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Our Policies

Our policies cover the following areas: 

Protecting the interests of investors is our top priority at FERI Trust (Luxembourg) S.A. (headquartered in Luxemburg) as well as FERI Trust (Luxembourg) S.A. – Niederlassung Deutschland (jointly "company").  The exercise of voting rights at general meetings is of particular importance in this context.

In principle, the company does not seek to exercise voting rights. In any case, the maximum percentage share of an asset permissible in law and the duty to diversify (Articles 43-48 of the Law of 17th December 2010) mean that it is generally not possible to obtain voting rights with any degree of influence. Nevertheless, the principles set out below provide guidelines according to which the company exercises voting rights at general meetings – either directly or indirectly – in the interests of investors.

  • If a fund managed by the company holds voting rights, these voting rights are exercised on the basis of the partnership agreement and the investment conditions of the fund.
  • The company exercises voting rights either directly itself or delegates these by proxy to a third party, usually investment managers, investment advisors or mandated lawyers. In doing so, we always issue instructions beforehand.
  • Voting rights are principally exercised for the benefit of the investors and are independent of the interests of third parties.
  • The exercise of voting rights is subject to the condition that it involves an effort that the company deems appropriate at its discretion.
  • Votes, proxies, instructions issued and various other documents are archived.
  • If required, an agreement with the custodian bank may be reached with regard to the blocking of voting rights, for example on the day of a general meeting.
  • In the case of routine decisions which generally have no long-term impact, our vote will normally be cast in favour of any motion proposed by the management.
  • In the case of decisions that have a major impact (e.g. mergers and acquisitions, restructurings, spin-offs, changes to capital structure and voting rights), we will generally request the investment manager/investment advisor to supply us with detailed information for our consideration.
  • In the case of contentious decisions, we will refrain from liquidating securities in order to gain possession of a larger voting share.
- In the event of a conflict between the English and German versions of this guideline, the German version will prevail. -

FERI Trust (Luxembourg) S.A. (headquartered in Luxembourg) as well as  FERI Trust (Luxembourg) S.A. - Niederlassung Deutschland and their employees are obliged to provide all services in the best interest of investors/clients and to avoid conflicts of interest as far as possible.

Should you nonetheless have cause for complaint, please inform us of your concerns.

FERI Trust (Luxembourg) S.A.
- Beschwerdestelle -
18, boulevard de la Foire
L-1528 Luxembourg
Grand Duchy of Luxembourg
Phone: +352 270448-721
E-Mail: info@feri.lu

You will immediately be sent an acknowledgement of receipt and will receive an initial response to your complaint in no more than seven working days stating how we intend to proceed and how long it should take.

If you are dissatisfied with our response, you may wish to either approach the member of the Management Board of FERI Trust (Luxembourg) S.A. responsible for complaints, Mr. Thomas Zimmer, or make use of the procedures for the out-of-court settlement of complaints provided by the CSSF under CSSF Regulation No 16-07. Contact may be made either by post (Commission de Surveillance du Secteur Financier, Département Juridique CC, 283, route d’Arlon, L-2991 Luxembourg), via fax at +352 26251-2601, via email to reclamation@cssf.lu or via the form provided on the CSSF's website at http://www.cssf.lu/en/consumer/complaints/.

In order for us to be able to contact you about your concerns, please inform us of your preferred method of contact (letter, fax, phone, e-mail) and supply us with your contact details.

1. Introduction and Scope

FERI Trust (Luxembourg) S.A. (headquartered in Luxembourg) as well as FERI Trust (Luxembourg) S.A. – Niederlassung Deutschland (jointly hereinafter referred to as ‘FTL’) is committed to avoiding any conflict of interest that might arise within the meaning of

  • Article 109 Section 1b) and Article 111 Section d) of the law of December 17th 2010 on the organisms of shared assets, further regulated by CSSF Regulation 10-04 in reference to UCITS funds;
  • Article 13 of the law of July 12th 2013 on the managers of alternative investment funds, and of Section 2 of Level 2 AIFM DVO to Article 14 of the AIFM Directive in connection with the management of investment funds or alternative investment funds, further regulated in CSSF Regulation 12-01 with reference to alternative investment funds;
  • of § 27 of the German Capital Investment Code (KAGB), insofar as they relate to the activities of a branch office located in Germany in the management of alternative investment funds;

the types of funds mentioned in the preceding indents are both hereinafter referred to as "funds", 

  • of Article 7 to of the law of 15th 2004 on venture capital companies (SICAR) (organisational structures and requirements) in conjunction with CSSF Regulation No 15-08.

concerning the venture capital companies (SICAR) in which the FTL participates, which for the sake of editorial simplification are also referred to as funds below. 

