Compliance

AIFM Capital is an authorized AIF-Manager and so we are legally obligated to disclose certain important information and documents. Below is a list of such information that are relevant to both fund investors as well as other stakeholders. Some of the documents are only available in Swedish.

Publicly disclosed documents:

Exercise of voting right

An AIFM shall develop adequate and effective strategies for determining when and how any voting rights held in the AIF portfolios it manages are to be exercised, to the exclusive benefit of the AIF concerned and its investors. To comply with this, AIFM has adopted and implemented internal guidelines for exercising voting rights. According to our ownership policy, we shall always vote with the common interest of the investors of the fund. This shall be done if AIFM, through its funds, are among the largest shareholders of the issuer, or if it is considered to be beneficial for the funds return. Voting can only be exercised in accordance with the funds investment policy and/or strategy. In most circumstances, AIFM does not exercise active ownership except for funds investing in non-listed companies. However, AIFM continously monitors the development of all funds’ portfolio companies. When voting rights are exercised, AIFM shall always act in accordance with relevant laws and regulations and otherwise according to good practice in the stock market.

Measures against money laundering and terrorist financing

The board of directors has appointed Dan Hjörnered as responsible for the anti-money laundering function and he will act as the officer for controlling and reporting obligations.

Dan Hjörnered
dan.hjornered@aifmgroup.com
00(46)76-566 01 66

Sustainability

Sustainability criteria is applied to some of the funds managed by AIFM. Information on sustainability critera for funds managed by AIFM can, in applicable cases, be found in each fund’s respective prospectus here.

Market Soundings

AIFM does not participate in market soundings. If AIFM wishes to participate in future market soundings, this will be disclosed.

Conflicts of interest

In order to comply with the regulation and to maintain the public’s confidence in the financial market and for the group, AIFM has established, implemented, and applied an internal policy for preventing, identifying, managing, and monitoring conflicts of interest. The internal policy is evaluated and re-approved at least once per year by the board of directors.

Depositary

AIFM uses the following providers as depositary for the funds:

Skandinaviska Enskilda Banken AB – org. no. 502032–9081
Swedbank AB – org. no. 502017-7753
Intertrust Depositary Services (Sweden) – org. no. 556944–1172
GotYourBack Fund Services AB – org. no. 556954-3993

Complaints

If you are not satisfied with our services, it is important that you get in contact with us as soon as possible. AIFM follows Finansinspektionen’s General guidelines regarding complaints management concerning financial services for consumers (FFFS 2002:23).

If you have a complaint, you should first and foremost contact the employee at AIFM with whom you have had contact regarding the matter to which the complaint applies. Should you still be dissatisfied with this, you can proceed by contacting AIFM’s Complaint Manager in writing.

When making a complaint in writing, attach copies of relevant documents. It is preferred if you indicate which employees you have had contact with in the case, as well as when these contacts happened.

If the complaint is to be regarded as a simple mistake or misunderstanding, this will be rectified as soon as possible. If we are unable to respond to your case within 14 days of receiving the complaint, you will receive written information on this as well as information on the further processing of your case.

Complaints decisions are normally made by our compliance officer, in consultation with relevant managers. If you are not satisfied after the first decision, a final answer will be provided by the compliance officer together with a board member. On this occasion, you are also informed that this is AIFM’s final decision. If this is also not to your satisfaction, you can contact an external body: General Complaints Board or General Court. If you would like to contact these bodies, we will help you.

If you want guidance on your complaint, you can get help from the municipal consumer guide (see your municipality’s website) and at the Consumer Banking and Finance Bureau (www.konsumentbankbyran.se).

Complaints manager:
Dan Hjörnered
dan.hjornered@aifmgroup.com
00(46)76-566 01 66

Partners

List of partners

Return

Historical returns are no guarantee of future returns. The money that is invested in the fund can both decrease and increase in value and it is not certain that the investor will get back all the deposited capital. A fund with risk classes 6-7 can both shrink and increase significantly in value, due to its composition and the management methods used. We recommend that you take note of the fund’s fact sheet, information brochure and fund regulations before investing.