Important Legal Information

SWISS FUNDS

1. GENERAL TERMS & CONDITIONS AND RELEVANT INVESTOR INFORMATION

It is important that you (hereinafter referred to as the ‘User’) familiarize yourself with these terms and conditions for using this Website and information before you go on to access this Website.

By accessing and using GERIFONDS SA’s Website (hereinafter referred to as the ‘Website’), the User hereby formally agrees to accept these terms and conditions, and takes due note of the important legal information outlined below. If the User does not agree to accept these terms and conditions, the User is kindly requested to leave the Website.

2. PROVIDER

The Website provider is GERIFONDS SA, rue du Maupas 2, P.O. Box 6249, CH-1002 LAUSANNE, Switzerland (hereinafter referred to, for the purposes of these terms and conditions, as GERIFONDS). GERIFONDS is a limited company registered in the Commercial Register of the Canton of Vaud under Entry No.H987/00252 and Federal Registration No.CH-555-0081921-4. GERIFONDS is a fund management company authorized for business in Switzerland by the Swiss Financial Market Supervisory Authority (FINMA), Laupenstrasse 27, 3003 Bern.

3. SALES RESTRICTIONS

The collective investment schemes (hereinafter referred to as the "Funds") referred to on this Website are registered at least in their relevant countries of origin and in Switzerland. Any offer, sale or delivery of fund units in other countries shall be subject to the relevant legislation of those countries involved.

In particular, the Funds have not been nor will be registered under the Securities Act of 1933 in the USA (hereinafter referred to as the ‘Securities Act’). The offer or sale of Fund units in the United States by a distributor may be in violation of the registration requirements under the Securities Act.

Fund units may not be offered, sold, assigned, or delivered, directly or indirectly:

1) In the United States, its territories, possessions, or areas under its jurisdiction; or

2) To US citizens (national or bi-national) regardless of their domicile or residence; or

3) To persons domiciled or residing in the United States; or

4) To other natural or legal persons, trusts, legal entities, or other structures whose income and/or returns, regardless of their origin, are subject to US income tax; or

5) To those who have the status of "US Persons", as defined under Regulation S of the Securities Act and/or the US Commodity Exchange Act of 1936 in their current version; or

6) Trusts, legal entities, or other structures created for the purpose of enabling those mentioned under numbers 1 to 5 to invest in these Funds.

The placement restrictions applicable to each Fund are also published in the Fund’s respective prospectus.

4. LOCAL RESTRICTIONS

This Website is not intended for those persons coming under jurisdictions in which (on the grounds of their nationality, place of residence or for any other reason) the publication and availability of or access to this Website are prohibited. Any User subject to such restrictions shall neither access nor use this Website.

It is possible that products and services exhibited on this Website are not available to or authorized for persons covered by other jurisdictions than Switzerland (on the grounds of their nationality, place of residence or for any other reason). It is incumbent on the User to seek advice about any sales restrictions that might apply to the relevant products and services.

5. EXERCISING CREDITOR AND CORPORATE RIGHTS

The terms & conditions for exercising creditor and corporate rights related to investments in funds governed by Swiss law are set out in the prospectuses of these funds under Information on the fund management company and Exercising creditor and corporate rights. Upon request, investors can obtain information on exercising creditor and corporate rights. Requests should be sent in writing to GERIFONDS SA, P.O. Box 6249, 1002 Lausanne or to the e-mail address at: @email.

6. INVESTOR COMPLAINTS AND CLAIMS

Any investor complaints and claims relating to the Funds should be addressed in writing to GERIFONDS SA, P.O. Box 6249, 1002 Lausanne or to the e-mail address at: info@gerifonds.ch.

7. COPYRIGHT

The entire content of the www.gerifonds.ch Website is protected by copyright. It is possible to download or print pages or selected sections of this Website provided that the indications relating to copyright protection or other references to rights of ownership over the material are not removed. Downloading or any other form of copying software or information posted on the Website confers no rights whatsoever over such material. The User may not reproduce all or part of, transmit by any means whatever, modify or use the Website for public or commercial purposes or establish any links to this Website without securing permission in advance from GERIFONDS.