Conflicts of interest arise when several persons have an interest in the legitimate realisation of certain business opportunities, or the business opportunity of one person is dependent on the specific decision of another person. Insofar as it is not possible to avoid conflicts of interest, FTL conducts its business in a manner that ensures the proper management of conflicts of interest.

FTL will make organisational arrangements and take administrative steps to implement all measures necessary to identify, prevent, resolve and monitor conflicts of interest. To this end, the FTL Board has adopted these guidelines which specify the detailed requirements.

These guidelines apply to all departments and employees of FTL, to their clients and to funds managed by FTL, as well as to Relevant Persons within the meaning of the following definitions. In such cases where activities are outsourced, FTL will ensure that appropriate arrangements are put in place by the service provider. Compliance with applicable laws in connection with policies, prohibitions and obligations arising from this FTL guideline shall be binding for all employees and relevant persons.

This policy on conflict of interest is an integral part of the comprehensive compliance management of FTL.

2. Definitions

2.1. Investors, Clients, Relevant Persons

‘Investors’ within the meaning of the policy on conflict of interest are:

  1. Investors who have subscribed to a fund managed by FTL;
  2. Investors who have subscribed to a different fund not managed by FTL;

‘Clients’ for the purposes of this policy are all clients of FTL.

‘Relevant Persons’ are members of the FTL Board and all staff of FTL or of any outsourcing company appointed by FTL, as well as any other natural or legal person who, under an agreement for the transfer of responsibilities to third parties, is directly involved in the provision of services which enable FTL to manage funds.

2.2.  Conflicts of Interest within the Meaning of this Policy

This policy on conflicts of interest applies to all conflicts of interest that may result in a risk of damage or loss to the investors in a fund managed by the FTL. Such conflicts of interest may arise in connection with the management of funds in the following combinations or legal relationships:

  • the management company, together with its officers, employees or any other person who is connected directly or indirectly with the management company by a controlling role and the funds it manages or the investors in these funds;
  • the fund or the investors in these funds and any other fund or the investors in that fund;
  • the fund or the investors in these funds and another client of the management company;
  • the fund or the investors in these funds and a fund managed by the fund management company or the investors in this fund or
  • two clients of the management company.

3. Managing Conflicts of Interest 

3.1. Situations Involving Conflict of Interest

A conflict of interest for FTL or for an external provider working on its behalf and/or a Relevant Person in the management of the Fund is particularly indicated if the following circumstances arise with regard to FTL and/or a Relevant Person:

  • obtaining a financial advantage for FTL, for an external provider working on its behalf or for a Relevant Person at the expense of the fund or its investors;
  • interest in the result of a service provided for the fund by FTL, by an external provider working on its behalf or a by Relevant Person, which does not correspond to the interests of the investors in the fund managed by FTL;
  • avoidance of a financial loss for FTL, for an external provider working on its behalf or for a Relevant Person to the detriment of the fund or its investors;
  • the interests of FTL, of an external provider working on its behalf or of a Relevant Person in the service provided to the fund are (except for remuneration) not congruent with the interests of the fund;
  • favouring the interests of an individual investor, of a group of investors or of other funds to the detriment of the fund managed by FTL;
  • simultaneous performance of identical work for more than one fund;
  • existence of a financial or other incentive to favour the interests of one fund over the interests of another that is also managed by FTL;
  • receipt of remuneration from a third person in the context of fund management.

3.2.  Preventing Conflicts of Interest

To prevent the possibility of conflicts of interest, FTL or an external provider working on its behalf or a Relevant Person must undertake to comply with the highest standards. These include acting in a lawful and professional manner at all times as well as upholding general market rules, whereby the interests of investors are always taken into account. Appropriate organisational arrangements and administrative measures to avoid conflicts of interest are to be put in place, applying the principle of proportionality in relation to the size and structure of FTL and the nature, scope and complexity of its business.

