KTL Luxembourg Policies

VOTING RIGHTS POLICY

Kredietrust Luxembourg S.A. is not usually involved in the management of the companies issuing financial instruments. Therefore, Kredietrust Luxembourg S.A. does not exercise the voting rights attached to the securities held in the managed portfolios.

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Policy of prevention and management of conflicts of interest

Kredietrust Luxembourg S.A. conducts its business in compliance with the principles of integrity and transparency, aiming to prevent the occurrence of actual or potential conflicts of interests or, at least, to manage them fairly in accordance with a framework which is common to KBL epb group.

The purpose of the Policy of prevention and management of conflicts of interest is to provide you with the key information about the measures adopted by Kredietrust Luxembourg S.A. in order to prevent and manage those conflicts.

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COMPLAINTS MANAGEMENT POLICY

As part of its commitment to quality and customer service, Kredietrust Luxembourg S.A. encourages feedback on the services provided to its Customers.

Thus Kredietrust Luxembourg S.A. has implemented effective and transparent procedures for handling of complaints which are compliant with the applicable regulation.

The Complaints management policy provides information that Customers will need in order to introduce a complaint. Main aspects on the complaints handling procedure is also described.

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MiFID – Markets in Financial Instruments Directive & Execution of orders

The Markets in Financial Instruments Directive – MiFID - became effective on 1 November 2007. The purpose of MiFID is to harmonise European financial markets, provide greater levels of transparency and offer a higher level of protection to investors through a new regulatory regime for investment services.

Kredietrust Luxembourg S.A. is a management company within the KBL epb group, which has established and implemented an Order Execution Policy, as required by MiFID among others.

When providing portfolio management services, Kredietrust Luxembourg S.A. transmits orders for execution to KBL epb and monitors that KBL epb executes orders in the best interest of the Funds it manages and its investors.

The document "General information on MiFID" gives explanation on the main measures implemented by KBL epb in order to be compliant with MiFID. The full version of the Best Execution Policy is also described.

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