8. RELATED SITES

GERIFONDS assumes no responsibility for the content of other websites linked to or from this Site. Links to other sites or pages outside the Site are at the User's own risk.

9. COOKIES

What is a cookie?

A cookie is a small file, generally made up of letters and numbers, inserted by the browser and stored on your computer or digital device when you visit a website. Cookies, for example, enable maintaining your session active or facilitating your navigation. Thus, if you connect to a website using the same terminal, the browser can recognize your preferences.

Can I refuse cookies?

Anyone who does not wish to have cookies stored on their computer or digital device must configure their browser to refuse them before using the site. The disadvantage of this is that some features of the site may not work properly without the help of cookies.

Type of cookies used by GERIFONDS

GERIFONDS uses several types of cookies. Some are essential, others are optional, or they can be blocked. Refusing or blocking certain cookies may affect your navigation on the site.

Would you like more information about cookies?

Visit the website of the Federal Data Protection and Transparency Officer (FDPIC): https://www.edoeb.admin.ch/edoeb/fr/home/protection-des-donnees/Internet_und_Computer/explications-concernant-le-webtracking.html.

10. NO RECOMMENDATIONS AND PERFORMANCE

This Website has been constructed for the sole purpose of providing information. It is not soliciting funds nor making any offer to buy or sell investments, nor is it making any personalised investment recommendations.

As the risks associated with certain types of investment do not suit all investors, it is incumbent on the User to consult documents pertaining to the Funds, such as prospectuses, fund contracts, management regulations/bylaws, annual and interim reports, and to contact your advisers to analyze in detail your risk profile and to gather information about the risks inherent in making any investment decision.

Past performance of an investment cannot be taken as a guarantee of present or future performance. The value of investments can go up or down for a whole variety of reasons. It is, therefore, possible that investors may not recoup their initial outlay invested. Moreover, fluctuations in exchange rates can also cause the value of an investment to rise or fall.

11. RELIABILITY OF INFORMATION POSTED ON THIS WEBSITE

GERIFONDS strives to select all the information posted on this Website with great care and attention. It cannot, however, provide any guarantee whatever as to the accuracy, reliability or comprehensiveness of this information. Any decision taken on the basis of information posted shall thus be taken at the User’s sole and exclusive risk, with GERIFONDS disclaiming all responsibility or liability for any direct or indirect losses, damages or detriment.

Furthermore, GERIFONDS reserves the right to alter the content of this Website at any time and without giving prior notice.

Only texts of prospectuses, fund contracts and management regulations/articles of incorporation in French are legally binding. GERIFONDS cannot be held liable for versions of these texts translated into other languages.

12. NO GUARANTEE

GERIFONDS, together with its directors, managers, employees, ancillary staff and shareholders, and third-party information providers, together with their directors, managers, employees, ancillary staff and shareholders, hereby expressly disclaim all responsibility or liability for any indirect or direct losses or damages whatsoever that might stem from accessing this Website or from making use of information or opinions posted on this Website or that might result from Users being unable to access or use information or opinions posted on this Website. In particular, GERIFONDS, together with its directors, managers, employees, ancillary staff and shareholders, cannot be held liable at all for any damage or loss incurred following an error, technical or otherwise, a failed download, a system overload, problems with accessing or using the Website, any disruption in the service (including, specifically, maintenance of the system), any delay in the transmission of data, any incompatibility between this Website and the User’s files and/or software (most notably the User’s browser) and/or computer, any malfunction, interference, virus infection or transmission of a computer worm or bug to the User’s hardware, any illegal intrusion into the Website (such as through computer hacking), any intentional and malicious blocking of telecommunications tools or networks (e.g. caused by the mass sending of emails or targeted attacks to cause a service to crash) or any other shortcoming or failure of telecommunications or network service providers.

13. PARTIAL NULLITY

If one or more of the provisions stipulated in these terms and conditions of use is or becomes not valid, non-compliant or not applicable as a result of a legal ruling or provision, this shall in no way result in other provisions stipulated in these terms and conditions of use being rendered null and void, being cancelled or being non-executable. Any clause deemed to be invalid, non-compliant or inapplicable will be replaced by a valid, compliant and applicable clause corresponding as closely as possible to the meaning and intention of the clause rendered invalid.

