LIOR GP is in charge of the Share class hedging, please refer to: 

1. Object

The  Hedging Prolicy define the procedure followed for performing the hedge calculation and hedge execution. 

2. Key principles

Hedging is usually performed by executing a FX Swap 

• The FX Forward leg of the FX Swap will have a maturity of the last business day of the month, with a maximum of one month. Maturity of FX Forwards longer than 1 month can only be applied with the express consent of the Investment Manager. 
• The FX Spot leg of the FX Swap is executed in order to offset the cash flows in non-reference Currency generated by subscriptions and redemptions.

3. Daily controls 

A daily control of the calculated Hedging Ratio is  performed in order to confirm that the share-class and Sub-Fund is within the Hedging Range (95% to 105%). 

Whereby the calculated Hedging Ratio is outside of the 95% to 105% Hedging Range, a hedging adjustment can be performed by LIOR GP executing a FX Forward to bring the hedging ratio back to approximately 100%. 

LIOR GLOBAL PARTNERS has designed and implemented a remuneration policy (the “Remuneration Policy”) in line with applicable regulations.  The Remuneration Policy remains under regular review and will be updated as required to ensure compliance with applicable legal and regulatory obligations.

LIOR  is committed to align the interests of its clients, employees and directors with a view to deliver performance within the constraints of a strict risk framework. LIOR GLOPBAL PARTNERS seeks to avoid any remuneration schemes that could generate excessive risks and retains the capacity to reduce bonuses materially if significant losses are incurred during a financial year.

The Remuneration Policy is designed to support Lior Global Partners’ business objectives and values and to allow LIOR to navigate a competitive environment, particularly in terms of staff attractiveness, retention and motivation. In line with the above-mentioned rules and regulations, LIOR has developed and implemented a Remuneration Policy that:

• integrates full-year financial results, achievement of strategic and operating results;
• promotes and is consistent with sound and effective risk management of the UCITS funds it manages;
• does not encourage risk-taking which is inconsistent with the risk profiles of or the rules governing the UCITS funds; and
• does not impair LIOR’s ability to act in the best interest of the UCITS funds and ultimately their investors.

1. Remuneration committee

The Board of directors of LIOR has established a Remuneration Committee to oversee the implementation of the remuneration arrangements and to exercise competent judgment on remuneration policies and practices applicable to the Identified Staff. The Remuneration Committee is responsible for assessing, overseeing and reviewing the remuneration arrangements of LIOR, in line with the provisions of the UCITS Directive, ESMA Guidelines.

The terms of the Policy are reviewed annually by the board of directors, with input from Operational Risk & Compliance functions.

2. Identified staff

In line with applicable regulation, LIOR has established a list of employees and directors of LIOR including senior management, risk takers and control functions whose professional activities may have a material impact on the risk profile of LIOR and the funds under management (the “Identified Staff”). This list is reviewed and updated annually by the committee in charge of remunerations (the “Remuneration Committee”).

3. Conflicts of interest

The Policy is designed to avoid conflicts of interest between LIOR and the interests of the UCITS Funds (the “Funds”) it manages and investors. It details how such conflicts are taken into account in setting remuneration, including through the exercise of discretion in setting bonus amounts.

4. Personal Investment Strategies

Employees must not use personal hedging strategies which could undermine the risk alignment effects embedded in their remuneration arrangements

5. Remuneration principles

Rules applying to all employees of LIOR consists of one or several of the following elements:

• a fixed remuneration: all employees receive a base salary. Base salaries are designed to provide a competitive level of remuneration consistent with the employee’s responsibilities and the relevant external labor market.
• a variable (incentive) remuneration: all employees with the exception of temporary staff are eligible to participate in an annual incentive plan. Annual incentives allow for individual participants to be positioned appropriately against similar roles in both the local and global marketplace. Annual incentives are designed to provide a remuneration linked to the Management Company’s business results and the individual employees’ performance, consistent with their business objectives and accomplishments.

