Potential conflicts of interest

The instructions apply to all Swisscanto employees who could become directly or indirectly involved in one of the following conflicts of interest when rendering services and performing their work:

If Swisscanto as an individual enterprise, or as part of the reciprocal relationships with other Swisscanto Group companies and Zürcher Kantonalbank and their employees

• makes a profit or avoids a loss which is to the detriment of investors.
• has an interest in the outcome of a service rendered for the fund or investor, or in a transaction executed for the fund or investor, which is contrary to the interests of the fund/investor in this outcome.
• has a financial or other incentive to place the interests of one or more investors before the interests of one or more other investors or before those of the fund. (Equal treatment)
• pursues the same commercial activities as the investor.
• receives a benefit, in addition to the customary commission or fee, in the form of money, goods or services, now or in future, from a person other than the investor, in relation to a service rendered for the investor/fund.

Swisscanto employees are obliged to report conflicts of interest or suspicions of a conflict of interest without exception to the internal contacts in Legal and Compliance. In cooperation with Compliance, incoming reports are documented and appropriate measures defined to avoid conflicts of interest. Compliance then also checks the implementation of the defined measures.

Compliance regularly reviews the conflict of interest policy and its implementation.

Swisscanto ensures that its delegates have an equivalent conflict of interest policy and that potential conflicts of interest are disclosed.

Avoiding conflicts of interest

Proprietary trading

Swisscanto has taken measures in an instruction "Proprietary trading by employees" to avoid potential conflicts of interest.

Gift acceptance

Pecuniary benefits in the form of payments, gifts, invitations, etc. from business partners, such as customers, can influence decisions and thus endanger the independence of employees. With the instruction "Gift acceptance", Swisscanto has regulated the consistent handling of the acceptance of gifts within Swisscanto in relation to the avoidance of conflicts of interest.

Secondary employment and external appointments

An employee must devote to Swisscanto their working hours and activities defined in accordance with the employment contract. The acceptance of a public office and the assumption of specific, private, part-time duties (appointment on bodies of trading companies, cooperatives and foundations) require the prior written consent of Swisscanto's decision-makers.

Market conduct rules

The misuse of confidential price-relevant information by employees for themselves, third parties or the benefit of Swisscanto and Zürcher Kantonalbank must be prevented. With the "Market conduct rules" instruction, Swisscanto has defined the procedure in the event of the knowledge of insider information and the prohibition on disclosure or the use of insider information.

Compensation

Compensation is based on a basic salary (fixed salary) and a variable component (bonus). The bonus is linked to the achievement of the employee's targets and the overall performance of Swisscanto. Compensation does not directly depend on the conclusion of individual transactions. Further details can be found in the compensation policy of Swisscanto Asset Management International S.A., which is available here. 

Implementation of measures

The affected employees and departments must implement the corresponding measures to avoid conflicts of interest in a timely manner. The implementation of the measures is monitored. A register of conflicts of interest is maintained by Swisscanto and presented annually to the Board of Directors, the general management and the competent supervisory authority.

Disclosure of unavoidable conflicts of interest

If the measures taken to regulate the avoidance of conflicts of interest are insufficient, such that the interests of the customer are impaired, Swisscanto shall clearly disclose to the customer the general nature and/or source of the conflicts of interest before performing services on their behalf.

Contact

Please do not hesitate to contact Swisscanto for further information:

Swisscanto Asset Management International S.A.
6, route de Trèves
L-2633 Senningerberg
Luxemburg
Contact
Tel.: +352 27 84 35 92

Last updated: February 2022