14. APPLICABLE LAW & JURISDICTION

All legal relations between the User of this Website and GERIFONDS shall be subject to Swiss law. The place of execution, the exclusive place of jurisdiction for any legal proceedings and the court for pursuing claims – but, in the case of the latter, this refers solely to Users of the Website that are not domiciled in Switzerland – shall be filed at the place of domicile of GERIFONDS’ head office in Lausanne. Those mandatory places of jurisdiction as stipulated in relevant Swiss law and international conventions ratified by Switzerland shall be reserved. GERIFONDS, however, reserves the right to institute legal proceedings in the place of domicile of the User of the Website or at any other court with the relevant authority.

15. AMENDMENTS TO THESE TERMS AND CONDITIONS OF USE

GERIFONDS reserves the right to amend the terms and conditions for using this Website at any time and without prior notice.

Last updated on 25/09/2020.

LUXEMBOURG FUNDS

1. INTRODUCTION AND APPLICABILITY OF THESE TERMS & CONDITIONS OF USE

It is important that you (hereinafter: the "User") are aware of the terms and conditions of use and information herein before continuing your visit to the Site.

By accessing and using the GERIFONDS (Luxembourg) SA website (hereinafter: the "Site"), you expressly agree to the terms and conditions of use and take note of the legal information mentioned below. Otherwise, the User is asked to leave the Site.

2. SUPPLIER

The Site supplier is GERIFONDS (Luxembourg) SA, 16 rue Jean-Pierre Brasseur, 1258 Luxembourg (referred to in the terms and conditions of use herein as: GERIFONDS). GERIFONDS is a UCITS management company under the Luxembourg law of December 17, 2010 and an alternative fund manager (AIFM) under the Luxembourg law of July 12, 2013. The focus of GERIFONDS’ professional activities is the management of collective investment schemes. GERIFONDS is registered with the Trade and Companies registry of Luxembourg; section B, under number 75.032. GERIFONDS is a management company authorized and supervised in Luxembourg by the Commission de Surveillance du Secateurs Financier (CSSF).

3. SALES RESTRICTIONS

The collective investment schemes (hereinafter referred to as the "Funds") mentioned on the Site are registered at least in their country of origin (Luxembourg). Any offer, sale or delivery of shares in other countries is subject to the laws applicable in these countries.

In particular, the Funds have not been and shall not be registered under the Securities Act of 1933 of the United States of America ("Securities Act"). The offer or sale of Fund units in the United States by a distributor may be in violation of the registration requirements under the Securities Act.

Units of the Funds may not be offered, sold, assigned, or delivered, directly or indirectly:

1) In the United States, its territories, possessions, or areas under its jurisdiction; or

2) To US citizens (national or bi-national) regardless of their domicile or residence; or

3) To persons domiciled or residing in the United States; or

4) To other natural or legal persons, trusts, legal entities, or other structures whose income and/or returns, regardless of their origin, are subject to US income tax; or

5) To those who have the status of "US Persons", as defined under Regulation S of the Securities Act and/or the US Commodity Exchange Act of 1936 in their current version; or

6) Trusts, legal entities, or other structures created for the purpose of enabling those mentioned under numbers 1 to 5 to invest in these Funds.

The placement restrictions applicable to each Fund are also published in the Fund’s respective prospectus.

4. LOCAL RESTRICTIONS

The Site is not intended for persons in any jurisdiction where (by reason of their nationality, residence or otherwise), the publication or access to this Site are prohibited. Users subject to such restrictions must neither access nor use the Site.

It is possible that the products and services displayed on the Site are not available or authorized for persons subject to a jurisdiction other than Luxembourg (because of their nationality, residence or otherwise). It is for the User to consult his advisers and the sales restrictions pertaining to the products and services in question.

