Luxembourg

Conflict of Interests

UBS Luxembourg Financial Group Asset Management S.A. (UBS LFGAM) must take reasonable measures to detect conflicts of interest that arise when rendering services and pursuing its activities. In addition, measures are to be taken that prevent such conflicts of interest prejudice the interest of the funds it manages and their investors.

UBS LFGAM has adopted the following guiding principles in relation to the identification and management of conflicts of interest:

  • UBS LFGAM is committed to treating its clients fairly and with integrity.
  • UBS LFGAM is committed to complying with all applicable legal and regulatory requirements relating to the proper identification and management of conflicts of interest.
  • UBS LFGAM is committed to maintaining and operating effective organisational and administrative arrangements to identify and manage actual or potential conflicts of interest.
  • UBS LFGAM recognizes that an important factor allowing it successfully to manage conflicts of interest is a culture of integrity. All employees, including the members of the Board of Directors, have a duty to be mindful of conflicts of interest and to take all reasonable steps to assist in their identification and proper management, including prompt escalation to relevant management and/or control functions.
  • UBS LFGAM expects its employees to act with independence.

UBS LFGAM keeps and updates regularly a register with the details of actual and potential conflicts of interest that have arisen or are likely to arise, as well as the mitigation measures implemented to manage those.

Where the arrangements made by UBS LFGAM for the management of conflicts of interest are not sufficient to ensure, with reasonable confidence, that risks of damage to the interests of the funds and their investors will be prevented UBS LFGAM will take any necessary decision to ensure that in any case, UBS LFGAM acts in the best interests of the funds and their investors. UBS LFGAM will report such situations to the funds and their funds investors by any appropriate durable medium including the reasons for its decision.

Investors may request free of charge from UBS LFGAM additional information by writing to:

UBS Luxembourg Financial Group Asset Management S.A.
Attn: Head of Compliance
33A, Avenue J.F. Kennedy
L-1855 Luxembourg

Voting Strategy

UBS Luxembourg Financial Group Asset Management S.A. (UBS LFGAM) manages its voting rights in a prudent and diligent manner, based on a reasonable judgement that will best serve the interests of share/unitholders of the funds it manages. UBS LFGAM has adopted a policy regarding the exercise of the voting rights.

The Policy is to be used as a guideline, but each voting decision involves a unique set of facts that will need to be considered in determining whether the vote is in the best interests of the funds. Acting on behalf of a fund, UBS LFGAM may abstain from voting or declining to vote where, in its opinion, the cost of casting the vote exceeds the economic value of the expected effect of the vote on the investment.

The organisation of the exercise of voting right differs whether the Investment Management function is delegated or not:

  • UBS LFGAM has delegated the Investment Management function to a third party

While UBS LFG AM has the ultimate responsibility with respect to the casting of votes relating to the portfolio securities held by the relevant fund. UBS LFGAM believes that the investment managers who are performing the portfolio management of the funds are in the best position to cast votes in the most beneficial way possible for the funds, and have access to all relevant information to do so. UBS LFGAM has consequently delegated the function of vote casting for portfolio securities held by the relevant fund to each delegated Investment Manager appointed through an investment management agreement, subject to the continuing oversight of UBS LFGAM, and in accordance with the provisions defined under the its voting rights policy. UBS LFGAM authorizes the relevant investment manager to exercise its vote casting responsibilities in accordance with the principles set forth under the policy, with a goal of acting in the best interest of the funds and of reaching their investment objectives.

  • UBS LFGAM has not delegated the Investment Management function

In case UBS LFGAM has not delegated the investment management to a third party then the Investment Management department has the power to exercise voting rights in accordance with the provisions set forth under the voting rights policy of UBS LFGAM.

Investors may request free of charge summarised information on the voting strategy and more details about the actions taken pursuant to the voting strategy by writing to:

UBS Luxembourg Financial Group Asset Management S.A.
Attn: Head of Compliance
33A, Avenue J.F. Kennedy
L-1855 Luxembourg

Complaints Handling

UBS Luxembourg Financial Group Asset Management S.A. (UBS LFGAM) has adopted a Complaint's policy, which provides with a common, clear and precise understanding on the manner UBS LFGAM handle clients' complaints, including a clear definition of the roles and responsibilities of the different stakeholders within the organisation.

UBS LFGAM takes all complaints raised by investors seriously, gives to them the appropriate attention and deals with them in an efficient and timely manner in the best interest of investors.

Investors are entitled to file complaints free of charge with UBS LFGAM.
In case you wish to address any complaint to the UBS LFGAM, please contact us via mail to:

UBS Luxembourg Financial Group Asset Management S.A.
Attn: Head of Compliance
33A, Avenue J.F. Kennedy
L-1855 Luxembourg

UBS LFGAM will confirm receipt of your mail and organize an answer in the shortest possible timeframe.

Best Execution

The Markets in Financial Instruments Directive 2004/39/EC (MiFID) requires all investment firms when executing orders on behalf of clients to take reasonable steps to obtain the best possible result.

UBS Luxembourg Financial Group Asset Management S.A. (UBS LFGAM) has established and implemented a best execution policy setting out the most important and/or relevant factors that it has put in place to comply with its best execution duties.

The purpose of this summary is to provide clients with information on UBS LFGAM’s best execution policy.

Remuneration Policy

The Board of Directors of UBS Luxembourg Financial Group Asset Management S.A. has adopted a remuneration policy whose objectives are on one hand, to ensure that the remuneration framework is in line with the applicable laws and regulations , and on the other hand to comply with the UBS Group Remuneration policy framework.

The Policy is meant to (i) not encourage excessive risk taking, (ii) contain measures to avoid conflicts of interest, (iii) be consistent with a sound and effective risk management and (iv) be consistent with the UBS Group business strategy, objectives and values.

Investors can find more details about the remuneration policy in the annual reports of the funds they are investing in and may request free of charge additional information by writing to:

UBS Luxembourg Financial Group Asset Management S.A.
Attn: Head of Compliance
33A, Avenue J.F. Kennedy
L-1855 Luxembourg