IQEQ FUND MANAGEMENT (LUXEMBOURG) S.A POLICIES

Our policies

IQ EQ Fund Management (Luxembourg) S.A. (“IQ-EQ FM”) is a third party independent management company which is an alternative investment fund manager pursuant to Chapter 2 of the Law dated 12 July 2013 (the “AIFM Law”) on alternative investment fund managers, licensed as fully authorized AIFM by the Commission de Surveillance du Secteur Financier (“CSSF”).

This section provides information regarding the policies of IQ-EQ FM.

Investors in the Funds managed by IQ-EQ FM may request additional information free of charge by writing to AIFM_distribution@iqeq.com.

Voting Rights Policy

IQ EQ FM has established a policy on voting rights, the purpose of which is to lay down the principles guiding IQ-EQ FM in exercising the voting rights attached to securities held in the Fund’s portfolios under its management.

The Voting Rights Policy is intended to meet the requirements of Article 37 of Commission Delegated Regulation (EU) No. 231/2013 of 19 December 2012 supplementing Directive 2011/61/EU of the European Parliament and of the Council on Alternative Investment Fund Managers (the “AIFMD”) with regard to exemptions, general operating conditions, depositaries, leverage, transparency and supervision (the “AIFM Regulation”).

Conflict of Interest Policy

The purpose of the Conflict of Interest Policy is to provide an official document that outlines the procedures for team members when a conflict occurs between their personal interests and the interests of the organization. IQ-EQ FM is committed to maintain and operate effective organizational and administrative arrangements with a view to taking all reasonable steps designed to identify, prevent, manage and monitor conflicts of interest that may arise within IQ-EQ FM and within the Funds and its investors.

IQ-EQ FM adopted the Conflict of Interest Policy which aims to identify, with reference to the activities carried out by the board of directors or in behalf of IQ-EQ FM, including those activities carried out by the delegates, sub-delegates, external valuer and/or counterparty, and to prevent manage and monitor any circumstance that constitutes or may constitute a possible conflict of interest entailing a material risk of damage to the interests of its clients or investors.

An IQ-EQ FM compliance officer is in charge of the tasks better specified in the policy, related to the monitoring of conflicts of interest.

Complaints Handling Policy

The Complaints Handling Policy sets out the legal & regulatory requirements, as well as the related actions, which IQ-EQ FM complies with in order to meet its obligations in the area of complaints’ handling in accordance with the following objectives, laws and regulations:

Address the client’s issues in a prompt, effective and satisfactory manner;
Ensure that systematic and recurring problems are identified and rectified;
Improve the internal system service delivery functions to clients.
Comply with all applicable regulatory obligations provided by the article 15 of the CSSF Regulation 16-07, CSSF Regulation 16-07, CSSF Circular 17/671, as well as align with the requirements set out in CSSF Circular 18/698 Section 5.5.
Privacy Policy

IQ-EQ Group has established a Privacy Policy in order to protect the personal data of its clients, employees, suppliers and other stakeholders in accordance with the requirements of privacy and data protection laws in all relevant jurisdictions, including the European Union General Data Protection Regulation No. 2016/679 of 27 April 2016 (the “GDPR”).

The Privacy Policy also sets out the key principles and requirements to which the IQ-EQ Group must adhere to ensure continued compliance with the privacy legislation applicable from time to time in relation to the collection, use, processing, transfer and destruction of personal data by or on behalf of the Group. The Privacy Policy sets out, and forms part of, the IQ-EQ Group’s wider Data Protection policy and Control Framework and should be read in conjunction with the Group’s other data protection policies, procedures and guidelines.

Remuneration Policy

IQ-EQ FM has established a remuneration policy pursuant to Article 12 of the AIFM Law, which states that an AIFM is required to adopt and implement a remuneration policy in accordance with the provisions of Annex II of the AIFM Law, the AIFMD and of the Guidelines on sound remuneration policies under the AIFMD issued by ESMA on 3 July 2013, as amended (the “ESMA Guidelines”).

The Remuneration Policy sets out principles applicable to the remuneration of persons who are members of the administrative and management bodies of IQ-EQ FM as well as those categories of staff whose professional activities have a material impact on the risk profile of IQ-EQ FM.

IQ-EQ FM has elected to apply the proportionality principle as provided by the guidelines, and the remuneration policy has therefore been designed in a way and to an extent that it is appropriate to its size and internal organization as well as the nature, size, scope and complexity of its activities. The Remuneration Policy includes also measures to avoid conflicts of interest.

Sustainability/ESG Policy

The assessment of Environmental, Social and Governance (ESG) risks and opportunities has become an increasing area of focus for both asset owners and investment managers. There is an increasing recognition that ESG risks and issues can have a material effect on the value of an issuer’s debt or equity and property investments as well.

Sustainability/ESG Policy describes the IQ-EQ FM’s commitment to sustainability, including mitigating environmental impacts, addressing relevant social issues and maintaining sound governance procedures.

The objective of the Sustainability/ESG policy is to affirm the IQ-EQ FM’s commitment to achieving long term sustainable outcomes through our real estate assets, across our supply chain and in the communities in which we operate. The policy describes the overall intentions and direction of IQ-EQ FM related to the Regulation (EU) 2019/2088 (Sustainable Finance Disclosure Regulation – “SFDR”) which provides wider transparency on the degree of sustainability of financial products to challenge private investment towards sustainable investments.