Privacy Policy


We at 7orca Asset Management AG are delighted to welcome you to our website. We have compiled the content on our website carefully and to the best of our knowledge, and we update it regularly. 
The content has been created by us or by third parties who we consider trustworthy. However, we cannot guarantee that the information from these third parties has been checked, and assume no liability for it. 

We also cannot guarantee that the information produced by us is up-to-date, accurate and complete, or that access to our website will be unimpeded at all times. 

Claims against 7orca Asset Management AG on the grounds of material or immaterial damage caused by using or not using the information provided or by using inaccurate or incomplete information are precluded, unless 7orca Asset Management AG is culpable of intent or gross negligence. All information is subject to change and is non-binding, and we reserve the right to amend or delete any of the information on our website at any time. 

Occasionally, we use links to third-party websites, which we are not responsible for. In such cases, we check these websites for any visibly illegal content, as far as it is technically possible and reasonable for us to do so. However, the check only goes back to the date of the link, and we have no influence over any subsequent changes to the content of the third-party websites. We expressly assume no liability for illegal, inaccurate or incomplete content and for damage resulting from the use of this content. 

Data protection

You can use our website anonymously, i.e. without providing us with details such as your name, address, email address or other information that could be used to find out about your personal circumstances and other matters. 

However, non-personal access data, such as the name of your Internet service provider, the website you are visiting us from, the names of the files requested and their retrieval date, is stored. This data is only used to improve our website and does not in any way enable us to identify you personally. 

Use of cookies

When doing so, we use so-called “cookies”. Cookies are small text files that that are sent to your browser from our web server during your visit to our website and then stored on your computer to be retrieved at a later date. We only use so-called session cookies (also called temporary cookies), i.e. those that are only stored temporarily, while you are using our website. In particular, the purpose of the cookies used is to determine the frequency of use of our website and the number of visitors to it, to enable us to identify your computer when you visit our website if you move from one of our web pages to another of our web pages, and to establish the end of your visit. This way, we know which part of our website and which other websites our visitors have visited. However, this usage data does not enable us to identify the user personally. After the session ends – as soon as you end your browser session – the cookies are deleted. 

However, you can deactivate the storage of cookies or adjust your browser settings so that it notifies you before cookies are stored. Users who do not accept cookies may not be able to access certain parts of our website. 

Google Analytics

This website uses Google Analytics, a web analysis service from Google Inc. (“Google”). Google Analytics also uses cookies. The information on your use of this website generated by the cookies is usually transmitted to a Google server in the USA and stored there. Google may also transmit this information to third parties if required by law to do so or if third parties process this data on Google’s behalf. 

However, if you activate IP anonymization on this website, Google will anonymize your IP address by shortening it first within EU member states or in other states that are party to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and anonymized there. Please note that this website uses Google Analytics with the extension code “gat._anonymizeIp();” to guarantee that IP addresses are recorded anonymously (so-called IP masking). 

Google uses this information on behalf of the owner of this website to analyse your use of the website, to compile reports on website activities and to provide other services associated with website use and Internet use for the website owner. Google will not link the IP address transmitted by your browser for Google Analytics up with any other data. 

You can prevent cookies being stored by adjusting your browser software settings; however, please note that in this case, you may not be able to use all of the functions of this website in full. You can also prevent the data generated by the cookie concerning your use of the website being recorded by Google by downloading and installing the browser plug-in available via the following link.

As an alternative to this browser plug-in or in browsers on mobile devices, you can prevent data being recorded by Google Analytics by clicking on the following link. An opt-out cookie that prevents your data being recorded when you visit our website in the future will then be stored. You can find further information here or here (general information on Google Analytics and data protection).

Deactivate data collection by Google Analytics for this website

Google Tag Manager

We use Google Tag Manager provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Google Tag Manager is used to manage website tags via an interface and allows us to control the precise integration of services on our website.

This allows us to flexibly integrate additional services to evaluate user access to our website.

The use of Google Tag Manager is based on our legitimate interests, i.e. interest in optimising our services in accordance with Art. 6 para. 1 lit. f. DSGVO.

The specific storage period of the processed data cannot be influenced by us, but is determined by Google Ireland Limited. Further information can be found in the privacy policy for Google Tag Manager:

Google Maps

This site uses the mapping service Google Maps via an API. The provider is Google Ireland Limited („Google“), Gordon House, Barrow Street, Dublin 4, Ireland.

To use the functions of Google Maps, it is necessary to store your IP address. This information is usually transferred to a Google server in the USA and stored there. The provider of this site has no influence on this data transmission.