5. COPYRIGHT

The whole www.gerifonds.lu Site is covered by copyright. It is possible to download or print pages or portions of the Site provided that the references to copyright or other notices regarding property rights are not deleted. Downloading or any other form of software copying or information on the Site does not confer any right on the latter. It is not possible to reproduce all or part, transmit in any way, modify, and use the Site for public or commercial purposes or to create links to the Site without prior authorization from GERIFONDS.

6. RELATED SITES

GERIFONDS assumes no responsibility for the content of other websites linked to or leading to this Site herein. The User uses the links that lead to other Sites or pages outside the Site at his own risk.

7. COOKIES

What is a cookie?

Can I refuse cookies?

Type of cookies used by GERIFONDS

GERIFONDS uses several types of cookies. Some are essential, others are optional, or they can be blocked. Refusing or blocking certain cookies may affect your navigation on the site.

Would you like more information about cookies?

8. NO OFFER, PERFORMANCE

The Site was developed for information purposes only and constitutes neither a solicitation nor an offer to buy or sell, or personalized investment advice.

As the risks associated with certain types of investment do not suit all investors, it is incumbent on the User to consult documents pertaining to the Funds, such as prospectuses, fund contracts, management regulations/bylaws, annual and interim reports, and to contact your advisers to analyze in detail your risk profile and to gather information about the risks inherent in making any investment decision.

Past performance cannot be taken as a guarantee of present or future evolution. An investment can rise or fall for many reasons and it is possible that investors will not recover their assets. In addition, fluctuations in exchange rates may cause an increase or decrease in value of investments.

9. RELIABILITY OF INFORMATION PRESENTED ON THE SITE

GERIFONDS strives to carefully select the information it publishes on this Site; it cannot give any guarantee as to its accuracy, reliability or completeness. Any decision made on the basis of this information is taken at the User’s own risks; GERIFONDS disclaims all liability for any loss, damage or direct or indirect damages.

In addition, GERIFONDS reserves the right to modify the content of this Site at any time and without notice.

Only texts approved by the CSSF in the prospectuses and management regulations/statutes are binding. GERIFONDS is not liable for translations into other languages.

10. NO GUARANTEE

GERIFONDS as well as its officers, directors, employees, affiliates and shareholders, and third party information providers and their administrators, directors, employees, affiliates and shareholders assume no liability for direct or indirect loss or damage of any nature whatsoever resulting from access to this Site or use of information or advice available on this Site or inability to access or use the information or advice available on this Site. In particular, the liability of GERIFONDS, and its officers, directors, employees, affiliates and shareholders is excluded for any damage or loss incurred due to an error, technical or not, a transfer failure, a condition of overload, difficulty of use, interruption of service (including, notably, the system maintenance service), a delay in the transmission of information, incompatibility between this Site and the files and/or software of the User (especially with his "browser") and/or computer, malfunction, interference, transmission of a virus or a worm to his computer, illegal access (for example due to hackers), intentional blocking of the tools and telecommunications networks (e.g. following a mass mailing e-mail or denial of service attacks) or any other error providers of telecommunications services or network.

11. PARTIAL NULLITY

Should any provision of the terms and conditions herein be invalid, non-compliant or unenforceable by reason of any statutory provision, it will in no case result in the invalidity, cancellation or the non-execution of the other provisions of the terms and conditions of use herein. The invalid clause, improper or unenforceable shall be replaced by a valid, compliant and applicable clause corresponding as much as possible to the meaning and purpose of the invalid clause.

12. APPLICABLE LAW & JURISDICTION

All legal relations between the User of the Site and GERIFONDS are subject to Luxembourg law. The place of execution, the exclusive jurisdiction for any type of procedure and for prosecution, but with regard to the latter only for the Site User not domiciled in Luxembourg, is at the headquarters of GERIFONDS in Luxembourg. Compulsory jurisdiction provided by applicable Luxembourg law and international conventions ratified by Luxembourg are reserved. GERIFONDS remains nonetheless entitled to take legal action at the domicile of the User’s or before any other competent jurisdiction.

13. MODIFICATION OF THE TERMS AND CONDITIONS OF USE
GERIFONDS reserves the right to modify the terms and conditions of use of the Site at any time and without advance notice.

