Asset management regulatory framework

Investor Rights Summary

• AAML Summary of Investor Rights FR
• AAML Summary of Investor Rights EN
• AAML Summary of Investor Rights NL

Compliance

On request, Andbank Asset Management Luxembourg can provide you, with the following policies and procedures free of charge. The information on these policies are relevant to AAML:

• Best Execution Policy
• Complaints Handling Policy
• Conflicts of Interest Policy
• Whistleblowing Policy
• Voting Rights Policy
• Top five execution venues 2018
• Top five execution venues 2019
• Top five execution venues 2020
• Top five execution venues 2021
• Top five execution venues 2022
• Top five execution venues 2023
• Top five execution venues 2024
• Personal Data Protection Notice – AAML
• Videosurveillance notice EN – AAML

SFDR, Governance and remuneration policies

• Remuneration Policy
• Sustainability Risk Policy
• SFDR Article 3
• SFDR Article 5 Remuneration Disclosure
• SFDR Article 10

Statement on Principal Adverse Impacts (PAI) – Article 4 SFDR:

* In accordance with Article 4(1)(b) of Regulation (EU) 2019/2088 (“SFDR”), AAML does not currently consider the principal adverse impacts of its investment decisions on sustainability factors at entity level.

* This approach is based on the nature, scale and range of the financial products managed by AAML, the fact that AAML employs fewer than 500 employees, and the current limitations regarding the availability and reliability of sustainability data.

* While certain funds managed by AAML may consider principal adverse impacts at product level in line with their specific investment policies and disclosure obligations, this does not apply to the assessment of principal adverse impacts at entity level.

* AAML may review this position in the future as regulatory requirements evolve and data availability and quality improve.

* Notwithstanding the above, sustainability risks are integrated into the investment decision-making process in accordance with Article 6 of the SFDR, as further described in the relevant pre-contractual disclosures.