Business Ethics

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: compliance@aism.lu

Conflict of interest-Voting rights

Unitholders can obtain, upon simple request (sent by mail to compliance@aism.lu) the procedures concerning the policy for management of conflict of interest and exercise of voting rights established by AISM Luxembourg.

Remuneration police

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:

E-mail: compliance@aism.lu
or by post to:
Compliance Officer
ALPHA INVESTOR SERVICES MANAGEMENT
21 rue Aldringen
L-1118 Luxembourg

Terms and Conditions

The website accessible at www.aism.lu is for information purpose only. Nothing contained herein constitutes or shall be deemed to constitute a financial, legal, tax or other advice of any kind and no information on the Website shall constitute or deem to constitute a solicitation or an offer to purchase or invest in, any financial products which are referred to on the Website.

If, in spite of the above, you were to take or consider taking an investment decision based on the information contained on the Website, then you expressly acknowledge and/or agree: that you must be, as the case may be, an investor who is legally or otherwise duly authorised to seek information about the funds referred to or described on the Website; that no investment decision shall be made solely on the basis of the information provided on the Website; that investment in any of the funds referred to on the Website can only be made after careful review, as the case may be with the assistance of its financial advisor, of the corresponding funds' or sub-funds' relevant documentation; that careful attention should, in particular, be given to, as the case may be, the articles of incorporation or management regulations, detailed prospectus or key investor information document, latest available annual and semi-annual reports, as applicable, and of the specific risks exposed in such documents; and that all investments involve risks and that it is your responsibility to collect relevant information about the risks inherent to any investment; that the value of investments and the income from them may go down as well as up and that you may not get back the amount originally invested, and that past performance is not a guide to future performance, hence that any past performance figures shown are not indicative of future performance.

Through this Site, Alpha Investor Services Management  will not collect any personal data about you (e.g. your name, address, telephone number or email address) unless you voluntary choose to provide us with this information (e.g. by registration, survey or some other means), provide your consent, or unless otherwise permitted by applicable laws and regulations for the protection of your personal data. The investment funds mentioned in the Website are not available to US persons unless otherwise indicated in their constitutional documents. Reasonable care has been taken to ensure that the information contained on this Website is accurate at the date of publication. However, no representation or warranty, express or implied, is made to its accuracy or completeness.

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