Google Maps is used in the interest of an appealing presentation of our online offers and to make it easy to find the places we indicate on the website. This constitutes a legitimate interest within the meaning of Art. 6 Para. 1 lit. f DSGVO.

More information on the handling of user data can be found in Google’s privacy policy:

LinkedIn Insight Tag

This website uses the Insight tag from LinkedIn. This service is provided by LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland.

Data processing by LinkedIn Insight tag

We use the LinkedIn Insight tag to obtain information about visitors to our website. Once a website visitor is registered with LinkedIn, we can analyze the key occupational data (e.g., career level, company size, country, location, industry, job title) of our website visitors to help us better target our site to the relevant audience. We can also use LinkedIn Insight tags to measure whether visitors to our websites make a purchase or perform other actions (conversion measurement). Conversion measurement can also be carried out across devices (e.g. from PC to tablet). LinkedIn Insight Tag also features a retargeting function that allows us to display targeted advertising to visitors to our website outside of the website. According to LinkedIn, no identification of the advertising addressee takes place.

LinkedIn itself also collects log files (URL, referrer URL, IP address, device and browser characteristics and time of access). The IP addresses are shortened or (if they are used to reach LinkedIn members across devices) hashed (pseudonymized). The direct identifiers of LinkedIn members are deleted by LinkedIn after seven days. The remaining pseudonymized data will then be deleted within 180 days.

The data collected by LinkedIn cannot be assigned by us as a website operator to specific individuals. LinkedIn will store the personal data collected from website visitors on its servers in the USA and use it for its own promotional activities. For details, please see LinkedIn’s privacy policy at

Legal basis

The use of LinkedIn Insight is based on Art. 6(1)(f) GDPR. The website operator has a legitimate interest in effective advertising measures, including social media. If appropriate consent has been obtained, the processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25 (1) TTDSG, insofar the consent includes the storage of cookies or the access to information in the user’s end device (e.g., device fingerprinting) within the meaning of the TTDSG. This consent can be revoked at any time.

Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here: und

Objection to the use of LinkedIn Insight Tag

You can object to LinkedIn’s analysis of user behavior and targeted advertising at the following link:

In addition, LinkedIn members can control the use of their personal information for promotional purposes in the account settings. To prevent LinkedIn from linking information collected on our site to your LinkedIn account, you must log out of your LinkedIn account before you visit our site.

Personal data

However, if you wish to use the services offered on our website, such as ordering an Asset Management Factsheet or newsletter, etc., you need to enter further details. These are details that are required to process your request, such as your email address. 

We use the data about you that we have collected to provide the products and services we offer, to respond to your queries, and to run and improve our website and applications. Your personal data is not used in any other way. Your personal data will not be passed on to third parties or used for advertising purposes without your consent, except for in the cases described below, unless we are required by law to provide the data (as information to criminal prosecution authorities and courts; as information to public bodies that collect data in accordance with legal provisions, e.g. social security bodies, financial authorities) or we are using third parties that are obligated to maintain professional confidentiality to enforce our claims. 

We will only store your personal data for as long as required by law. Personal data will be deleted if the user revokes their consent to it being stored, if this information is no longer required to meet the purpose for which it was stored or if storing it becomes inadmissible for other legal reasons. You can revoke your consent to the use of your personal data in the future at any time by writing to “7orca Asset Management AG, Sandtorkai 77, 20457 Hamburg”. 

Integration of the Xing plug-in

We would like to inform you that your personal data is processed using the “XING button” function on this website. When this website is accessed, your browser is quickly connected to the XING AG (“XING”) servers that perform the “XING button” functions. XING does not store any personal data from you regarding access to this website. In particular, XING does not store any IP addresses, and your usage behaviour is not analysed using cookies in connection with the “XING Share Button”. You can find up-to-date data protection information on the “XING Share Button” and additional information here and here

Integration of LinkedIn plug-ins

Plug-ins for the social network LinkedIn from the LinkedIn Corporation (“LinkedIn”) are also integrated into our website. You can recognise the LinkedIn plug-ins by the LinkedIn logo on our website. When you visit our website, the plug-in establishes a direct connection between your browser and the LinkedIn server. This enables LinkedIn to be informed that you have visited our website with your IP address. If you click on the LinkedIn “Recommend button” while you are logged into your LinkedIn account, you can post a link to the content on our website on your LinkedIn profile. LinkedIn can then match your visit to our website to your user account. Please note that we, as the provider of the website, do not have any knowledge of the content of the data transmitted and use of it by LinkedIn. 