Precautionary measures to be taken for the prevention of conflicts of interest must be reasonable and effective. In particular, steps must be taken to ensure that any persons concerned are familiar with and adept in any procedures that are necessary for the proper discharge of their duties. For this purpose, process descriptions and work instructions are to be drawn up and training carried out. In this context, documentation must be kept, describing functions, reporting and responsibilities.

3.3.  Organisational Arrangements

To avoid conflicts of interest, steps must be taken to ensure that FTL or an external provider working on its behalf, a Relevant Person or an employee authorised by FTL conduct their activities independently and are mindful of potential risks to the fund and its investors and to clients. To ensure the independence of FTL and of Relevant Persons, the following organisational precautions were put in place:

  • FTL and/or an external provider working on its behalf are to conduct their business activities independently of the interests of third parties.
  • There is to be functional and spatial separation of different business areas, in particular between fund management on the one hand and compliance, control systems and risk management on the other, and separation of duties and responsibilities in relation to its own operations which are deemed to be incompatible with each other or have the potential to cause systematic conflicts of interest.
  • Remuneration due to an employee is to be determined in accordance with the regulatory requirements in such a way that Relevant Persons see their incentive in the performance of all funds managed by them, thus obviating any preference for individual funds or clients.
  • As and when appropriate, areas of confidentiality are to be defined and barriers put in place – either virtual or physical (so-called ‘Chinese Walls’) – to restrict the flow of information.
  • A policy on personal transactions is to be implemented.
  • Likewise a policy on employee payments and other benefits acquired from FTL, its employees or Relevant Persons.
  • Senior staff at FTL are obliged to complete a questionnaire on potential conflicts of interest whenever a new fund is set up.
  • Steps are to be taken to prevent or restrict an unwarranted influence on the activity of a Relevant Person.

3.4. Adminstrative Measures

To avoid conflicts of interest, the Executive Board of FTL and/or an external provider working on its behalf has taken the following administrative measures with regard to monitoring and training for Relevant Persons and staff acting for FTL:

  • Processes and measures have been implemented for monitoring whether the employees of FTL comply with the code of conduct and procedures for dealing with conflicts of interest.
  • Within the individual departments and between departments, there are certain processes for resolving conflicts of interest in force that must be strictly adhered to when a conflict of interest has been identified.
  • Appropriate documentation of the services and activities of FTL, its Board of Directors, staff and Relevant Persons is to be made in those cases where a conflict of interest has been identified.
  • In the case of investment opportunities which come under consideration for multiple funds pursuing the same investment strategy, FTL will offer the investment opportunity in compliance with the principle of equal treatment to all eligible funds it manages under the same conditions and, in the case of investment interest from several of its managed funds, will divide up the investment opportunity between the funds having an interest or, if the opportunity cannot be divided, will apply an appropriate allocation method (rotation or random procedure), also ensuring that documentation of such is in place.
  • To the extent required by an appropriate resolution or observation of a conflict of interest, Relevant Persons and FTL employees may be asked to cease working on a specific business activity or participating in its management in order to resolve a potential conflict of interest.
  • Regular training is provided for all affected employees at FTL and/or certification of training having been carried out at an external provider working on its behalf or of Relevant Persons at FTL. 

4.   Dealing with Conflicts of Interest

4.1.  Officer Responsible for Avoiding Conflicts of Interest

The Executive Board of FTL has appointed one person to oversee the prevention of conflicts of interest (hereinafter ‘Conflict of Interest Officer’). The person appointed is the Compliance Officer. The Conflict of Interest Officer is responsible for the ongoing investigation, prevention, resolution and/or the management and monitoring of conflicts of interest.

The Conflict of Interest Officer reports directly to the Board on a regular basis concerning the performance of his/her duties.

It is the responsibility of the Conflict of Interest Officer to ensure that the parties affected by FTL conflict of interest management are always informed about and receive regular training on these guidelines.

Furthermore, it is his/her responsibility to monitor compliance with these conflict of interest management guidelines on a regular basis.

