Guiding Principles of the Undertaking
The acts of the SWM responsible persons are based not only on the legal provisions but also on the guiding principles of the undertaking. We feel responsible for the observance of these guiding principles and live in line with them every day.

Conflicts of interests
The most important part of the management of conflict of interests consists in the prevention of potential conflicts of interests, resp. the prevention of the arising of abstractly existing conflicts of interests. In this relation SWM will take reasonable precautions that to the extent possible prevent the arising of the identified abstract conflicts of interests in the management of a UCITS/AIF or of a client.

Voting policy
Generally, good corporate management is expressed in an increasing exchange rate of the shares in the long run. For this reason SWM is regularly kept informed for the most important questions in relation to the activity and control over the undertaking. This knowledge makes possible the competent exercising of the membership rights and voting rights and enables the participation in the development of the undertaking strategy and the control of the management activities.

Best Execution Policy
Another essential objective is the best possible execution (hereinafter referred to as the “Best Execution“) of the trade decisions of UCITS/ AIF in favour of the clients. The applicable provisions are an integral part of this best execution policy. It points out the principles, in accordance with which SWM executives trade decisions in order to guarantee the best possible execution for investors. The best execution policy applies to all UCITS/ AIF and assets of clients managed by SWM, in respect of which SWM makes trade decisions.

Trade centres
In the enclosed summary you will find a list of the SWM trade centres for collective investment schemes and client portfolios.

Complaint management
We are dedicated to professional complaint management. In this way a possibility is created for you not to lose in case of a complaint and to have the commitment increased. We would like to encourage you to send us each of your complaints and proposals by the enclosed form.

The attached document provides the current charges of Scarabaeus WM AG in respect to time spent based on work.