6. Variable (Incentive) Remuneration:

LIOR has set up specific rules regarding the payment of the Variable Compensation to the Identified Staff. The following rules apply to the Variable Compensation of the Identified Staff:

• Variable Compensation of a year is announced at the beginning of following year;
• A part (or all, depending on the amount) of the Variable Compensation (“short term incentive”) is paid as cash several weeks after the announcement.
• The remainder of the Variable Compensation (“Deferred Compensation”) is deferred over three years, as required under the UCITS Directive (the “Deferral”).

7. Performance Measurement

When determining compensation including any variable compensation, the Compensation Committee will give consideration to:

• Overall Company’s performance
• Performance of the team(s)
• Risk management or compliance failures relating to current or future risks or events, that impact the Management Company.
• Individual performance relative to job requirements and with specific attention to stand-out performance, and annually agreed upon individual goals. Individual performance is measured by achievement of goals, work quality, behavioural skills and management skills, if applicable.

8. Incentive Remuneration Funding

The short and long-term incentive award pool is funded based on a fixed percentage of certified adjusted OIBT (consolidated Operating Income Before Taxes of LIOR).

The funding pools will be reviewed regularly to ensure that awards are only paid when it is appropriate to do so. Pools are reviewed against firm wide performance to ensure that incentive pools take into account the business results of LIOR. In addition, LIOR will consider:

• Risk or compliance issues or events during the course of a financial year that have impacted the financial performance in that financial year, and make appropriate adjustments to the incentive pool to reflect those issues or events;
• The capital base of LIOR and whether this is appropriate taking into account its risk profile and risk exposures. If additional capital is required, LIOR will consider adjustments to the incentive pool to reflect this.

Pools are reviewed against non-financial, risk (both current and future) and compliance based objectives. The final pool including any risk or capital funding adjustments, will be calculated after year-end.

9. Internal

This Remuneration Policy is part of LIOR’s policy and procedures. The employees are regularly informed about their remuneration, criteria used to measure performance and the link between performance and pay.

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The details of the current remuneration policy of the SICAV’s management company, LEMANIK ASSET MANAGEMENT (LUXEMBOURG) S.A., such as a description of how remuneration and benefits are calculated and the identity of the persons responsible for awarding the remuneration and benefits, are available on the “Regulatory information” page of  www.lemanikgroup.com

LIOR GLOBAL PARTNERS has designed and implemented a conflicts of interest policy (the “Conflicts of Interest Policy”) in line with applicable regulations.  The Conflicts of Interest Policy remains under regular review and will be updated as required to ensure compliance with applicable legal and regulatory obligations.

1. Introduction

LIOR is an asset manager, providing to its clients all forms of placements and investment services. As a result, like any financial services group, it has or may have conflicts of interest when considering engagement and voting matters. However, the protection of LIOR’s client interests is of primary concern and so its conflicts policy sets out how:

• LIOR identifies circumstances which may give rise to conflicts of interest including a material risk of damage to our clients’ interests;
• LIOR has established and will maintain appropriate mechanisms and systems to manage fairly those conflicts.

2. Conflicts of interest

2.1. Generally, a conflict of interest may exist between the members of LIOR or its employees and its clients or between the clients themselves as a result of the intended or actual activities of LIOR or its employees and which may result in detriment to clients or a group of clients. There is a “conflict of interest” in two situations:

1. LIOR is providing a service to a client and may have a material interest, relationship or arrangement in the transaction or product or service;
2. LIOR is acting for a given client and for another client whose interests materially conflict.