If a conflict of interest has been identified, the Conflict of Interest Officer shall inform the FTL Board of the nature and extent of the conflict of interest and document this accordingly.

4.2.  Resolving und Monitoring Conflicts of Interest

If a conflict of interest has been identified, as defined by the conflict of interest management guidelines, this is to be dealt with immediately and in an equitable manner.

The assessment of a potential conflict of interest is a two-step process: stage one is managed by the Conflict of Interest Officer; if the issue cannot be resolved, it is escalated to stage two, at which point the FTL Board or its Board of Supervisors become involved.

If it should become apparent during an attempt to resolve a conflict of interest that existing and ongoing measures are not appropriate or sufficient, additional measures must be taken, such as:

  • thorough examination of all available measures by the relevant Board and implementation of fund-specific information restrictions or other additional measures for separating information;
  • resolution of the conflict of interest by transferring conflict of interest management to a higher management level which is responsible for the business strategy of FTL and is able to assess the potential risks correctly;
  • termination of the business activity.

4.3.  Disclosing Conflicts of Interest

FTL is obliged to inform investors of conflicts of interest as soon as it becomes apparent that the organisational measures taken by FTL to identify, prevent, resolve and monitor conflicts of interest are not sufficient to ensure with reasonable confidence that any risk of damage or loss to the interests of investors and/or managed funds has been avoided. The rules on disclosure also apply to potential conflicts of interest that may arise in connection with the delegation/outsourcing or sub-delegation of two specific business areas, namely Portfolio and/or Risk Management. Furthermore, disclosure must be made of any transactions conducted by employees and Relevant Persons in connection with the managed funds.

The duty to disclose non-resolvable conflicts of interest at FTL includes informing investors prior to the execution of the relevant businesses measure about the general nature and the sources of conflicts of interest and developing appropriate strategies and procedures.

Disclosure of potential or actual conflicts of interest may be made by means of a durable medium or, for example, publication on the website of FTL.

Insofar as disclosure of conflicts of interest is effected on the FTL website, FTL is to ensure the implementation and application of the following measures:

  • The address of the website is to be made known to investors.
  • Information posted on the website is to be updated on a regular basis.
- In the event of a conflict between the English and German versions of this guideline, the German version will prevail. -

In accordance with applicable law and regulations by authorities FERI Trust (Luxembourg) S.A. („FERI Trust“) has defined remuneration guidelines applicable to their staff members.

The remuneration system has to be in line with the business strategy, the objectives and values as well as the long-term interests of FERI Trust and the investment funds administrated. It has as well to be in line with the risks that can be taken by the investment funds (compliance of risk profiles with regulation of the funds) and with the principle of protecting clients and investors by executing the service. The remuneration system is consistent with a solid and effective risk management, it should not generate any incentives to take immoderate risks and respects to avoid potential conflicts of interest.

The remuneration of the members of staff and the bodies consists in general a fix (incl. possible monetary and non-monetary Benefits) and a variable component. The allocation of the fix component is oriented on market standards and has to be a sufficient remuneration for the members of staff and the bodies, this to exclude a significant dependence from variable components.

 The variable remuneration is based especially by the following factors:

  • Success of the company
  • Performance of the person
  • Qualification, experience and capability of the person
  • Kind and coverage of the work assigned 
  • Success of a certain investment (in case of a carried interest)
  • Success of a Fund (in case of a carried interest). 

The variable remuneration of specific categories of members of staff (e.g. board members, risk taker, control function, staff members with salary equivalent to board members as well as staff members with significant influence on riks profiles of FERI Trust or the administrated investment funds) is orientated on long-term performances.

The remuneration system will be set in place by the board of directors after having passed the remuneration committee. The supervisory board acts as well as remuneration committee and will do an annual review of the remuneration system. 

- In the event of a conflict between the English and German versions of this guideline, the German version will prevail. -

Herewith we inform you about the processing of your personal data through FERI Trust (Luxembourg) S.A. and about your rights regarding the data protection law.

The English version is a translation of the original in German for information purposes only. In case of a discrepancy, the German original will prevail.

