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enquiries@lfpartners.lu

Management Company Policies

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Our Policies

Luxembourg Fund Partners policies regarding conflict of interest, complaints handling, best execution and voting rights can be obtained free of charge on request. The following sections provide essential information regarding these policies.

Best Execution Policy

When executing transactions, while managing portfolios, on behalf of the funds under management, Luxembourg Fund Partners applies a policy to ensure that its actions are in the best interests of these funds and their shareholders.

Luxembourg Fund Partners has implemented processes in accordance with this best execution policy to obtain the best possible results for the funds under management. These processes take into account factors such as the characteristics of the order (eg price, costs, speed, order size and nature), the financial instruments subject to the order, the execution venues and the investment policy of the fund.

Luxembourg Fund Partners monitors and reviews this policy on a regular basis and ensures the effectiveness of its processes, in order to obtain the best possible results for the managed funds on an ongoing bases.

Voting Rights Policy

Luxembourg Fund Partners applies adequate and effective strategies for determining when and how voting rights attached to securities held in the portfolios under management are exercised.

Voting rights are exercised exclusively in the best interests of the fund and its shareholders and in accordance with the investment objectives of the fund.

Luxembourg Fund Partners monitors corporate events relating to the exercise of voting rights on a regular basis. Issues being voted at shareholder meetings are evaluated on a case by case basis.

Conflict of Interest Policy

Luxembourg Fund Partners is committed to investigate and monitor potential conflicts of interest that may arise within the company and within the investment funds under management.

A conflicting situation may arises for example when a person linked to the fund by way of control finds himself in a situation where while providing a service to the fund he has an incentive to favour the interests of others over the interests of the fund.

Such a situation which may give rise to a conflict of interest entail a material risk of damage.

Luxembourg Fund Partners has therefore set a process whereby potential circumstances of conflicts are identified, prevented and resolved.

A compliance officer actively manages the conflicts of interest.

Complaint Handling Policy

Luxembourg Fund Partners has implemented procedures for managing customer complaints relating to our services.

This procedure is simple, objective and transparent. In this process we investigate all relevant information in order to correct root causes and improve processes.

In order to file a complaint please contact us in writing:

2, Boulevard de la Foire, L-1528 Luxembourg

complaints@lfpantners.lu

Our staff has been trained to resolve and deal with complaints in real time. A written acknowledgement of receipt of a complaint will be provided within 5 business days and a detailed answer will be sent within a month (where an answer cannot be provided within this period, the cause of the delay and an estimated finalisation date shall be provided).

The name and contact details of the person in charge of the complaint file, as well as the name and contact details of a person assigned to the case at the management level will be provided. This will allow the complaint to be raised to the management level, in case the answer is not satisfactory.

In a case where Luxembourg Fund Partners would not provide a satisfactory answer, the complaint can be filed directly to the CSSF (the Luxembourg supervisor of the financial sector), for an out-of-court resolution. A form to facilitate a direct complaint to the CSSF can be found on the CSSF website. (www.cssf.lu)

Remuneration Policy

This policy aims to:

  • Ensure that remuneration is in line with the business strategy, objectives, values and interests of Luxembourg Fund Partners S.A. and the collective investment schemes manages or the investors of such collective investment schemes, CIS;
  • Not encourage risk‐taking which is inconsistent with the risk profiles, rules or articles of incorporation or management regulations of the CIS Luxembourg Fund Partners S.A. manages;
  • Ensure consistency with and promotion of sound and effective risk management to avoid excessive risk taking;
  • Avoid or manage conflicts of interest.

The variable component of remuneration should at all times be reasonable compared to the fixed component of the remuneration. Remunerations to be applied shall always provide for appropriate balance between fixed and variable remuneration elements and should be in line with the business strategy, objective, value and interest of Luxembourg Fund Partners S.A.. The maximum limit of the variable component of the remuneration does in principle not exceed 100 % of the annual gross salary of the employee.

The total amount of remuneration is based on a combination of the assessment of the performance of the individual, the business unit concerned and the overall results of Luxembourg Fund Partners S.A.

Luxembourg Fund Partners S.A. may perform an “ex‐post risk adjustment” of the variable remuneration, in presence of certain factors (such as for example but not limited to, evidence of misbehavior or serious error by the person in scope; significant downturn in the financial performance or a significant failure of risk management in Luxembourg Fund Partners S.A. in its relevant business unit; significant change in Luxembourg Fund Partners’ financial situation and in general when the bonuses have been based on fraudulent data) which may lead to the reimbursement (clawback) or the total or partial cancellation (malus) of bonuses awarded to the person in scope.

Bonus shall not be offered if they cause conflicts of interest, specifically regarding the ability of Luxembourg Fund Partners S.A. to have sound risk management and clients’ and investors ‘protection principles in place.