LIOR has worked to identify conflicts of interest that may exist in the course of business. These include (non-exhaustive lists):

2.2. Conflicts principally resulting from the fact that LIOR GP has other clients;

1. LIOR casts proxy votes for other clients;
2. LIOR may cast proxy votes consistent with Client(s) investment strategies which may conflict with the investment strategies of other clients of ours, and notably, individual proxy votes may differ between clients.
3. LIOR may cast proxy votes where it has authority to do so. Certain clients retain such authority in certain instances which may conflict with industry or LIOR’s recommendations;

2.3. Conflicts principally resulting from the fact that LIOR GLOBAL PARTNERS may have an own account conflict;

1. Employees of LIOR may from time to time, serve as a director, advisory board member or other oversight capacity for a public or private company
2. while most frequently acting as agent, LIOR may also act as principal when carrying out investment business for a Client or any other investor;
3. LIOR’s employees may invest in their own personal account in securities that are traded in Client portfolios. As a result, employees may vote for their own a/c

2.4. Conflicts specifically relating to proxy voting and engagement on behalf of clients;

1. LIOR may cast proxy votes at companies, or for clients, who may be an Affiliate, or who are otherwise interested in the company at which LIOR is voting;
2. LIOR may, in certain circumstances, cast our votes differently for different portfolios at the same shareholder meeting, in order to reflect differing investment outcomes or for other technical reasons
3. LIOR may cast proxy votes for portfolios which include seed capital or other proprietary monies
4. LIOR, or our clients, may participate in stock lending programs or lend stock to third parties whose investment objectives may be different to ours
5. during the course of engagement with company management, LIOR may inadvertently become ‘insiders’ or privy to material non-public or price-sensitive information

3. Management of Conflicts

LIOR tries to avoid conflicts of interest and, where they cannot be avoided, applies its policies and procedures aiming at identifying, managing/mitigating and monitoring and, where appropriate, disclosing such conflicts of interest with a view of preventing them from adversely affecting the interest of the funds managed by LIOR and their investors and to ensure they are treated fairly.

Measures adopted Some of the measures LIOR have adopted to manage identified conflicts are set out below. LIOR consider them appropriate to our efforts to take reasonable care that, in relation to each identified conflict, LIOR acts independently to avoid material risk of damage to clients’ interests.

3.1. Policies and procedures

LIOR has adopted policies and procedures throughout our businesses to manage conflicts of interests. These policies and procedures will be subject to normal monitoring and review processes.

3.2. Separation of functions

If a business with two functions within LIOR would lead to conflicts of interest, it may separate the functions into two separately managed businesses or ensure that they are managed by different senior members of staff.

3.3. Wall Crossing

The overarching principle of LIOR is that it is considered to be a “public area” that invests and trades in securities based upon publicly available market information and, therefore, if any member of LIOR is made an “insider”, this restricts the firm globally and may not be in the interests of its clients. Employees are therefore aware of the consequences, should inside information be received, that trading for client portfolios and funds will be prohibited on a global basis. Occasionally, inside information may be received, for instance, as part of a pre-sounding for a forthcoming issue of securities; however the period for which LIOR is an insider should be as short as possible. Before the start of any meeting or conversation this should be made clear and brokers and issuers are reminded that if they inadvertently make LIOR “insiders”, it will be detrimental to the ongoing relationship. It is therefore a condition that, where LIOR is made an insider, the broker (or other person) providing the information should give LIOR the opportunity to decline before being provided with the information. Should LIOR receive insider information, the individual(s) in receipt of such information must contact Compliance immediately. They may not share the information with anyone (not even their supervisor) and transactions in the securities of the issuer are prohibited, as well as recommendations of transactions for clients or own personal accounts. The issuer information is placed on a “Banned List” where trading activity is systematically restricted across the LIOR. These restrictions are only lifted either once the transaction has been made public, or when confirmation has been received that the information is no longer relevant.

3.4. Proxy Voting

Where a potential material conflict of interest has been identified in relation to a proxy vote, LIOR will call upon an independent third-party to make the voting decision, or it will contact individual clients to approve any voting decision, or may elect not to vote. Stocks placed on the banned list may not be voted.

3.5. Pay

Pay and bonuses will often be linked to the profits of LIOR without resulting in a conflict of interest. In some cases, however, there would be a conflict and so LIOR avoids such staff payments.

3.6. Gifts and Inducements

The giving and receiving of gifts or inducements has the potential to create conflicts of interest. LIOR employees must not solicit or provide anything of value directly or indirectly to or from anyone, except under limited circumstances, which would impair the LIOR’s duty to act in the best interest of the client.

