Additional information is made available by the Management Company on the following website, in accordance with the provisions of Luxembourg laws and regulations: https://www.ubs.com/global/en/asset-management/investment-capabilities/platform-services/fms/fund-management-company/fml-procedures.html

This additional information includes the procedures relating to complaints handling, the strategy followed for the exercise of voting rights of the Fund, the conflict of interest , the remuneration and best execution policy.

1. Cyber Security Policy

"UBS (Irl) ETF plc (the "Company") regulated by the Central Bank of Ireland (the "Central Bank") and UBS ETF SICAV (The "Company) regulated by CSSF have adopted this cyber-security policy (this "Policy") as part of its internal arrangements to ensure it has effective and robust safeguards in place to mitigate the risk of a cyber-security attack and document its reliance on third party service providers' cyber-security arrangements to protect the Company's technology and assets.

As a regulated entity, the Company is committed to ensuring the highest possible standards including that of its cyber-security arrangements.

As the Company is an investment fund it places reliance on the cyber-security policies of the Service Providers as they are the front line of defense for the Company and have the necessary infrastructure, systems and controls in place to mitigate these cyber-security attacks on the Company's technology and assets. The Manager places reliance on the cyber-security policies of its delegates.

The Company is satisfied that each service provider has a robust and effective cyber security policy in place to mitigate the risk of cyber-security attacks on the Company's technology and assets. The Manager is satisfied that each service provider has a robust and effective cyber security policy in place to mitigate the risk of cyber-security attacks on the Company's technology and assets.

Where a cyber-security breach has occurred that impacts investors or the Company's technology or assets, the service providers are required to immediately notify Michael Bern providing him with full details of the issue, the impact and remediation steps. Where a cyber-security breach has occurred that impacts investors or the Company's technology or assets, the service providers are required to immediately notify the Manager providing them with full details of the issue, the impact and remediation steps.

Each Service Provider should provide a full report on their cyber security policies and confirm in writing, to the Manager that their cyber security policies are being adequately maintained, reviewed and tested annually and that they are operatively effectively. Each Service Provider shall confirm in writing, on an annual basis, to Michael Bern that their cyber security policies are being adequately maintained, reviewed and tested annually and that they are operatively effectively. Michael Bern will send this confirmation to Manager in order for the Manager to make the relevant reporting's to the Board of Directors of the Company."

2. Whistleblowing Policy

UBS has a policy entitled “Whistleblowing Protection for Employees” which is applied to the UBS group. As part of this policy all UBS employees are encouraged to promptly report any conduct which they reasonably believe violates any applicable laws, regulations, rules, or other legal requirements, or applicable UBS codes of conduct and policies, ethical code or any professional standards, with assurance that they will receive adequate protection.

The UBS (Irl) ETF plc UBS and UBS ETF SICAV has adopted this UBS Whistleblowing policy. Any independent Director / non UBS employees that perform duties for an investment company, for which the Management Company acts as Management Company has access to the below misconduct form which can be found under the following website to report any concerns which he/she may wish to raise in the form of a whistleblowing disclosure: 

https://www.ubs.com/global/en/contact/ubs-staff-misconduct.html

The Board will review this whistleblowing policy on an annual basis with a view to making changes when considered necessary or appropriate for the Company. Any amendments to this whistleblowing policy shall be approved by the Board.

Complaints Handling
In case you wish to address any complaint to UBS Fund Management (Luxembourg) S.A., please send your concerns to:
UBS Fund Management (Luxembourg) S.A.
Head of Compliance
33A avenue J.F. Kennedy
L-1855 Luxembourg
email : sh-ubsfml-compliance@ubs.com

The Compliance department will confirm receipt of your mail and organize the answer to your concerns in the shortest possible timeframe.

The remuneration policy, complaint handling policy, whistleblower, policy and cyber security policy and market abuse policy may be obtained free of charge on request from the Management Company.