Responsible Person of Data Processing

Responsible for the data processing:

FERI Trust (Luxembourg) S.A.
18, Bd. de la Foire, L-1528 Luxembourg
Phone: +352 270448-0 / Fax: +352 270448-729 / e-Mail: info@feri.lu

Data Protection Officer

You can contact the data protection officer of FERI Trust (Luxembourg) S.A. under this e-Mail: datenschutz@feri.lu.

Legal Bases, Sources and Purpose of the Data Processing

We are processing your personal data because of the data protection regulations especially based on the EU General Data Protection Regulation (GDPR) and on other relevant national laws.

We are processing these personal data, which we get from business relationships with our customers, business associates and interested parties. Furthermore, we are processing, if necessary for our service, personal data which we get, permitted by law, from public sources (e.g. commercial register, register of associations, press and internet) or which we get from other companies of the FERI-Group, MLP-Group or other third parties.

Relevant personal data are personal details (name, address, other contact data, birthday, birthplace and citizenship), legitimation data (e.g. passport data) and authentication data (e.g. specimen signature). Furthermore, these data could include order data (e.g. bank details for payment orders), data from our contractual fulfillments (e.g. sales data of transactions), information about your financial situation (e.g. creditworthiness data, scoring/rating data, source of financial assets), commercial and distribution data, documentary data (e.g. suitable standardized declaration) and other data comparable to these categories.

Reasons for the Processing of Personal Data:

a. To Fulfill Our Contracts (art. 6 para. 1 b GDPR)
To make business as a fund management company, the processing of data is necessary to fulfill our contracts with our clients and business partner or to perform precontractual appropriate measures which are performed on request.

The purpose of the data processing is about the specific product (e.g. about the specific investment fund) and could also include consultation and a provision of transactions.

b. Within the Scope of the Balancing of Interest (art. 6 para. 1 f GDPR)
If necessary we are processing your data on top of the contractual fulfillments to balance the justified interests of us or of third parties.

Examples:

  • Measures of business management and further development
  • Within the scope of services and products
  • Risk management
  • Analysis and optimization of processes for needs analysis for the purpose of the direct approach of clients
  • Advertising or market and opinion research unless you have objected to the use of your data
  • Assertion of statutory claims und defense
  • Within the scope of legal disputes
  • Ensuring IT security and IT Operation

c. Due to Your Approval (art. 6 para. 1 a GDPR)
As soon as you gave us your approval to proceed with your personal data for specific reasons (e.g. to give data to others in the concern, e-mail contact data for marketing reasons) the data proceeding is legal for us. Notice that this approval can be revoked anytime.

d. On the Basis of Statutory Regulations (art. 6 para. 1 c GDPR) or in the Public Interest (art. 6 para. 1 e GDPR)
Moreover, we, as a fund management company, are subject to various legal obligations, i.e. statutory requirements (such as the Law on Money Laundering or tax laws) and regulations relating to the supervision of banking (e.g. of the banking supervision of Luxembourg). The purposes of processing include, among others, the assessment of creditworthiness, checking identity and age, prevention of fraud and money laundering, compliance with obligations of control and reporting under tax law and the assessment and management of risks.

Obligation to Provide Data

Within the scope of our business relationship, you are obliged to provide those personal data which are required for commencing, executing and terminating a business relationship and for compliance with the associated contractual obligations or the collection of which is imposed upon us by law. Without these data, we will generally not be able to enter into agreements with you, to perform under such an agreement or to terminate it. Under the statutory regulations in connection with money laundering, we are especially obliged to identify you by an ID document before entering into business relations with you and, especially, to ask for and record your name, place of birth, date of birth, nationality, address and identity card details. So as to enable us to comply with these statutory obligations, you are obliged to provide the necessary information and documents in connection with the anti-money laundering law and to report any changes that may occur in the course of our business relationship. If you should fail to provide the necessary information and documents, we are not permitted to enter into the desired business relationship or to continue with such a relationship.

Categories of Recipients of the Personal Data

Within the FERI-Group and MLP-Group, those units will be granted access to your data that need them in order to comply with our contractual and statutory obligations. Service providers and agents appointed by us may also receive the data for these purposes on the condition that they, specifically, observe banking secrecy. These are companies in the categories funds administration, IT services, telecommunication as well as sales and marketing.

As far as passing on data to recipients outside our company is concerned, it must first be kept in mind that we, as a fund management company are obliged to keep all client-related facts and assessments we become aware of in strict confidence.