3.7. Personal account dealing and Outside Business Activity

To prevent conflicts arising from the use of information obtained from clients, and market abuse generally, all employees are subject to personal account dealing rules. In addition, employees are required to pre-clear their outside business activities which are only permitted in limited circumstances.

3.8. Declining to Act

Where LIOR considers that the conflict of interest cannot be managed in any other way, LIOR may decline to act for a client.

3.9. Disclosure

Additional conflicts that are identified by LIOR in the future will be included within appropriate mechanisms or systems in order to manage those conflicts. Where LIOR considers that there are no other means of managing the conflict or where the measures in place do not sufficiently protect clients’ interests, the specific conflict will be disclosed to enable clients to make an informed decision with respect to the services in the context of which the conflict of interest arise.

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The conflicts of interest policy of the SICAV’s management company, LEMANIK ASSET MANAGEMENT (LUXEMBOURG) S.A., can be found at: www.lemanikgroup.com

LIOR GLOBAL PARTNERS (LIOR) has adopted a best execution policy to implement all reasonable measures to ensure the best possible result for the funds it manages, when executing orders. In determining what constitutes best execution, LIOR will consider a range of different factors, such as price, liquidity, speed and cost, among others, depending on their relative importance based on the various types of orders or financial instrument. Transactions are principally executed via brokers that are selected and monitored on the basis of the criteria of the best execution policy. 

Through the use of AMUNDI INTERMEDIATION, LIOR relies on AMUNDI best execution policy, a copy of which can be found at: Amundi Intermediation – Regulatory information | Amundi International | Institutionals & Corporate​ 

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The best execution policy of the SICAV’s management company, LEMANIK ASSET MANAGEMENT (LUXEMBOURG) S.A., can be found at: www.lemanikgroup.com 

LIOR GLOBAL PARTNERS (LIOR) has designed and implemented a complaints handling policy (the “Complaints Handling Policy”) in line with applicable regulations.  The Complaints Handling Policy remains under regular review and will be updated as required to ensure compliance with applicable legal and regulatory obligations.

1. What is a complaint?

A complaint is an expression of dissatisfaction made to LIOR that is related to the services provided by LIOR or to the complaint handling process itself and where a response or resolution is expected by the complainant.

2. How to make a complaint?

As a principle, a complaint must be formally presented in writing in order to be acknowledged, even if the complaint has already been expressed verbally to LIOR. The written communication must be addressed to the Complaints Handling Officer, Mr. Raphaël Remond.

By email: contact@LIOR-GP.com

By post:

LIOR GLOBAL PARTNERS 27 Boulevard Albert 1er, Ermanno Palace, 98000 Monaco

The complainant shall explain in detail the facts behind the complaint, providing all relevant supporting documentation if applicable. When making a complaint, please, provide the following information:

• your name, position and contact details;
• your relationship with LIOR;
• your contact person within LIOR;
• a written summary of the complaint (including when the conduct giving rise to the complaint occurred);
• copies of any documentation supporting the complaint.

3. Complaint handling process

Upon receipt of any complaint, LIOR will record the relevant details. A written acknowledgement will be issued to the complainant within 5 Business Days after receipt of the complaint and will include the name and contact details of the person in charge of the complaint handling process. LIOR will investigate the complaint and will provide to the complainant written explanation of the outcome of the investigation no later than one month after receipt of the complaint. Where a response cannot be provided within the prescribed period of one month, the complainant will be informed of the cause for the delay with an indication of the date by which the investigation will be completed and a final response issued. LIOR might request from the complainant additional information or evidences required to resolve the complaint. 4. If the complaint handling by LIOR does not result in a satisfactory answer for the complainant, the complainant may contact the Commission de Contrôle des Activités Financières (CCAF) for out-of-court resolution within one year after he/she filed the complaint with LIOR. All required information regarding out-of-court resolution of complaints

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The complaints handling policy of the SICAV’s management company, LEMANIK ASSET MANAGEMENT (LUXEMBOURG) S.A., can be found at: www.lemanikgroup.com