II. Claims and complaints handling policy
GERIFONDS has put in place policies and procedures covering the handling of all customer complaints and claims.

In accordance with CSSF Regulation 16-17, a complaint shall mean a "complaint filed with a professional to recognize a right or to redress a harm." Thus, simple requests for information or clarification cannot be considered as claims, and GERIFONDS does not consider simple demands for information or explanation as complaints.

All customer complaints and claims shall be processed in a secure manner within GERIFONDS and in line with CSSF Regulation 10-04 and CSSF Regulation 16-17 Any person who wishes to do so, can file a complaint or a claim by sending such complaint in writing to the attention of the compliance officer of GERIFONDS, on info@gerifonds.lu or to GERIFONDS’s office at 16, rue Jean-Pierre Brasseur, L-1258, Luxembourg.

All complaints and claims are handled by the compliance officer of GERIFONDS.

A reply (usually in the form of an acknowledgement of receipt) shall be sent in writing within 10 (ten) business days following the receipt of the complaint or claim.

GERIFONDS provide an answer within a period which cannot exceed 1 (one) month between the date of receipt of the.

If an answer cannot be provided within this period, GERIFONDS shall inform the client of the causes of the delay and indicate the date on which a response will be provided.

If the answer provided is not found satisfactory, the compliance officer of GERIFONDS shall discuss the content of such complaint or claim along with the response given to the client, with the management of GERIFONDS.

If following such deliberations held with the management of GERIFONDS, the client still finds the answer provided insufficient and unsatisfactory, the compliance officer of GERIFONDS will inform the client of alternative solutions for resolving such complaints and claims, and inform in writing of the existence of the out-of-court complaint resolution procedure at the CSSF and send a copy of CSSF regulation 16-17 or the reference to the CSSF website.

For further details on GERIFONDS’s complaints and claims handling policy, please contact the compliance officer of GERIFONDS at info@gerifonds.lu.

III. Policy for the management of conflicts of interest
As a management Company, GERIFONDS shall establish, implement and maintain an effective conflicts of interest policy. That policy shall be set out in writing and shall be appropriate to the size and organization of GERIFONDS and the nature, scale and complexity of its business.

As GERIFONDS is a member of the BCV group, the policy also takes into account any circumstances of which GERIFONDS is or should be aware which may give rise to a conflict of interest resulting from the structure and business activities of other members of the BCV group.

The conflicts of interest policy of GERIFONDS includes the following:

a) Measures for the identification of potential conflicts of interests entailing a material risk of damage to the interests of the funds managed or one or more other clients (the “Clients”) ;

b) procedures to be followed and measures to be adopted in order to manage such conflicts.

GERIFONDS shall keep and regularly update a record of the activities, in which a conflict of interest may negatively impact its Clients. Such record must be kept whether such conflict of interest has arisen or, may arise.

Where the organizational or administrative arrangements made by GERIFONDS are not sufficient to ensure, with reasonable confidence, that risks of damage to the interests of its clients will be prevented, the senior management or other competent internal body of GERFIFONDS is promptly informed in order for them to take any necessary decision to ensure that in any case GERIFONDS acts in the best interests of its Clients. In such situations, GERIFONDS will report such conflicts of interests to its Clients by an appropriate durable medium and give reasons for its decision.

For further details on GERIFONDS’s conflict of interest policies, please contact the compliance officer of GERIFONDS on info@gerifonds.lu.

IV. Proxy voting policy
Considering that in some cases GERIFONDS has delegated the portfolio management function, together with GERIFONDS the portfolio managers (“PM”) to whom such function has been delegated will ensure that each voting rights is exercised in the best interests of the Funds, in line with the investment strategy of the Funds, and in line with GERIFONDS’s proxy voting policy.

Following the execution of a voting right, the PM (as the case may be) should also report to GERIFONDS that it has exercised a voting right, and should also report in which way such right has been exercised (e.g.: with a vote “for” a specific resolution, or “against” a specific resolution, etc.).

Details of the actions taken regarding the voting rights exercised (if any) can be made available free of charge by GERIFONDS, at the unitholders’ request.

More information about the proxy voting policy, can also be made available free of charge by GERIFONDS, at the unitholders’ request.

