which the Management Company is jointly 1. Issue and redemption prices may be requested and fees, among the unitholders of the respec- managed or controlled or connected through a from the Management Company and all paying tive sub-fund in accordance with their rights. The significant direct or indirect investment, the agents. In addition, the issue and redemption net proceeds of liquidation not collected by Management Company or the other company prices are published in appropriate media (such unitholders upon completion of the liquidation shall not charge the fund any initial sales charges as the Internet, electronic information systems, proceedings will at that time be deposited by the or redemption fees for the purchase or redemp- newspapers, etc.) in every country of Depositary with the Caisse de Consignation in tion of units of this other fund. distribution. Luxembourg for the account of unitholders entitled to them, where such amounts will be The share of the management or all-in fee attrib- 2. The Management Company produces an forfeited if not claimed there by the statutory utable to the units of affiliated investment funds audited annual report and a semiannual report for deadline. (double-charging or difference method) can be the fund according to the laws of the Grand Duchy found in the special section of the Sales of Luxembourg. 7. The unitholders, their heirs or successors may Prospectus. not apply for the liquidation or division of the fund 3. The Sales Prospectus, the key investor or a sub-fund. Certain costs and fees may arise in connection information documents, the Management Regu- with total return swaps, especially with respect lations, and the annual and semiannual reports Article 17 Merger of the fund and to entering into these transactions and/or any are available free of charge to unitholders at the sub-funds increase or decrease in their nominal values. registered office of the Management Company 1. According to the definitions in the Law of These may be flat fees or variable fees. Further and at all paying agents. 2010, the fund or each of its sub-funds may, by information on costs and fees that the fund must resolution of the Management Company, be bear, as well as the identities of the recipients Article 16 Liquidation of the fund merged with another sub-fund of the fund, with and all relationships (if any) existing between or of a sub-fund another Luxembourg or non-Luxembourg UCITS them and the Management Company, the fund 1. The fund has no fixed maturity. Sub-funds or with a sub-fund of a Luxembourg or non-­ manager or the Depositary, are disclosed in the may also be established for a limited period of Luxembourg UCITS either as the transferring or annual report. Income resulting from the use of time. Information on the maturity of the respec- as the receiving sub-fund. total return swaps is generally transferred to the tive sub-fund can be found in the special section fund’s assets – less direct or indirect operational of the Sales Prospectus. 2. Unless otherwise provided for in individual costs. cases, the execution of the merger shall be 2. Notwithstanding the provision in section 1, carried out as if the transferring sub-fund were Article 13 Distribution policy the fund or an individual sub-fund may be liqui- dissolved without being liquidated and all assets 1. The Management Company shall decide dated by the Management Company at any time, were simultaneously taken over by the receiving whether to make a distribution or reinvestment. unless otherwise provided for in the special (sub-)fund in accordance with statutory provi- In the case of a distribution, the Management section of the Sales Prospectus. The Manage- sions. Investors in the transferring sub-fund Company shall also decide each year whether a ment Company may decide to liquidate the fund receive units of the receiving (sub-)fund, the distribution will be made and in what amount. or an individual sub-fund if this appears neces- number of which is based on the ratio of the net Both regular net income and realized capital sary or appropriate, taking into account the asset values per unit of the (sub-)funds involved gains may be distributed. In addition, unrealized interests of the unitholders, to protect the inter- at the time of the merger, with a provision for capital gains, as well as retained capital gains ests of the Management Company or in the settlement of fractions if necessary. from previous years and other assets, may also interest of investment policy. be distributed, provided the net assets of the 3. Unitholders of the sub-fund will be notified fund do not fall below the minimum amount 3. The liquidation of the fund is mandatory in of the merger on the Management Company’s specified in article 23 of the Law of 2010. Distri- the cases provided for by law. website www.dws.com as well as in accordance butions are paid out based on the number of with the regulations of the country of distribution. units in issue on the distribution date. Distribu- 4. As required by law and the regulations of the Unitholders of the sub-fund may within a period of tions may be paid entirely or partly in the form of country of distribution, a liquidation of the fund at least 30 days request the redemption or

29 exchange of units free of charge as outlined in greater detail in the relevant publication.

4. For each merger of a transferring fund by dissolution, the decision on the effective date of the merger must be filed with the Trade and Companies Register and must be published via a corresponding notice of deposit in the RESA.

5. The Management Company may additionally decide to merge unit classes within the sub- fund. The result of such a merger is that the unitholders of the transferring unit class receive units of the receiving unit class, the number of which is based on the ratio of the net asset values per unit of the unit classes involved at the time of the merger, with a provision for settle- ment of fractions if necessary.

6. The execution of the merger will be moni- tored by the auditors of the fund.

Article 18 Limitation of claims and submission period 1. Claims of unitholders against the Manage- ment Company or the Depositary shall cease to be enforceable in court once a period of five years has elapsed since the claim arose; this shall not affect the provisions of article 16 (6).

2. The submission period for coupons is five years.

Article 19 Applicable law, jurisdiction and language of contract 1. The Management Regulations of the fund are subject to Luxembourg law. The same applies to the legal relationship between the unitholders and the Management Company. The Manage- ment Regulations are filed with the District Court in Luxembourg. Any legal disputes between unitholders, the Management Company and the Depositary are subject to the jurisdiction of the competent court in the judicial district of Luxem- bourg in the Grand Duchy of Luxembourg. The Management Company and the Depositary may elect to submit themselves and the fund to the jurisdiction and laws of any of the countries of distribution in respect of the claims of investors who reside in the relevant country, and with regard to matters concerning the fund.

2. The German wording of these Management Regulations shall prevail. The Management Company may, with regard to fund units sold to investors in such countries, declare translations into the languages of those countries where the units may be offered for sale to the public to be binding on itself and on the fund.

30 Management and Administration

Management Company, Central Management Board Information and Paying Agent Administration Agent, Transfer Agent, Registrar and Main Distributor Nathalie Bausch Luxembourg Chairwoman Deutsche Bank Luxembourg S.A. DWS Investment S.A. DWS Investment S.A., 2, Boulevard Konrad Adenauer 2, Boulevard Konrad Adenauer Luxembourg 1115 Luxembourg, Luxembourg 1115 Luxembourg, Luxembourg Leif Bjurstroem DWS Investment S.A., Supervisory Board Luxembourg

Claire Peel Dr. Stefan Junglen Chairwoman DWS Investment S.A., DWS Management GmbH, Luxembourg Frankfurt/Main Barbara Schots Manfred Bauer DWS Investment S.A., DWS Management GmbH, Luxembourg Frankfurt/Main

Stefan Kreuzkamp Fund Manager DWS Investment GmbH, Frankfurt/Main DWS Investment GmbH Mainzer Landstraße 11–17 Frank Krings 60329 Frankfurt/Main, Germany Deutsche Bank Luxembourg S.A., Luxembourg The address of an additional (sub-)fund manager is listed (for each sub-fund) in the special section Dr. Matthias Liermann of the Sales Prospectus. DWS Investment GmbH, Frankfurt/Main Depositary Holger Nauman DWS Investments Hong Kong Ltd., State Street Bank International GmbH Hong Kong Luxembourg Branch 49, Avenue John F. Kennedy 1855 Luxembourg, Luxembourg

Auditor

KPMG Luxembourg, Société Coopérative 39, Avenue John F. Kennedy 1855 Luxembourg, Luxembourg

As of: October 1, 2020 DWS Investment S.A. 2, Boulevard Konrad Adenauer 1115 Luxembourg, Luxembourg Tel.: +352 4 21 01-1 Fax: +352 4 21 01-900 www.dws.com