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Regulatory affairs

Voting rights policy

According to the current regulation, Kredietrust Luxembourg S.A.’s strategy for exercising  voting rights is defined in this document.

This strategy applies to all kind of funds and investment portfolios for which Kredietrust S.A. has been appointed investment manager.

Due to the small participation in the market capitalization of companies in which Kredietrust S.A. invests, “abstention” is the systematic rule. Therefore, Kredietrust S.A. does not exercise the voting rights attached to securities held in the above mentioned portfolios.

However, if Kredietrust S.A. should exercise its voting right, the asset manager will make his/her choice by preventing any conflict of interest and in the best interest of the shareholders, unitholders or investors. The Kredietrust S.A. conflicts of interests policy defines the organizational measures to prevent and manage such conflicts.

Any investor may address his/her request to Kredietrust S.A. in order to obtain details on the votes attached to financial instruments held in the fund or in the investment portfolio.

 

Policy for prevention and management of conflicts of interest

A conflict of interest shall be defined as a detrimental conflict between the interests of Kredietrust S.A., or its employees, and those of its clients or between the interests of several of its clients, between one of its clients and a fund or between two or also several funds managed by (*) Kredietrust S.A.

According to the current regulation, Kredietrust S.A. has established a policy of prevention and management of conflicts of interest. This policy identifies the circumstances which constitute or may rise to a conflict of interest, and defines the set up procedures as well as the measures to adopt in order to prevent and manage those conflicts.

Kredietrust S.A. has reviewed all of its activities with a view to detecting the situations likely to produce a conflict of interest. As the company is member of KBL epb , the policy has also taken into account any circumstances which may give rise to a conflict of interest resulting from the structure and business activities of other members of the Group, and if necessary, appropriate procedures have been set up.

Situations likely to produce a conflict of interest are recorded and kept at the registered office of the management company. Regular updating is in charge of the Compliance Officer of Kredietrust S.A.

Kredietrust S.A. has put in place some other preventive measures such as the submission to a Code of Conduct and to rules of integrity by all employees, the adoption of security measures, in particular for information technology issues, preventing the circulation of information within the Group, the implementation of procedures regarding personal transactions and the treatment of inside information.

If Kredietrust S.A. should note that its policy arrangements are insufficient to ensure that the risk of harming the interests of a fund or its unitholders, or any other client, can be avoided with reasonable certainty, Kredietrust S.A. shall work on resolving this conflict and shall inform the relevant party in writing of the general nature of the conflict of interest and/or its source and shall give reasons for its decision.

Any investor may contact Kredietrust S.A. in order to obtain more details on this policy.

 (*)  "managed by" refers to all funds for which Kredietrust S.A. has been designated management company or alternative investment fund manager.

Handling of complaints

A complaint is a written expression of dissatisfaction addressed to the Central Administration in the name of the UCITS or in the name the Management Company and to which the UCITS or the Management Company has to reply.

If there is no doubt that the communication is a complaint, the file shall immediately be sent to the Compliance Officer who will take charge of the ad hoc investigations.

Please note that asking for information is not considered as a complaint.

Procedure:

  • Investors can complain
    • by sending an e-mail to: Complaints@ktl.lu
    • by sending a letter to: KREDIETRUST LUXEMBOURG SA Service Réclamations 11, Rue Aldringen L – 2960 LUXEMBOURG
  • Investors can file a complaint in their own language.
  • All information regarding the handling of complaints is available free on request.