As a matter of principle, we may pass on information about our clients only if this is required by law or the client has given his consent. Under these circumstances, recipients of personal data may, for example, be:

  • Public authorities and institutions (such as the European Banking Supervisory Agency, the Federal Agency for the Supervision of Financial Services or authorities prosecuting criminal acts) provided a statutory obligation or an official decree is in place.
  • Other loan and financial services institutes or comparable institutes to whom we transmit your personal data for the purpose of performing transactions under our business relationship (depending on the agreement, for example, correspondent banks, depositary banks or stock exchanges).

If we do a data transfer to bodies in states outside the European Economic Area (EEA) the data transfer will only take place if the EU Commission guarantee that this third country has an adequate level of data protection or other data protection guarantees are existing in this country (e.g. binding intra-corporate data protection provisions or EU standard contractual clauses).

Data transfer to bodies in states outside the European Union (so-called third countries) will take place to the extent

  • this is required to carry out your services (such as payment or securities orders),
  • it is required by law (such as obligatory reporting under tax law) or
  • you gave us your consent.

Storage Period of the Data

We store your personal data as long as this is required to meet our contractual and statutory obligations. Another storage time could be existing due to legal burden of proof and retention obligation which are regulated by law (e.g. code of commercial law). The storage periods are up to ten years. Other storage periods could exist due to national legal limitation periods which are three or up to thirty years.

Rights of the Persons Affected

Every data subject has the right to get access of the personal data pursuant to Article 15 GDPR.

Furthermore, you have the right to rectification your personal data pursuant to Article 16 GDPR and the right to erase your personal data pursuant to Article 17 GDPR under specific circumstances e.g.:

  • If your personal data are no longer needed for the purpose they were collected,
  • If you revoke your approval and there is no other legal base,
  • If you revoke the processing and there are no legitimate reasons for a processing,
  • If your personal data where processed not legally or
  • If your personal data must be erased to fit into legal requirements

Please notice that a claim of erase is regarding to a legitimate reason which might makes the processing of data necessary.

Furthermore, you have the right of a restriction of your data processing pursuant Article 18 GDPR, e.g.:

  • If you say that your personal data is not right and we had the opportunity to confirm your data,
  • If the processing is not legal and you want a restriction of your data processing instead of an erase,
  • If we do not need your data anymore, but we need them for assertion or defence of legal claims or
  • If you revoked and it is not clear yet, if your interests prevail

If we process your data due to statistical reasons, you can revoke these processing due to reasons which are regarding to your special situation pursuant Article 21 para. 6 GDPR.

Furthermore, it is possible that you have got the right to get your supplied data on a structured, established and machine-readable format.

In some cases, it might also possible that you are not satisfied with our respond regarding to your request. If this is the case, it is your right to complain at the data protection officer and at the responsible regulatory agency.

Right of Appeal

If you have any questions or a complaint you can contact our data protection officer. You may also contact the responsible regulatory agency in Luxembourg:

Commission nationale pour la protection des données
Service des plaintes
1, avenue du Rock’n’Roll
L-4361 Esch-sur-Alzette

Right to Object Based on Individual Case

You have the right to object, on grounds relating to your particular situation, at any time to the processing of personal data.

If you do object, we will no longer process your personal data unless we have compelling justified reasons for such processing which take precedence over your interests, rights and freedom or, alternatively, such processing serves to assert, exercise or defend legal claims. You can send your contradiction to:

FERI Trust (Luxembourg) S.A.
Data protection officer
18. Bd. de la Foire , L-1528 Luxembourg

1. Essentials

According to the guidelines of Directive 2004/39/EC ("MiFID") dated 21.04.2004, Article 28 of CSSF Regulation No. 10-4 dated 22.12.2010 and Article 27 of Delegated Regulation (EU) No. 231/2013 dated 19.12.2012, management companies and managers of alternative investment funds ("AIFM") are obliged to draw up a Best Execution Policy ("Policy") in order to achieve the best possible trading results for their clients. Furthermore, with consideration of "Directive" 2014/65/EU regarding "Markets in Financial Instruments" dated 15.05.2014 ("MiFID II") and "Regulation" (EU) No 600/2014 regarding "Markets in Financial Instruments" dated 15.05.2014 ("MiFIR"), since 03.01.2018 there has been an obligation to take certain regulations regarding "Best Execution" in consideration. Due to its business orientation, the company is not primarily affected by MiFID II / MiFIR. In order to document the procedures that have already been practiced, the company would nevertheless like to have a "Best Execution Policy”, which, however, can only have the character of a basic process description/documentation.