For further details on GERIFONDS’s proxy voting policy, please contact the compliance officer of GERIFONDS on info@gerifonds.lu.

V. Remuneration policy
1. INTRODUCTION
The remuneration policy of GERIFONDS, in line with Directives 2011/61/EU and 2014/91/EU, applies in the context of managing UCITS and alternative investment funds ("AIFs") (jointly hereafter referred to as "UCIs"), and sets out principles applicable to the remunerations of the senior management, all staff members having a material impact on the risk profile of UCIs, and all staff members carrying out independent control functions.

2. REMUNERATION PRINCIPLES
When establishing and applying the total remuneration policies, for those categories of staff, including senior management, risk takers, control functions and any employee receiving total remuneration that takes them into the same remuneration bracket as senior management and risk takers, whose professional activities have a material impact on the risk profiles of GERIFONDS or of the UCIs managed, GERIFONDS must comply with the remuneration principles applicable to portfolio managers of UCIs in a way and to the extent that is appropriate to its size, internal organisation and the nature, scope and complexity of its activities.

3. PROPORTIONALITY
In taking measures to comply with the remuneration principles GERIFONDS should comply 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 therefore allow GERIFONDS to apply proportionality in its implementation of the remuneration principles.

4. DELEGATED PORTFOLIO MANAGERS OF UCIs MANAGED BY GERIFONDS
Any appointed portfolio manager must demonstrate that he is also subject to an equivalent remuneration policy as defined in Directive 2011/61/EU or in Directive 2014/91/EU.

5. MONITORING AND REVIEW OF THE POLICY
The remuneration policy shall be reviewed at least on an annual basis, and the outcome of the review shall be reported to the board of directors of GERIFONDS.

VII. Best execution policy
GERIFONDS shall take all reasonable steps to obtain the best possible results when executing or placing orders on behalf of the Funds. GERIFONDS’ best execution policy specifically describes the arrangements implemented by the portfolio managers to whom the management of the Funds was delegated, in order to comply with the requirements of the relevant UCITS and AIFM Directives as well as ensuring the best execution of the Funds.

Under such a delegation structure, GERIFONDS ensures and monitors whether the third parties managing the portfolios provide the best execution to the Funds.

This monitoring, for example, is performed through periodic reviews of the best execution measures implemented, of due diligence, and oversight of the policies and procedures of the portfolio managers.

For more information on GERIFONDS’ best execution policy, you can contact the GERIFONDS compliance officer at info@gerifonds.lu.

VIII. Protection of personal data
The General Regulations on Data Protection (GRDP) came into force in the European Union on May 25, 2018. GERIFONDS informs you that the obligations relating to this new regulation have been considered and implemented.

This information applies to all personal data processed by GERIFONDS, acting as data controller.

What sort of personal data is processed by GERIFONDS?

GERIFONDS only collects personal data strictly necessary for investment purposes, in particular managing the registration of the Funds’ unitholders.

GERIFONDS is likely to process in particular:

- Identification data (name, and address, etc.);

- Contact information (email, and phone number);

- Information on professional and extra-professional activity and employment (position, and CV, etc.);

- Information concerning convictions, offenses, penalties, or other measures; and

- Login connection data (extranet, and identifiers).

Such data may be collected directly from the customer or obtained from GERIFONDS’ counterparties, for example.

On what basis is your personal data used by GERIFONDS?

GERIFONDS only processes your personal data if this use is compliant with the legal bases provided by law:

- In the legitimate interests of GERIFONDS;

- In the context of carrying out a contract;

- In compliance with a legal or regulatory obligation; or

- If GERIFONDS has obtained your consent.

For what purpose is your personal data processed by GERIFONDS?

Compliance with legal and regulatory obligations: GERIFONDS may process your personal data to comply with its legal or regulatory obligations. Where appropriate, GERIFONDS may be required to share your information with a regulator or a competent authority, in particular in the fight against money laundering and the financing of terrorism.

Monitoring the commercial or contractual management: GERIFONDS may be required to record and archive email exchanges and/or to share contact data with customers.