You can find the details of data collection (purpose, scope, further processing, use) as well as your rights and settings in LinkedIn’s privacy policy, which can be found here.

If parts or specific phrases contained in this legal notice do not correspond to current legislation, or cease to do so or do not do so entirely, the content and validity of the other parts of the legal notice will remain unaffected. 

Execution Principles 
(Version October 2017) 

The following principles for executing orders (hereinafter “Principles”) set how 7orca Asset Management AG guarantees the execution of an order consistently when acquiring and disposing of asset items, in the best interests of the investment fund or the investor. If there are no agreements to the contrary with the client, we will execute the purchase or sale order of financial instruments or other financial assets via an execution venue as per the following provisions. If a client issues instructions to 7orca Asset Management AG to execute their order or for partial aspects of order execution, they release 7orca Asset Management AG in this respect from their obligation to provide the best-possible execution and implementation of the guidelines included in the Principles of order execution. 


Our company has procedures and actions that ensure due care and probity, legal and professional action, compliance with market standards, and in particular, compliance with the interests of the respective investors. The Principles apply to the execution of trading transactions in financial instruments or other financial assets by our company or within the scope of individual asset management, which we provide for our clients.

Execution rules

Trading transactions can regularly be executed via different execution paths or at different execution venues, e.g. on stock exchanges or other trading venues, domestically or abroad or on the one hand, in floor trading or in electronic trading on the other hand. For this purpose, we use various intermediaries, which we select carefully and to whom we forward trading orders for execution or with whom we place trading transactions. The main intermediaries are detailed in the appendix to these principles. 

We regularly place orders for equities and exchange-traded derivatives via electronic trading systems at intermediaries on regulated markets, multi-lateral trading systems or internal systems. 

We settle non-exchange-traded derivatives on the basis of standardised framework agreements by representing the investor or also a prime broker directly with the respective counterparty. For this purpose, we also use electronic trading systems for multi-lateral trading systems, if possible.

Orders for bonds will also generally be issued via intermediaries for execution off-market. This usually concerns fixed-price transactions that are executed via electronic trading systems.

Investment fund units are acquired or delivered via the respective capital management company or the respective custodian. In exceptions, exchanges may also be used. Exchange Traded Funds (ETFs) are normally traded using a broker via an exchange.

In compliance with the targets, the investment policy and the specific risks of the respective investment fund, the special features of the order and the financial instruments and special features or the execution venues, our company takes the factors detailed in the products presented below into account when selecting concrete trading paths and partners. The weighting of the respective factor generally results from the sequence specified below, where factors in first place are given the highest weighting. 

  1. The following factors are authoritative for trading with equities, investment funds and Exchange Traded Funds (ETF) or securitised, standardised derivatives (warrants, certificates) and trading with bonds (bond issues, debt securities, money market instruments):

    Rate or price, costs of the transaction; features of the instrument, of the order and the market circumstances; execution quality, speed and probability; market access and providing liquidity; settlement quality/settlement
  2. The following factors are authoritative for trading with non-securitised standardised derivatives (options, futures and OTC derivatives) and securities loans: 

    Rate or price, costs of the transaction; features of the instrument, of the order and the market circumstances; execution quality, speed and probability; market access and providing liquidity; capability of the counterparty to support the products appropriately over the term and any settlement agreements that exist between the relevant parties.
  3. The following factors are authoritative for concluding foreign exchange transactions: 

    Rate or price, costs of the transaction; execution quality, speed and probability; settlement quality

This can lead to an order being executed via brokers that does not meet the cheapest execution fee. The importance of the factors detailed above can vary depending on the type of order, the financial instruments or the execution venue. If several brokers allow an equally good execution to be expected, we will make a selection from among these at our discretion before recommendation. For some trading transactions the selection of brokers or counterparties can be restricted by up to only one single provider; the transparency of liquidity and prices can also be restricted. Within the scope of portfolio administration as the representative of capital management companies for the account of some of these administrated investment funds, the selection of the available brokers is a regular constituent of the contractually agreed framework conditions of the respective mandate. Our selection in the individual case is restricted to these framework conditions. The regulations of the execution apply accordingly if orders are issued to execute via counterparties “over the counter“ (OTC). For OTC derivatives, alongside the price, the long-term capability of the counterparties to support these products appropriately is an important criterion. 

