- Voting Rights and Shareholders Engagement Policy
- Conflict of interest policy
- Best execution policy
- Client complaints handling procedure
- Remuneration policy
- Sustainability Policy
- Summary of investors’ rights
2. Conflict of interest policy
As a general principle, the directors and employees of all RAM group companies must always to act in the best interests of the investors of the RAM Funds. RAM’s policy is to take all reasonable steps to maintain and operate effective organizational and administrative arrangements to identify and manage relevant conflicts. It conducts its business in accordance with the principle that it must manage conflicts of interest fairly, both between itself and the managed Funds (incl. investors) and between one Fund and another (incl. respective investors). The aim is to take all reasonable steps to identify and adequately manage conflicts of interest entailing a material risk of damage to the Funds’ and the Funds’ investors’ interests.
Management is responsible for ensuring the Firm’s systems, controls and procedures are adequate to identify and manage conflicts of interest. The Compliance team assists in the identification and monitoring of actual and potential conflicts of interest. The conflict of interest policy is available on request by clicking here
3. Best execution policy
The Markets in Financial Instruments Directive (“MiFID”) requires all investment firms when executing orders on behalf of clients to take reasonable steps to obtain the best possible result.
As part of its management of UCITS RAM Active Investments SA (“RAM”) 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 the best execution obligation.
The criteria for best selection of execution venues are set down in this procedure and are continuously reviewed by RAM managers. This procedure is being formalised further to cover new brokers’ selection and the rating of existing brokers within a Brokerage Committee composed of members of RAM management, Middle Office and Compliance functions. This Committee will meet each semester and will be in charge of deciding which new broker will incorporate RAM list of authorized brokers based on reputation, human and technical resources, fees and transparency, ability to provide best performance based on "best execution" policy, as well as technical and technological criteria such as access to various markets, FIX connections etc.
RAM selects carefully its counterparties, always seeking to optimise costs and services offered to investors.
As Investment Manager, RAM must take all sufficient steps to obtain the best possible results for the collective investment schemes. This obligation is known as the duty of “best execution” and must take taking into account:
- likelihood of execution and settlement,
- order, size and nature or any other consideration relevant to order execution.
In determining the relevant importance of each of the above factors, the Investment Manager will take into account the following best execution criteria:
- the objectives, investment policy and risks specific to the collective investment scheme, as indicated in the prospectus;
- the characteristics of the order;
- the characteristics of the financial instruments that are the subject of that order;
- the characteristics of the execution venues to which the order can be directed.
RAM does not have soft commission agreements with its counterparties.
4. Client complaints handling procedure
We pay a particular attention to our investors’ satisfaction and the protection of their interests holds a high priority for us.
Consequently, and as per applicable regulatory requirements, we have established a quick and simple procedure in order to grant each of our investors with the faculty to contact the Management Team easily, should one of them need or wish to express dissatisfaction as regards the quality and carrying out of the services rendered by RAM Active Investments SA, its employees and/or Funds services providers.
Thus, we invite you to communicate to us free of charge your dissatisfaction and more generally any complaint that you may have by sending an email by clicking here.
You will receive acknowledgement of receipt of your complaint within 2 business days of its receipt by RAM Active Investments SA, and it shall be answered within 5 business days following the receipt date unless your complaint requires deepest investigation, what you would then be informed of without delay. Please kindly note that a complete description of the complaints handling policy of RAM Active Investments SA is available free of charge to investors upon request by using the above-mentioned email address link.
If for any reasons the complaints handling process does not result in a satisfactory response, you may contact the Luxembourg supervisory authority, the Commission de Surveillance du Secteur Financier, for out-of-courts customer complaint resolution purposes. The detailed procedure can be found at http://www.cssf.lu/en/consumer/complaints.
5. Remuneration policy
As duly licensed management company for UCITS, RAM Active Investments (Europe) SA is required to disclose detailed information on its remuneration policy. Such detailed information on its remuneration policy is available here.
6. Sustainability Policy
As financial market operator, RAM Active Investments (Europe) SA, is required to publish its sustainability policy following the REGULATION 2019/2088 on sustainability‐related disclosures in the financial services sector. This policy is available here.
7. Summary of investors’ rights
Please find attached the summary of Investor Rights (here).