Legal and regulatory information


"The following pages contain information concerning investment funds registered with the Commission de Surveillance du Secteur Financier (CSSF) or registered in other jurisdictions.

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Strategy for exercising voting rights

Regulatory framework :

In accordance with Article 23 of Rule n° 10-4 of the CSSF (Luxembourg Financial Sector Supervisory Commission), Kaltchuga Capital Management S.A.'s Strategy for exercising voting rights ("the Strategy") is stated in this document. The Strategy applies to the OPCVM (mutual funds) and other investment vehicles (the "funds") managed by Kaltchuga Capital Management S.A. and sets down the application principles that it has adopted.

Principle for determining whether to exercise voting rights and attend Shareholders' Meetings :

Given the relatively small size of assets under management, the specific markets on which the funds are invested, and the burden and cost of the procedures involved, the principle adopted is not to vote.

However, in the event that the funds own more than 3% of the voting rights of any one company, the management team will pay special attention to the resolutions submitted at Shareholders' Meetings. For such companies, the management team will determine if there is any concrete risk that could undermine the company's strategy, such as a change in management, change in shareholders, merger, takeover or restructuring.

The management team will then decide whether it is necessary to attend the Shareholders' Meeting and vote on behalf of the funds represented.

Policy adopted for exercising voting rights and/or attending Shareholders' Meetings :

Regardless of the decisions made, the management team will endeavour to protect and promote exclusively the interests of the shareholders of the funds represented. In its actions and decisions, it will promote: (i) the rights and equitable treatment of shareholders; (ii) the implemention of effective corporate governance; and (iii) transparency in disclosures.

Preventing and managing conflicts of interest when exercising voting rights :

The code of conduct and the policy for managing conflicts, which are applicable to all employees, define the cases in which a conflict-of-interest situation could arise.

Moreover, based on the above-stated principles, the company only rarely exercises voting rights and attends shareholders' meeting. The risk of a conflict of interests therefore looks limited.

Investor information :

In addition, each investor may, on request, obtain detailed information on the measures taken on the voting rights Strategy of the fund in which he has invested, either by mail (Kaltchuga Capital Management S.A; 8 Avenue Marie-Thérèse L-2132 Luxembourg) or email at

Best selection and best execution policies for orders routed to selected brokers

Best Selection policy

As a money management firm, Kaltchuga Capital Management S.A. (hereinafter: "KCM") must act in the best interests of the OPCVM (mutual funds) and other investment vehicles that it manages (hereinafter: the "Funds").

In accordance with Rule N°10-4 of the CSSF (Luxembourg Financial Sector Supervisory Commission), KCM is required to take all reasonable measures to obtain the best possible result for its Funds when transmitting and executing orders resulting from its decisions to trade financial instruments on behalf of its Funds.

As part of its activities, KCM is required in particular to select those intermediaries whose execution policies make it possible to ensure the best result possible in executing orders sent to it on behalf of its Funds. The broker selection pool is nonetheless limited by the geographical specificities of KCM's management practices.

With this in mind, KCM has taken a multi-criteria approach to selecting its brokers. These criteria are both quantitative and qualitative and include broker availability and responsiveness, financial resources and solidity, speed, quality of order processing and execution, as well as intermediation costs. Each analysis criterion is rated individually, and cumulative ratings are assigned to each broker.

This review process is updated once per year.

Best Execution policy

The Best Execution Policy aims to select the execution venues and methodology that produce the best possible result in executing orders, based on the following factors :

  • costs of trading the financial instrument,
  • transaction cost,
  • execution speed,
  • probability of order execution and settlement,
  • order size,
  • type of order.

KCM takes into account the following criteria to determine the relative importance of the above-mentioned factors :

  • fund characteristics,
  • characteristics of the order concerned,
  • characteristics of the financial instruments covered by the order,
  • characteristics of the execution venues to which the order may be sent.

KCM places no orders, and will place no order, for its own account. KCM may pool orders for its Funds, as long as, when placing the orders, it has determined that the impact will be positive both on the whole and individually for the funds concerned. Both pooled and non-pooled orders are pre-allocated to the fund(s) concerned at the time the orders are placed with the selected broker. Post-execution order breakdown and allocation follows the pre-set allocation. In the event of partial execution of an order and depending on the level of execution, the order will either be allocated to the funds on a prorated basis or, if the level of execution is not sufficient, to one of the funds concerned. Partially executed orders will be submitted to the Compliance Officer for review.