Best Execution Policy

FundRock Management Company (“FRMC”) as Management Company under Chapter 15 of the amended Law of 17 December 2010 and AIFM under Chapter 2 of the amended Law of 2013 shall obtain the best possible result when executing decisions to deal on behalf of its funds under management according to the objectives, investment policy and specific risks, as indicated in the respective prospectuses (CSSF Regulation 10-04, article 28, Commission Regulation 231/2013 (AIFMD Level II articles 27 and 28)).

Key Principles

As of today, FRMC always delegates the portfolio management function to appointed Investment Manager (‘IM’) delegates; therefore FRMC ensures that these Investment Managers to which portfolio management has been delegated, have defined implemented and monitor the implementation of a best execution policy.

Responsibilities

The Management Committee of FRMC is defining the best execution framework, ensuring that it is cascaded down to the relevant oversight teams via proper training and instructions.

The Compliance Function ensures that any new rules concerning best execution are analysed and communicated to the teams in charge of delegates oversight. The Compliance Function also ensures monitoring of compliance with the regulatory requirements, i.e. the effectiveness of the control by the FRMC oversight teams on the implementation of the relevant policy requirements by appointed delegates.

FRMC team managers are responsible for defining procedures of oversight that fit legal requirements and compliance advice and for escalating any breach detected to the Management Committee and the respective Funds Boards of Directors.

A paper version of this Policy is made available free of charge to investors at FundRock’s registered office.