Legal information
Best execution
A fund management company shall, in accordance with the Swedish Financial Supervisory Authority’s (“SFSA”) binding rules for Fund Managers, strive to provide the best possible result when executing orders and/or placing orders with other parties on behalf of the fund. This includes Lysa Fonder’s obligation to take all sufficient steps to obtain the best possible result for each fund it manages, taking into account price, costs, speed, likelihood of execution and settlement, order size and narue and any other consideration relevant to the execution to the decision to deal.
These factors should be determined in relation to a number of fund and transaction specific criteria, including the funds investment and risk profile and the nature of the portfolio transaction.
Lysa Fonder has determined that when assessing the best execution in most cases the price and cost will be given a high importance. In certain cases the fund management company can however asess that other factors are of greater importance. This includes situations when the fund manager assesses that for example the size and nature of the order or other specific requirements can have a material impact on the price or likelihood of execution and settlement, or if there for other reasons are motivated to give greater importance to other factors than the price.
Where the Management Company combines a portfolio transaction with one or more other portfolio transactions and only partially executes the combined order, the transactions concerned shall be allocated. All funds for which transactions are executed shall receive an average price. As a general rule, the distribution principle is pro rata, which means that the trading volume is distributed as a percentage in relation to the size and price of the orders included in the block. However, investment limitations and restrictions on individual portfolios may mean that this main rule cannot be fully complied with in some cases.
Unitholders can, upon request, receive Lysa Fonder's guidelines for best execution.
Remuneration
None of Lysa Fonder’s employees receive a variable remuneration.
Lysa Fonder is part of a company group (the “Lysa Group”) consisting of three companies; Lysa Group AB (the “Parent Company”), Lysa AB (“Lysa”) and Lysa Fonder. Lysa and Lysa Fonder are wholly-owned subsidiaries of the Parent Company.
As Lysa Fonder is a fund management company we must have a formal remuneration policy. A remuneration policy aims to promote sound and efficient risk management and counteract excessive risk-taking. Somewhat simplified, this is done mainly by setting specific rules for how and when variable compensation and bonuses may be paid out. Lysa Fonder’s remuneration system must be in line with Lysa Fonder’s long term interests, encourage good performance and be able to maintain and attract competent employees.
Lysa Fonder’s remuneration policy has been adopted by the Board of Directors. Lysa Fonder applies individual salaries and does not pay bonuses. To be able to hire competent employees, the Lysa Group however offers stock options in the Parent Company.
In order to fulfill the regulatory requirements, we will annually review and update our remuneration policy. On a yearly basis we will also analyse and identify which employees that have a material impact on the company’s risk profile.
A paper copy of the remuneration policy of the fund management company can be obtained free of charge on request.
Information on the remuneration policy and remuneration is provided in the annual reports of the funds.
Personal data policy
Here you can find Lysa Fonders personal data policy
Complaints
If you are unhappy with our services you are always welcome to contact us. You also have the possibility to file a written complaint.
Lysa Fonder strives to maintain a high level of service. If you are dissatisfied with our services, we gladly accept your views through our customer service. If you are still dissatisfied after such a contact, and you have a claim for financial compensation or correction, you can refer the case to our complaint officer.
Your complaint must be made in writing. Specify times and events as extensively as you can. Please also attach the supporting documents you have in the form of notes, correspondence etc. This is to ensure that all the facts and the background to the complaint are included in the complaint. Please also state your claim for financial compensation.
Lysa handles the complaints we receive with care and urgency, and our goal is that all cases should be answered within fourteen days. If an investigation of the case would require longer processing time, you will receive information about this and when we think we will be able to respond. If we are unable to meet your complaint, you as a customer have the right to receive a written reply with the reasons for this.
The complaint officer is Jessica Sædén. You can send a complaint by e-mail to [email protected].
If you are unhappy with our decision you have the opportunity to receive free advice from the Swedish Consumers’ Banking and Finance Bureau, see www.konsumernas.se. If you are unsuccessful with your complaint to Lysa Fonder’s Complaints Officer function, you have the opportunity to refer the case to the Swedish National Board for Consumer Disputes (Swe. Allmänna reklamationsnämnden - ARN), see www.arn.se for more information, or to the general court. You can also refer a complaint to ARN via the European Online Dispute Resolution (ODR) provided by the European Commission: http://ec.europa.eu/odr..