2. Outsourcing Concept

FERI Trust (Luxembourg) S.A. (headquartered in Luxembourg) including FERI Trust (Luxembourg) S.A. – Niederlassung Deutschland (jointly"Company" or "FTL") manages undertakings for collective investment in transferable securities ("OGAW" or "UCITS") and alternative investment funds ("AIF"). As part of its strategic business organization, the Company has decided not to provide all management services itself but, for reasons of efficiency, to outsource certain business areas to highly specialized service providers. The aim is always to provide investors with the highest level of expertise and flexibility.

(1) Portfolio management is outsourced for all UCITS and some AIFs. In this context, orders are placed with the portfolio manager. In this case the traded assets are mostly represented on regulated markets by securities.

As part of the initial due diligence, portfolio managers are reviewed to see whether they are authorized to carry out the sourced activities and have appropriate regulatory prerequisites such as their own execution principles for executing orders in financial instruments with professional clients ("Best Execution Policy").

In addition, the existence of current execution principles is regularly reviewed as part of the ongoing due diligence of service providers in the role of portfolio managers.

(2) For certain AIFs, FTL performs the role of portfolio manager itself. These AIFs are funds that invest almost exclusively in private equity-, real estate- and hedge fund- target funds. These target funds are not traded on a regulated trading market but canonly be ordered at an unknown price (next NAV) or acquired via commitments. Therefore, there are no comparative prices on different trading venues.

3. FTL in the Role of Portfolio Manager

For certain AIF, FTL, as an authorized AIFM, performs the role of portfolio manager. As mentioned above, the AIFs are funds that directly invest in Private Equity Assets or Real Estate Assets ("direct assets") or in private equity-, real estate- or hedge fund target funds ("target funds"). In principle, these directs assets and target funds are not traded on a regulated trading market but can only be ordered at an unknown price (next NAV) or acquired through commitments. Comparative prices do therefore not exist at different trading venues.

Investment decisions for direct assets and target funds are made in the context of an extensive due diligence process that often takes the time of several weeks or - if neccessary - months. The main economic, regulatory, tax and contractual conditions and documents are examined together with external partners such as tax advisors, auditors, lawyers, etc. During the negotiation of contracts and at the end of the process these negotiations can result in individual agreements which are reflected, for example, in subscription documents, partnership agreements and/or side letters.

Investment decisions for individual target hedge funds are made by FTL after completion of an extensive due diligence process. This process extends over several weeks or months for each target fund. The relevant target hedge funds are usually so-called offshore funds. Often these feeder funds are domiciled on the Cayman Islands, which themselves invest in local master funds. Among other investors, US Institutional investors could also invest their capital in these master funds.

Due to the breadth of the investment universe, FTL relies on the support of external service providers. During the investment process, the essential investment strategic, economic, regulatory, contractual and, if applicable, tax law conditions and documents are examined by external partners, in particular the investment advisor, the depositary of the AIF and, if necessary, also by tax advisors or lawyers.

A best execution policy in the classical sense of regulated trading markets is not applicable to this type of investment.

4. Final Provisions

This Best Execution Policy of FTL must be reviewed regularly and adjusted accordingly in the event of changes to the basic facts described in sections 2 and 3. As part of the outsourcing controlling (Section 2 (1)), the existence of a current Best Execution Policy at the relevant service providers is monitored.

- In the event of a conflict between the English and German versions of this guideline, the German version will prevail. -
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FERI Trust (Luxembourg) S.A.

T +352 270448-0
F +352 270448-729
info@feri.lu


18, Boulevard de la Foire
L-1528 Luxembourg

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FERI Trust (Luxembourg) S.A.

T +352 270448-0
F +352 270448-729
info@feri.lu


18, Boulevard de la Foire
L-1528 Luxembourg

Contact

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