Recruitment: GERIFONDS may record and maintain the personal data that you sent as part of an employment application.

In any case, your personal data is subject to security measures, for example, through the use of a password or restricted access.

Is your personal data shared with third parties?

If required, GERIFONDS reserves the right to disclose, make available, or transfer your data to its subcontractors, regulators, or counterparties if this is deemed justified.

GERIFONDS agrees to only transfer your personal data to the third parties listed above, except in cases specifically notified to the persons concerned, as well as in the event of legal obligations or decisions rendered by a court of law, or governmental, supervisory, or regulatory authorities.

Is personal data ever transferred outside the European Union?

As part of our commercial relations, GERIFONDS may be required to disclose and/or transfer your personal data to countries outside the European Union uniquely to execute a contract signed with you, to meet a legal obligation, protect public interest, or to defend the legitimate interests of GERIFONDS.

GERIFONDS ensures that appropriate safeguards are provided, for example through the standard contractual data protection clauses established by the European Commission (e.g. via the Working Party 29).

For how long will your personal data be stored or archived?

GERIFONDS will keep your personal data at most five (5) years after the end of the customer relationship. In accordance with the applicable legislation, if GERIFONDS no longer requires your personal data, it will be destroyed safely according to GERIFONDS internal policy or will be rendered anonymous.

Certain data may be retained for an additional period of time to handle possible claims, to manage pre-litigation and/or litigation, to meet commercial, legal or regulatory obligations or to respond to requests from authorized authorities.

What are your data protection rights?

In accordance with the legislation in force, your personal data rights are as follows:

- A right of access and rectification;

- A right of opposition and restriction of treatment;

- A right to deletion; and

- A right to the portability of your data.

Even against your objection, GERIFONDS may be allowed to continue processing your data, in particular if it is legally required.

Subject to the limitations provided in the present information or by law, you may exercise your rights free of charge by contacting our Data Protection Officer.

Who is the contact person?

If you would like to know more about the provisions of this information, or exercise your rights, please contact the GERIFONDS Data Protection Officer, at the following address:

GERIFONDS (Luxembourg) SA

43 Boulevard Prince Henri

L-1724 Luxembourg

Email: info@gerifonds.lu

Attention: Data Protection Officer

IX. Automatic exchange of information
The OECD developed a Common Reporting Standard (CRS) to achieve full automatic, multilateral information exchange on a global scale. The goal is to increase tax transparency and prevent tax evasion.

The CRS was transposed into Luxembourg law on December 18, 2015 on the automatic exchange of information relating to financial accounts in tax matters ("CRS Law"). The CRS Law requires Luxembourg financial institutions to identify the owners of financial assets and determine whether they are tax residents of countries with which Luxembourg has a tax information exchange agreement. Luxembourg financial institutions will then communicate the financial account information of the asset holders to the Luxembourg tax authorities, who will then automatically transfer this information to the competent foreign tax authorities on an annual basis.

In this regard, the Luxembourg financial institutions shall fulfill the reasonable due diligence and reporting obligations imposed on them, in order to determine which financial accounts shall be declared according to the CRS Law.

As a result, the Funds may require their registered unitholders to provide information concerning the identity and tax residence of the financial account holders, including certain entities and persons controlling them, in order to establish their status and to declare, if necessary, the information concerning a unitholder and his account to the Luxembourg tax authorities (Direct Tax Department) under the CRS Law.

This information may include:

- The identity and information concerning the person having his tax residence in a CRS jurisdiction (full name, address, date and place of birth, tax identification number);

- The identification of accounts held, account numbers, and their balances;

- Financial income received - interest, dividends, proceeds of sales, and other income.

Unitholders are advised to consult with their legal and tax consultants regarding the implications of implementing the CRS Law.

For more information on the automatic exchange of information, especially with Switzerland, you may consult the website of the Secretary of State for International Financial Matters (SIF) at the following address:

https://www.sif.admin.ch/sif/fr/home/themen/informationsaustausch/automatischer-informationsaustausch/automatischer-informationsaustausch1.html.

