AISM Luxembourg puts clients interest first
It places a particular emphasis to understanding their investment goals and providing services consistent with those. It also strives to provide them with a comprehensive information, is a spirit of transparency, with this site, the documents made available there as well as all its other communications or publications.
Best selection and best execution policies
The purpose of these policies is to set out AISM Luxembourg practices as regards its financial intermediary selection policy and the obligation of best execution that is imposed on them.
AISM Luxembourg selects its intermediaries on their quality in providing services for the traded instruments: the best execution price, the best execution quality, and (if relevant) the best-suited technology.
The Board of Directors reviews the selection process every year. This review allows AISM Luxembourg to evaluate intermediaries based on the various selection criteria.
As regards derivatives, AISM Luxembourg only deals with one intermediary: Interactive Brokers, one of the leading derivatives trading platforms in the world. This exclusive choice enables AISM Luxembourg to offer its clients a significant size effect and to reduce the costs borne by the Managed Funds.
More information concerning AISM Luxembourg policies is available upon request by mail sent to: firstname.lastname@example.org
Conflict of interest-Voting rights
Unitholders can obtain, upon simple request (sent by mail to email@example.com) the procedures concerning the policy for management of conflict of interest and exercise of voting rights established by AISM Luxembourg.
The Management Company precises that at the date of the present prospectus (August 2016), no variable remuneration is granted to its staff. A fixed remuneration is paid to all staff members.
Would this policy change, the Management Company would establish, according to 2010 Law, a remuneration policy applying to all its staff, including senior management, risk-takers and employees whose professional activities have a material impact on the risk profile of the management company. The remuneration policy will respect the following principles:
- ensure consistency with and promotion of sound and effective risk management to avoid excessive risk taking which would not be in line with the risk profile, management regulation and documentation of the Funds ;
- ensure that remuneration is in line with the business strategy, objectives, values and interests of the Management Company, of the funds it manages or the investor of such Funds, and includes measures to avoid or manage conflicts of interests;
- the evaluation of personnel takes place in a pluriannual frame matching the recommended investment horizon of the managed Funds, to guarantee that the evaluation concerns the long-terme performance of the Funds and their investment risks and that the payment of the variable remuneration which could be associated to the performance is spread out over the same period;
- establish an appropriate balance between fixed and variable components of the remuneration, ensuring that the fixed component represents a sufficiently high proportion of the total remuneration to make non-payment of the variable component possible .
The details of the updated remuneration policy, including among others an illustration of how the remuneration and advantages are calculated, the identity of the people responsible of the allocation of the remuneration and advantages are available on the asset management company’s website: http://www.aism.lu/en/business-ethics. A hard copy shall be made available for free upon request.
Complaints resolution procedure
AISM Luxembourg has a formalized complaints procedure to ensure the issue is resolved timely and to its client’s satisfaction.
The complaints procedure is as follows:
- All complaints must be submitted in writing to ensure that all the correct details are provided to the Company, and that the procedure is managed efficiently and effectively.
- The client will be provided with a written acknowledgment of receipt of the complaint, and the estimated processing time.
- AISM Luxembourg undertakes to evaluate all complaints equitably and will respond as soon as its investigations have been completed.
- All complaints will be reviewed and dealt with independently by the Compliance Officer in a professional and proficient manner.
AISM Luxembourg encourages its clients to address their complaints, queries and concerns to the Compliance Officer on:
or by post to:
ALPHA INVESTOR SERVICES MANAGEMENT
21 rue Aldringen