Coller Investment Management (Luxembourg) S.àr.l. - Regulatory disclosures

I. Complaints handling policy

Coller Investment Management (Luxembourg) S.à r.l. (hereinafter “CIM Lux”) has put in place policies and procedures covering the handling of all customer complaints and claims.

In accordance with CSSF Regulation 16-07, complaints for this purpose include any “complaint filed with a professional to recognize a right or to redress a harm.” Simple requests for information or clarification  are not  claims, and accordingly, CIM Lux does not consider them as complaints.

All complaints and claims will be processed in a secure manner within CIM Lux, and in line with CSSF Circular 18-698 and CSSF Regulation 16-07, any person who wishes to do so can file a complaint or a claim by writing to the attention of the Conducting Officer – Compliance of CIM Lux at the email address CCLuxembourgAIFM@collercapital.com or by mail addressed to CIM Lux’s office at BOS (Business Office Services), Le President, 4th Floor, 37A, Avenue JFK, Kirchberg, L-1855 Luxembourg.

A reply (usually in the form of an acknowledgement of receipt) will be sent in writing within 10 (ten) business days following the receipt of the complaint or claim. CIM Lux will provide an answer within a period not to exceed 1 (one) month following the receipt of the complaint or claim. If an answer cannot be provided within this period, CIM Lux will inform the person of the causes of the delay and indicate the date on which an answer will be provided.

If the answer provided is not found satisfactory by the complainant, the Conducting Officer – Compliance of CIM Lux will discuss the content of the complaint or claim, along with the response given, with the board of managers of CIM Lux.

Following deliberations held with the board of managers of CIM Lux, the Conducting Officer – Compliance of CIM Lux will provide a further response and inform the complainant in writing  of alternative ways for resolving the complaint or claim, including by reference to the out-of-court complaint resolution procedure at the CSSF.

For further details on the complaints and claims handling policy, please contact the Conducting Officer – Compliance of CIM Lux at the following email address: CCLuxembourgAIFM@collercapital.com.

II. Policy for the management of conflicts of interests

As an AIFM, CIM Lux has established and implemented, and maintains, an effective conflicts of interests policy. That policy is set out in writing and has been designed with due regard to the size and organization of CIM Lux and the nature, scale and complexity of its business.

As CIM Lux is a member of the Coller Capital group, the policy also takes into account any circumstances of which CIM Lux is or should be aware which may result from its relationships with, or the business activities of, other members of the Coller Capital group.

The conflicts of interests policy of CIM Lux includes the following:

1. a) Measures for the identification of potential or actual conflicts of interests entailing a risk of material damage to the interests of the funds managed by CIM Lux or other clients (together, “Clients”); and
2. b) procedures to be followed and measures to be adopted in order to manage such conflicts.

CIM Lux will keep an up-to-date record of activities and circumstances in which a conflict of interests has negatively impacted, or could negatively impact, its Clients.

Where, in the view of CIM Lux, the organizational or administrative arrangements made by CIM Lux are not sufficient to ensure, with reasonable confidence, that risks of material damage to the interests of its Clients will be prevented, the senior management or board of managers of CIM Lux is promptly informed in order for them to take any necessary decision to ensure that CIM Lux acts in the best interests of its Clients. Where appropriate or required, CIM Lux will report the decision and the reasons on which it is based to Clients.

For further details on the conflict of interests policy, please contact the Conducting Officer – Compliance of CIM Lux at the following email address: CCLuxembourgAIFM@collercapital.com.

III. Proxy voting policy

Considering that CIM Lux performs the portfolio management function for the alternative investment funds under its management (hereinafter “AIFs”), CIM Lux ensures that any voting rights attached to any instrument included in the portfolios of the AIFs are exercised in the best interests of the AIFs, in line with the investment strategy of the AIFs, and consistent with CIM Lux’s proxy voting policy.

CIM Lux maintains a record of the way in which any such voting rights are exercised.

Details of actions taken by CIM Lux regarding the exercise of any such voting rights for any particular AIF are made available free of charge by CIM Lux, at the written request of a limited partner or shareholder in that AIF.

For further details on the proxy voting policy, please contact the Conducting Officer – Compliance of CIM Lux at the following email address: CCLuxembourgAIFM@collercapital.com

IV. Remuneration policy

1. Introduction

The remuneration policy of CIM Lux, in line with Directive 2011/61/EU, applies in the context of the management of AIFs, and sets out principles applicable to the remuneration of the senior management of CIM Lux, all staff members having a material impact on the risk profile of AIFs (“Risk Takers”), all staff members carrying out independent control functions, and any employees receiving total remuneration that takes them into the same remuneration bracket as senior management and Risk Takers.

2. Remuneration principles and proportionality

When establishing and applying the remuneration policy for the aforementioned categories of staff, CIM Lux complies with the remuneration principles applicable to managers of AIFs in a way and to the extent that is appropriate to its size, internal organisation and the nature, scope, and complexity of its activities.

If deemed appropriate, the ESMA guidelines on sound remuneration policies allow CIM Lux to apply proportionality in its implementation of the remuneration principles.

3. Monitoring and review of the policy

The remuneration policy of CIM Lux is reviewed at least on an annual basis, and the outcome of the review is reported to the board of managers of CIM Lux.

For further details on the remuneration policy, please contact the Conducting Officer – Compliance of CIM Lux at the following email address: CCLuxembourgAIFM@collercapital.com.