X. General guidelines relating to sustainability

In 2019, the European Union adopted the Sustainable Finance Disclosure Regulation (EU Regulation 2019/2088 "SFDR") in order to improve transparency with regard to the sustainability and associated risks of investments, as well as towards financial market participants such as AIF or UCITS fund management companies.

The risks relating to sustainability include environmental, social, and governance events or circumstances that may have a significant negative impact on the perceived value of the investment.

The two primary levels of transparency of such information are:

At the entity level;
At the product level, as regards the AIF or UCITS (Funds), presenting environmental or social characteristics or whose investment objectives consist in targeting sustainable investments as defined in the SFDR.

These transparency requirements therefore apply to GERIFONDS (Luxembourg) SA as well as to its representatives to whom it delegates the portfolio management function of the Funds (GLUX). They also apply to the Funds managed by GLUX.

As a financial market participant, GLUX must comply with the requirements of EU REGULATION 2019/2088 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 November 2019 (the Regulation) on the reporting of sustainability information within the financial services sector.

The Regulation introduces harmonized transparency rules for financial market participants and financial advisors. These rules address the integration of sustainability risks, the consideration of negative sustainability impacts in their processes, as well as the provision of sustainability information with respect to financial products.

The Regulation defines sustainability risk as an environmental, social, or governance event or condition that, if it were to occur, could have an actual or potential material adverse effect on the value of an investment.

The Regulation defines sustainability factors as those pertaining to environmental, social, and personnel issues, respect for human rights, and the fight against corruption and bribery.

a) Addressing sustainability risk

GLUX, in particular the Funds, is required to disclose the manner in which potential sustainability risks are factored into their investment decision-making processes.

In accordance with Article 6 of the Regulation, taking into account the diversity of investments in relation to the strategy and investment policy of the UCIs managed by GLUX (hereinafter collectively the "Funds"), sustainability risks may be taken into account among other elements of analysis when making an investment decision but are not the determining criteria defining the framework of the investments actually held in the Funds.

The majority of the Funds managed by GLUX are categorized as either Article 6, i.e. they are products that do not include sustainable objectives or characteristics in their investment process, or under Article 8, i.e. they are funds that do include certain sustainability characteristics as part of their investment approach. For the latter funds, a document outlining how these characteristics or objectives are taken into account is specifically presented on our website under the "document" section referring to each unit class. A pre-contractual document as well as a periodical report also describing certain information pertaining to these sustainability transparency requirements, can also be found in the same section.

In addition, the securities held in the portfolio are subject to regular monitoring to ensure compliance with the principles of the UN Global Compact.

b) Integrating sustainability risks into GLUX's compensation policy

Sustainability risks also form an essential component of our remuneration model.

Sustainability risks are factored into our compensation policies at various levels. They are integrated both in terms of compensation of our delegated managers, as well as at the internal GLUX level.

GLUX's remuneration policy takes into account the inclusion of sustainability risks into the investment decision processes.

Sustainability risk is addressed in particular in the context of a general good governance practice by means of performance assessments under our variable compensation plans. All employees receiving a portion of their compensation as variable pay are assessed against qualitative targets commensurate with their position and responsibilities.

Thus, employee performance is evaluated against risk and compliance outcomes, including sustainability risk. The latter require compliance with regulatory and even self-regulatory standards as part of our internal policies.

c) Failure to take into account the negative impact of investment decisions on sustainability factors

Investors are cautioned that it is rather difficult to assess with reasonable certainty the existence or likely outcome of sustainability risks on investments and/or their impact on the Funds.

Each Fund is expected to comply with its investment policies, objectives, and general investment restrictions as described in the Funds' prospectuses and management regulations. These do not incorporate sustainability considerations.

Furthermore, due to its size, its lack of complexity, and its organization, GLUX does not currently address negative sustainability impacts, nor does it plan on addressing them.

Consequently, and in connection with Article 4 and Article 7 of the Regulation, GERIFONDS (Luxembourg) SA does not take into account the negative impact of investment decisions on sustainability factors.

The Funds' investments do not reflect the European Union's criteria for environmentally sustainable economic activities as specified in EU Regulation 2020/852.

Last updated on March 6, 2023