Principles for shareholders’ engagement
A fund management company must adopt internal rules on how to exercise its voting rights connected to the financial instruments held by the funds managed by the fund management company. Also, a fund company must adopt principles for its shareholders’ engagement in relation to listed companies. The principles shall establish how the fund company integrates the principles for shareholders’ engagement with the investment strategy of the fund. Lysa Fonder is responsible for the ongoing monitoring of relevant corporate events relating to the managed funds, but as a general rule the company shall not have any ambition to exercise influence of the management of the company through ownership. The company has during the past year, for the same reason, not voted at general meetings of portfolio companies; Lysa Fonders principles for shareholder engagement are available at the following link Principles of shareholder engagement
Information relating to the activity of the managed funds
Here you can find information on the activity level of the management of the funds.
Inducement
In connection with the fund management, Lysa Fonder may only pay or receive fees, commission or natural non-monetary benefits under certain conditions.
If the inducement is paid by or to a third party the fees, commission or natural non-monetary benefits must be designed to enhance the quality of the service to the client and shall not impair compliance with the company's overriding duty to act honestly, fairly and professionally in accordance with the best interests of the client. Lysa Fonder has adopted a policy for inducement which is available at the following link Lysa Fonder’s inducement policy.
Money laundering
In order to protect both you and us from being exploited for money laundering purposes, the Swedish Money Laundering Act requires us to have documented knowledge of you as a customer.
What is money laundering, terrorist financing and the Money Laundering Act?
Money laundering is when money from criminal activities, through various transactions, is transformed into assets that can be declared openly. It conceals the criminal origin of the money. Terrorist financing is the financial support of terrorism. This means not only making direct contributions to terrorism, but also collecting, providing or receiving money or other assets that are known to finance terrorism. All financial institutions in the EU are obliged to prevent money laundering. The Swedish Money Laundering Act is based on an EU Directive. The Money Laundering Act means that Lysa must make an assessment of the risk of being used for money laundering. Lysa must also have good knowledge of its customers and their business and understand the purpose of the business relationship and the customer's transactions.
We must ask you questions
To comply with the Money Laundering Act, we must ask questions. Given that Lysa AB is the sole distributor of the fund units, it is also Lysa AB that typically asks these questions to you as a customer. More information about Lysa AB's work against money laundering can be found here. AML
Correction of fund unit value
Lysa Fonder applies procedures to ensure a correct valuation of the funds we manage. Should errors occur in the valuation, this will be handled according to the company's internal rules. These rules have been developed based on the Swedish Investment Fund Association's guidance for handling compensation for incorrect fund unit value.
You can get more information by contacting us at [email protected].
Whistleblowing
For the Lysa Group ("Lysa") it is of utmost importance that suspicions of possible irregularities are detected and addressed as soon as possible. An important part of Lysa's continuous risk management work is therefore the establishment of a whistleblower function to which Lysa's employees and other stakeholders can openly or anonymously report suspected irregularities. Lysa also has an obligation under the Act (2017:630) on measures against money laundering and terrorist financing ("PTL") to provide a reporting system for the purpose of reporting violations of PTL.
To ensure that anonymous reporting of suspected offences within the business is possible, Lysa has an external whistleblower function through cooperation with an independent actor: CRD Protection AB.
CRD receives, manages and investigates reports of suspected violations through a digital whistleblowing service that allows for anonymity for the reporter.
You can find more information and report a case in CRD's whistleblower portal [CRD Protection AB] (https://whistleblowing.crdprotection.com/lysas-visselblasartjanst/).
You can read about how Lysa processes personal data here.
Customer complaints and individual disputes should not be reported via our whistleblowing function.
Report externally We encourage you to report your suspicions via Lysa's whistleblowing function but reports of suspected breaches of financial market rules can also be sent to the Swedish Financial Supervisory Authority and breaches of the General Data Protection Regulation (GDPR) to the Swedish Data Protection Authority.
Swedish Code for Fund Management Companies
Lysa Fonder AB follows the Swedish Code of Conduct for fund management companies. Swedish Code of Conduct
Amendments to this information
Lysa Fonder may at any time make amendments to the information above.
RISK INFORMATION
Investments in funds are always associated with risk. Past performance is no guarantee for future performance. The value of the money invested in a fund can increase or decrease and there is no guarantee that all of your invested capital can be redeemed.. Investors should always contact an independent financial advisor if they are not sure if this investment is suitable for them. We also recommend investors to read the funds prospectus , Key Investor Information Documents (KIID), annual reports and semi annual reports. The documents can always be found on our website, and can in addition also be ordered directly from Lysa Fonder.