Consolidation of orders

We can combine purchase or sale orders for different clients and execute these as an aggregated order (block order) if order volumes, types of securities, the market segment, current market liquidity and the price sensitivity of the securities to be traded allow this to seem advisable in the best interests of the investment fund or investor affected. We must point out that a consolidation can be disadvantageous for an individual order. However, we will only consolidate orders if any disadvantage for individual investment funds or investors is not generally expected. An executed block order will be assigned to the individual investment fund pro rata. There may be exceptions for a partial execution of block orders, if when assigning the partial execution, compliance with minimum denominations is required. If a new emission is subscribed at several brokers, the different assignment quotas that may exist apply to the respective broker via whom a subscription was made. 

Reviewing the Principles

Our Principles are reviewed annually. In particular, we regularly review the quality of the execution of the purchase and sales orders provided by the trading partners specified in these Principles. In addition, we will carry out a review within an appropriate period if we have any indications that a material change has occurred that no longer guarantees order execution in the best-possible interests. We will inform our clients of material changes to the Principles. 

Appendix “Main Intermediaries”
(Version October 2017)


  • Bank of America Merrill Lynch
  • BNP Paribas
  • Deutsche Bank
  • Goldman Sachs
  • HSBC
  • J.P. Morgan Chase
  • Morgan Stanley
  • Société Générale

Principles for dealing with conflicts of interest
(Version October 2017) 

As a securities service company we are required to act exclusively in the interests of our investors and carry out our activities honestly, with the required care, conscientiousness and probity, and for this purpose act in the best interests of our clients and the integrity of the market. 

In view of our focused business model with a limited number of services, conflicts of interest when carrying out our activities are manageable, but cannot always be ruled out in individual cases.


The focal point of the services we provide is individual financial portfolio management and investment advice for institutional investors, primarily within the scope of insourcing portfolio management of capital management companies for investment funds. In addition, 7orca Asset Management AG can also broker investments and acquisitions. Private investors are usually only indirect recipients of our services, such as through acquiring shares in investment funds for whose portfolio management we are responsible.

We have specialised in rules-based portfolio management and focus on overlay management, currency and value guarantee management, and short-vola strategies. Within this framework, we use in particular exchange-traded derivatives (such as futures and options) and off-exchange-traded (“OTC”) derivatives, such as forward exchange transactions.

We commission the following important services from third parties: internal audit, external audit, legal advice, tax consulting, insurance services, data supply and IT services.


In addition to the founders, a pension fund and a financial services provider that also specialise in institutional investors hold minority shareholdings in the company. 7ORCA Asset Management does not hold any investments in other companies.

In accordance with the guidelines of the German Securities Trading Act, we will inform you below about our precautions when dealing with conflicts of interest.

Possible conflicts of interest

Interests of our clients or investors could collide with the following interests:

  • the interests of 7orca Asset Management or its affiliates;
  • the interests of our employees;
  • the interests of other clients or investors.

Conflicts of interest between our company, capital management companies and the custodians of our insourcing mandates are also conceivable. 

Conflicts of interest can result from, for example

  • when receiving or granting gratuities (such as when selecting brokers/counterparties or financial instruments)
  • from incentive systems for managers or employees of the company
  • personal transactions with assets that are held in investment funds whose portfolio we manage
  • reallocations in investment funds;
  • transactions between investment funds administered by our company and/or individual portfolios;
  • consolidating several orders (“block trades”);
  • commissioning closely affiliated companies and people,
  • individual investments of considerable extent;
  • frequent trading;
  • exploiting insider information

Measures to prevent, control and monitor these possible conflicts of interest

7orca Asset Management AG has taken organisational and administrative precautions to identify, prevent, settle, control and observe/monitor conflicts of interest in order to prevent conflicts of interest from causing considerable damage to the interests of investment funds or investors.

In particular, we have set up a compliance organisation that monitors our precautions against conflicts of interest regardless of the business field and regularly train all employees concerning legal requirements and internal company directives. 

If it is possible in a company of our size, we create confidentiality areas and information barriers between individual business areas and in relationship to the third parties we commission. Our risk controlling system is subject to special protective precautions against conflicts of interest.

If the organisational precautions taken by us to identify, prevent, settle and observe conflicts of interest to avoid an impairment of investor interests are not sufficient, we will inform investors in advance and develop countermeasures.

