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Conflicts of Interest Policy

1. Objectives

Conflict of interest management is one of the most important and comprehensive challenges that a central management company with a register and transfer agent such as navAXX SA has to deal with to protect the investment funds (UCITS and AIF) and their investors that it manages centrally. In this context, the central management company commissioned by the management companies and the registrar and transfer office must always carry out the tasks assigned to them in a neutral manner. This applies in particular to the relationship with the custodians and the management companies of the investment funds. As part of its activities, navAXX SA strives at all times, in consultation and cooperation with its clients (ie the management companies)

  • to act in the best interests of the investment funds (= UCITS and/or AIF) centrally managed by it and their investors;

  • to take all reasonable measures to avoid conflicts of interest and, where these cannot be avoided, to contribute to the identification, settlement, monitoring and, if necessary, disclosure of these conflicts of interest by the management company, in order to prevent them from being detrimental to the interests of the investment funds and their investors and to ensure that the investment funds managed by the Management Company and their investors are treated fairly;

  • not to permit any undue preferential treatment of investors or investment funds, unless such preferential treatment is expressly provided for in the management regulations or the articles of incorporation of the relevant investment fund;

  • regularly monitor compliance with the requirements for achieving these goals.

2. Conflicts of Interest


navAXX SA, in collaboration with the management companies, will take all reasonable measures to identify conflicts of interest.

Potential conflicts of interest arise in the following circumstances, among others:

  • Relationships with issuers or service providers and, if applicable, involvement of employees, managing directors, members of the board of directors in management boards, supervisory or advisory boards of these issuers or service providers;

  • Obtaining information that is not publicly known, as well as personal relationships between employees, management, the board of directors or persons associated with them (including service providers);

  • Relationships with affiliated companies (see appendix);

  • portfolio management and valuation of assets (purchase, sale, valuation);

  • employee transactions;

  • employee benefits;

  • selection of service providers;

  • remuneration policy;

  • Return of Share Certificates.

As the central management company, navAXX SA will implement and maintain effective organizational and administrative arrangements to take appropriate measures to identify, prevent, resolve and monitor conflicts of interest.


These include the following principles and precautions:

  • all decisions are based on reliable data subject to an appropriate level of oversight by management and department heads;

  • the remuneration of all employees is based on the goals associated with the respective employee function;

  • an appropriate review of all processes by the compliance and internal audit functions;

  • potentially conflicting tasks are properly separated;

  • creating areas of confidentiality by erecting information barriers, separation of responsibilities and/or physical separation;

  • regulation of employee transactions;

  • regulations on the acceptance, granting and disclosure of benefits/gifts;

  • registration of memberships and business interests of directors, officers and employees;

  • regular employee training.

In connection with the central administration of investment funds, conflicts of interest can arise in particular between:

  • the management company/central management company and its managers, employees or any other person who is directly or indirectly linked to the management company through a control relationship, and the investment fund managed by it or the investors in this investment fund

  • the investment fund or the investors of this investment fund and another investment fund or the investors of that investment fund;

  • the investment fund or the investors in this investment fund and another client of the management company/central management company;

  • the investment fund or the investors in this investment fund and another investment fund managed by the management company/central management company or the investors in this investment fund; or

  • two clients of the Management Company/Central Management Company.

In order to prevent these potential conflicts from harming the interests of the investment funds and their investors, the compliance officer keeps a register, which every employee can use to report potential conflicts of interest. These are then evaluated and decided on a case-by-case basis by the compliance officer and/or management in coordination with the departments concerned.

If the organizational measures taken by navAXX SA to identify, prevent, resolve and monitor conflicts of interest are not sufficient to reasonably ensure that the risk of prejudice to investors' interests is avoided, navAXX SA will require its clients (i.e. the management companies ) to ensure that they provide investors with clear notice of the general nature or sources of the conflicts of interest and develop appropriate policies and procedures for future management of them.

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