Corporate
Governance

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Policies

  • Best Execution & Order Handling
  • Remuneration
  • Conflict of Interests
  • Voting Rights
  • GDPR Request
  • Complaint Policy

Best Execution & Order Handling

Lemanik Asset Management S.A. (the “Management Company”) adheres to the rules laid down in the UCITS and AIFM Directives and their implementing measures. In this context, the Management Company and its delegates have adopted a best execution policy whose aim is to ensure the fair and prompt execution of portfolio transactions on behalf of UCITS and instructions of its investors.

This policy can be obtained, on simple request, free of charge, via mail to:

Remuneration

<div class="popuptext"><div class="overflow"><p>The Management Company has established and applies a remuneration policy and practices that are consistent with, and promote, sound and effective risk management and that neither encourage risk taking which is inconsistent with the risk profiles, rules, this Prospectus or the Articles nor impair compliance with the Management Company’s obligation to act in the best interest of the Company (the Remuneration Policy).</p><p>The Remuneration Policy includes fixed and variable components of salaries and applies to those categories of staff, including senior management, risk takers, control functions and any employee receiving total remuneration that falls within the remuneration bracket of senior management and risk takers whose professional activities have a material impact on the risk profiles of the Management Company, the Company or the Sub-Funds.</p><p>The Executive Committee is in charge of determining the fixed and variable remunerations of employees. The variable remuneration is granted based on two main criteria: the financial benefit realised at each year end of the management company and the individual’s performance.</p><p>The Remuneration Policy is in line with the business strategy, objectives, values and interests of the Management Company, the Company and the Shareholders and includes measures to avoid conflicts of interest.</p><p>In particular, the Remuneration Policy will ensure that:</p><p>a) the staff engaged in control functions are compensated in accordance with the achievement of the objectives linked to their functions, independently of the performance of the business areas that they control;<br /><br />b) the fixed and variable components of total remuneration are appropriately balanced and the fixed component represents a sufficiently high proportion of the total remuneration to allow the operation of a fully flexible policy on variable remuneration components, including the possibility to pay no variable remuneration component;<br /><br />c) the measurement of performance used to calculate variable remuneration components or pools of variable remuneration components includes a comprehensive adjustment mechanism to integrate all relevant types of current and future risks;</p><p>In context of delegation, the Remuneration Policy will ensure that the Delegate comply with the following:</p><p>a) the assessment of performance is set in a multi-year framework appropriate to the holding period recommended to the investors of the Company in order to ensure that the assessment process is based on the longer-term performance of the Company and its investment risks and that the actual payment of performance-based components of remuneration is spread over the same period;<br /><br />b) if at any point of time, the management of the Company were to account for 50 % or more of the total portfolio managed by the Delegate, at least 50 % of any variable remuneration component will have to consist of Shares, equivalent ownership interests, or share-linked instruments or equivalent non-cash instruments with equally effective incentives as any of the instruments referred to in this item (e); and<br /><br />c) a substantial portion, and in any event at least 40 % of the variable remuneration component, is deferred over a period which is appropriate in view of the holding period recommended to the Shareholders and is correctly aligned with the nature of the risks of the Company.</p><p>A paper copy of the Remuneration Policy is available free of charge to the Shareholders upon request.</p></div></div>

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This policy can be obtained, on simple request, free of charge, via mail to:

Conflict of
Interests

<div class="popuptext"><div class="overflow"><p><strong>1. Foreword</strong></p><p>Lemanik Asset Management (&ldquo;Lemanik&rdquo;) is a management company for third-party investment funds incorporated under Luxembourg law with its registered office in Grand Duchy of Luxembourg.</p><p>Lemanik has branches in Italy and Ireland and representative offices in Hong-Kong and in London.</p><p>Lemanik is authorized to provide activities as:</p><p>- Management Company Chapter 15 of the Law 17 December 2010 ( the &ldquo;2010 Law&rdquo;)<br /> - Alternative Investment Funds Manager (&ldquo;AIFM&rdquo;) as per the Law 12 July 2013 (the &ldquo;AIFM Law&rdquo;), including the services described in the Article 5(4) of the Law 12 July 2013 referred to as &ldquo;Discretionary Portfolio Management&rdquo;.</p><p>Lemanik has in place a conflict of interest ( &ldquo;CoIs&rdquo;) policy applicable in all its locations. This policy describes Lemanik&rsquo;s overall approach in identifying, preventing, managing or disclosing CoIs whatever they are actual, potential or perceived.</p><p>&nbsp;</p><p><strong>2.&nbsp;Legal Framework</strong></p><p>In accordance with the 2010 Law, the AIFM Law, the Commission Directive 2010/43/EU of 1st July 2010, the MIFID II Directive 2014/65/EU and MIFID Commission Delegated Directive 2017/593, the European Regulation no. 596/2014 of 16 April 2014 on market abuse, the Commission Delegated Regulation (EU) no 231/2013, the CSSF Regulation 10-04 and the CSSF Circular 18/698, Lemanik developed strategies for identify, manage and when necessary disclose CoIs.</p><p>&nbsp;</p><p><strong>3. Identification of cois</strong></p><p>Lemanik accepts that CoIs arise in the normal course of its activities. Lemanik does not seek to eliminate all CoIs but to mitigate their risks and to manage them in a way which is sufficient to ensure that (i) client&rsquo;s interests are put first, (ii) there is no material damages suffered by the client and (iii) a fair treatment of clients is guaranteed.</p><p>A. General Rules</p><p>Lemanik identifies and keeps up to date a registrar of CoIs situations which are likely to encounter as part of its activities.</p><p>For the purpose of identifying conflicts of interest that may arise, it must be considered whether Lemanik (employee or persons directly or indirectly linked to Lemanik by control, or involved in the provision of services to Lemanik under a delegation arrangement):</p><p>- is likely to make a financial gain, or avoid a financial loss, at the expense of a client;</p><p>- has an interest in the outcome of a service or an activity provided to a client or of a transaction carried out on behalf of a client, which is distinct from the client' interest in that outcome;</p><p>- has a financial or other incentive to favour the interests of a client over the interests of another client;</p><p>- is involved in a business that is the same as the client&rsquo;s business;</p><p>- receives from (or gives to) a person other than the client an inducement for entering into a transaction with a client or for providing a service to it, in the form of a fee or a non-monetary benefit (hereinafter together referred to as benefit). The above shall not apply in case of a standard commission or fee that is payable for the specific service.</p><p>B. Specific Rules</p><p>Lemanik has in place policies and processes covering situations when Lemanik:</p><p>- acts as AIFM or as management company of undertakings for collective investment in transferable securities (&ldquo;UCITS&rdquo;);<br /> - performs portfolio management function;<br /> - performs investment advice and management of individual portfolios on a discretionary basis;<br /> - provides risk management services.</p><p><strong>4.&nbsp;Prevention and management of Conflicts of interest</strong></p><p>In addition to the CoIs policy, appropriate provisions are included in the following policies in order to set out specific measures for the identification, prevention and management of CoIs:</p><p>- Remuneration policy<br /> - Personal account dealing<br /> - Gift and entertainment<br /> - Code of conduct</p><p>In addition, Lemanik has in place adequate organizational measures including segregation of duties.</p><p>Lemanik established a CoIs Committee who (i) assesses the existing and potential CoIs situations, (ii) maintains and updates the register of CoIs, (iii) decides on the mitigation measures. The CoIs Committee reports at least annually to the COMEX and Board of Directors of Lemanik.</p><p>&nbsp;</p><p><strong>5.&nbsp;Amendment and review of the POLICY</strong></p><p>Lemanik is committed to ensuring that its policies and procedures are comprehensive and kept up-to-date, particular as new information, techniques, laws and regulations come into effect or in case of change in Lemanik business model.</p><p>&nbsp;</p><p><strong>6. Disclosure of the POLICY</strong></p><p>The full policy can be made available at Lemanik&rsquo;s premises to any investor who requests it.</p></div></div>

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This policy can be obtained, on simple request, free of charge, via mail to:

Voting Rights

Lemanik Asset Management S.A. (the “Management Company”) adheres to the rules laid down in the UCITS and AIFM Directives and their implementing measures. The Management Company has adopted a policy with defined Key Principles regarding the exercise of voting rights attached to the financial instruments held by the funds under management.

This policy can be obtained, on simple request, free of charge, via mail to:

GDPR Request

If you wish to send a GDPR request, please send a email to: "[email protected]".

Please ensure that you indicate "GDPR Request" as the subject of your email and the appropriate subcategory of Deletion, Retrieval, or Rectification to indicate the specific GDPR rights you would like to exercise.

Please provide the following information with your request (this part is important for us to be able to help you as quickly and accurately as possible):

Complaint Policy

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<p>Lemanik Asset Management S.A. (the &ldquo;Management Company&rdquo;) is subject to the supervision of the Commission de Surveillance du Secteur Financier (&ldquo;CSSF&rdquo;). The Management Company has adopted a Complaint Handling policy for managing investor complaints in an effective manner.</p>
<p>Investors may file complaints free of charge in the official language or one of the official languages of their Member State.</p>
<p>Any complaint shall be sent to the attention of the Complaint Handling Officer of the Management Company at:</p>
<p>Lemanik Asset Management S.A.<br />106 route d&rsquo;Arlon<br />L-8210 Mamer<br />Grand Duchy of Luxembourg<br /><br />Email: <a href="mailto:[email protected]">[email protected] </a></p>
<p>The following steps will be taken by the Complaint Handling Officer upon receipt of an investor&rsquo;s complaint:</p>
<p>- An acknowledgment letter will be sent to the investor within ten business days after receipt of the complaint where the complaint cannot be closed within these ten business days.<br />- The investor will be informed of the name of the person handling the complaint.<br />- An answer will be provided to the investor without undue delay. It must be handled within a period which will not exceed one month between the date of receipt of the complaint and the date at which the answer is sent. When an answer cannot be provided by the Complaint Handling Officer within this period, the Complaint Handling Officer informs the investor of the causes of delay and indicate a timeframe for resolution.</p>
<p>The Management Company informs the investors of the existence of the out-of-court dispute settlement procedure with the Commission de Surveillance du Secteur Financier (the &ldquo;CSSF&rdquo;).</p>
<p>This out-of-court resolution applies where the complainant did not receive a response or satisfactory response within one month of a complaint being submitted to the Management Company. In this case, the complainant can refer to the CSSF by the following means:</p>
<p>- Either by filling in the form (PDF or online) available at the following address: http://www.cssf.lu/en/consumer/complaints/<br />- Or by e-mail at <a href="mailto:[email protected]">[email protected]</a><br />- or by mail (simple mailing, no registered letter required) to the following address: CSSF, 283 route d&rsquo;Arlon, L-2991 Luxembourg;<br />- or by fax sent at the following number: (352) 26 25 12601;<br />- or by e-mail at the following address: <a href="mailto:[email protected]"> [email protected] </a></p>
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This policy can be obtained, on simple request, free of charge, via mail to:

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