We have also taken the following measures in detail:

  • our remuneration system does not create any incentive to place personal interests above those of our investors and clients;
  • we have set up rules for personal transactions that are continuously monitored by the Compliance department and lead to a blocked list, which prohibits personal transactions with certain asset items (depending on the investment strategy we offer), in order to counter possible conflicts of interest;
  • we have ruled out the acceptance of third party payments (trailer fees, reimbursements, other payments). One exception is low-value, non-monetary gratuities, which we may accept under certain conditions and that are documented in a directory of gratuities;
  • we continuously monitor the transaction frequency in the investment funds we manage in order to prevent investors from experiencing disadvantageous reallocations in the individual portfolios or insourcing mandates;
  • we have published our Execution Principles;
  • we do not do any own-account business whatsoever – especially not with the investment funds or individual portfolios we manage – and only carry out securities transactions between different clients of ours at their wish;
  • the consolidation of several orders (“block trades”) is done on the basis of a standard assignment principle;
  • if we commission closely affiliated companies or people (in particular our shareholders), (e.g. with the role of an asset manager, investment advisor, broker or custodian), we will disclose this to investors;
  • we only use our own financial instruments or those from shareholder companies within the scope of investment advice or financial portfolio management at the explicit wish of the client;

If our company cannot avoid conflicts of interests, we will advise you of the type of conflict and its cause.

Disclosure report according to the Institutsvergütungsverordnung and in conjunction with Article 450 of the EU-Capital Requirements Regulation 575/2013
(Last updated 15/03/2018 )

7orca Asset Management AG is not a prominent institution within the meaning of the Institutsvergütungsverordnung (InstVergVO), meaning that the presentation and scope of information relating to our remuneration policy conform to article 450 of the EU CRR no. 575/2013 without having to fulfil the additional provisions of paragraph 16 I and II of the InstVergVO. Although the company does not qualify as a CRR investment firm and hence not as an institute within the meaning of EU CRR no. 575/2013, the analogous application of article 450 comes into effect in accordance with paragraph 1a II of the German Banking Act (Kreditwesengesetz – KWG). 

7orca Asset Management AG specialises in financial portfolio management for institutional clients and generally provides its services to capital management companies for the account of investment funds. In so doing, we predominantly pursue systematically and quantitatively oriented investment strategies. 

The company´s remuneration principles meet the requirements of the German Banking Act (KWG) and those of MaComp (Mindestanforderungen Compliance) – minimum requirements for compliance – which were communicated to each employee at the end of his/her employment contract. Presently, the company employs another nine workers in addition to the three members of the executive board. All members of the executive board as well as the persons involved in portfolio management are relevant persons according to the (MaComp). 

The executive board is responsible for the appropriate design and implementation of the remuneration system as well as the avoidance of remuneration-related risks, in as far as the remuneration of the the other employees is concerned. In contrast the supervisory board of the company is responsible for the remuneration principles of the executive board in a corresponding manner. 

The remuneration principles are reviewed at least once a year with the participation of the compliance officer, and they currently contain a fixed and a variable component.Bonus regulations for all employees starting from a low threshold value are subject to the approval by the supervisory board. 

The remuneration structure and implementation plan must be aligned with our business and risk policy, and hence be of benefit to the sustainable development of the company. Consequently, the payment of a variable remuneration is always subject to the company havingadequate capital and liquidity. 

A variable remuneration scheme did not take effect in 2017 due to the fact that the company was at an early stage of development. Even beyond 2017, the essential remuneration component for all employees is fixed and no significant dependencies on bonus payments arise. In general the variable remuneration depends on the overall success of the company as a whole and does not lead to disproportionate risks. This is also accommodated by the fact that the strategies we pursue are strongly rule-based and are not dependent on individual portfolio managers for their implementation. 

The fixed remuneration of employees is paid in twelve monthly payments per year and is calculated in such a manner that no incentives for disproportionately risky transactions are created. The variable remuneration is paid annually, where payment is applicable, and is capped in accordance with the provisions of the German Banking Act (KWG).

execution venues

The files that can be downloaded below contain information in German on the identity of the most important trading venues and on the quality of execution.

Meldung Ausführungsplätze 2017.pdf
Informationen zu Handelsplätzen.pdf
Ausführungsplätze 2018.pdf
Informationen zu Handelsplätzen 2018.pdf

complaint management

We aim to meet the requirements and standards of our customers and investors with our services and products at any time. If there is nevertheless cause for complaint, you can contact us free of charge electronically, in writing or verbally. You will find the contact information next to each of our employees on the page „team“. 

We have established effective and transparent complaint management procedures. This includes confirming receipt of a complaint without delay and providing you with information on how the complaint is handled. All complaints are immediately brought to the attention of the board.

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The content of our website is exclusively directed at professional investors in accordance with section 31a (2) WpHG. Therefore, we do not take the guidelines of section 4 WpDVerOV into account for the presentation of information for private clients. Thus, the contents detailed on our website are not suitable for private investors.

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