Credit Suisse Regulatory Information

Financial markets are closely regulated to ensure they function efficiently and effectively. Governments and regulatory authorities around the globe have proposed and enacted numerous reforms to help create a more robust financial system.

Shareholder rights

Shareholder rights: transparency statement, engagement policy and voting rights

Credit Suisse Asset Management ensures that investee companies follow good governance practices engaging with companies and by exercising voting rights.

Further information:

Sustainable Investing

Regulatory disclosures relating to sustainable investing of Credit Suisse Fund Management S.A. (hereinafter referred to as “CSFM”)

Please note that details on the CSAM Sustainable Investing Policy and Regulatory Methodologies and Standards can be found here.

Regulatory disclosures relating to sustainable investing of Credit Suisse Fund Management S.A. (hereinafter referred to as “CSFM”)
Please note that details on the CSAM Sustainable Investing Policy and Regulatory Methodologies and Standards can be found here.

Transparency of sustainability risk policies

Pursuant to EU Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability-related disclosures in the financial services sector (the “SFDR”) Article 3, financial market participants shall publish on their websites information about their policies on the integration of sustainability risks in their investment decision‐making process.

Sustainability risk is defined as an environmental, social, or governance event or condition that, if it occurs, could have a material negative impact on the value of investments. The materiality of sustainability risks is determined by the likelihood, magnitude, and time horizon of the risk materializing. Sustainability risks can be understood as a subcategory of traditional risk types (e.g. credit, market, liquidity, operational, and strategy risk) and are identified and managed in the context of risk-management processes. Since sustainability risks differ between asset classes and investment styles, they are defined at the portfolio level.

In addition to the risk-management processes, Credit Suisse Asset Management has established a Sustainable Investing Policy that specifies for investment funds following a sustainable investing strategy, how to integrate ESG factors into the investment process in order to identify sustainability-related opportunities and to reduce sustainability risks further.

No consideration of adverse impacts of investment decisions on sustainability factors at legal entity level within the meaning of Article 4 of the Sustainable Finance Disclosure Regulation of the European Union (EU) 2019/2088.

Credit Suisse Fund Management S.A. (CSFM)  does not consider adverse impacts of investment decisions on sustainability factors (“PAI”) at legal entity level within the meaning of Article 4 of the Sustainable Finance Disclosure Regulation of the European Union (EU) 2019/2088.

CSFM has outsourced the portfolio management for its investment funds within UBS group. The portfolio managers make investment decisions within the framework of the contractual agreements.

Therefore, CSFM does not consider adverse impacts of investment decisions on sustainability factors (“PAI”) at legal entity level within the meaning of Article 4 of the Sustainable Finance Disclosure Regulation of the European Union (EU) 2019/2088. However, the appointed portfolio managers may consider PAI for certain investment funds as outlined in the applicable product documentation.

CSFM intends to keep this position under review and may reassess it in the context of the migration with UBS.

Transparency of remuneration policies in relation to the integration of sustainability risks

Pursuant to SFDR Article 5, financial market participants shall include in their remuneration policies information on how those policies are consistent with the integration of sustainability risks, and shall publish that information on their websites.

Credit Suisse has a Group-wide compensation policy in accordance with the SFDR’s requirements, which also applies to CSFM.

Review of disclosures

SFDR Article 12 requires financial market participants to ensure that any information published in accordance with Article 3, 5, or 10 is kept up to date. Where a financial market participant amends such information, a clear explanation of such an amendment shall be published on the same website.

The following table explains the amendments on disclosures related to SFDR Articles 3 and 5. Information regarding Art. 10 is available on ubs.com/funds.

Table of revisions

Date

Date

Article

Article

Explanation of amendments

Explanation of amendments

Date

23.02.2023

Article

All

Explanation of amendments

Specification that the disclosures apply to CSFM

Date

01.01.2023

Article

4

Explanation of amendments

No consideration of adverse impacts according to SFDR Art. 4.

Date

10.03.2021

Article

All

Explanation of amendments

Disclosures according to SFDR Level 1 requirements

Investor rights

Summary of Investor Rights for EEA domiciled funds

This statement is a summary of investor rights prepared in relation to Regulation (EU) 2019/1156 of the European Parliament and of the Council of June 20, 2019 on facilitating cross-border distribution of collective investment undertakings and amending Regulations (EU) No 345/2013, (EU) No 346/2013 and (EU) No 1286/2014 (the "Regulation"). One of the goals of the Regulation is to ensure that investors are provided with a summary of investor rights resulting from their investment in an undertaking for collective investment in transferable securities in the meaning of Directive 2009/65/EC or, under certain circumstances, in an alternative investment fund in the meaning of Directive 2011/61/EU (hereinafter referred to as "Fund" or jointly as "Funds").

It is not the intention of this summary to give an exhaustive list of rights Investors may have. Further information may also be obtained in the respective Fund's prospectus, offering document or other pre-contractual disclosure document as well as by contacting the management company or alternative investment fund manager ("AIFM"), respectively.

Conflict of Interest

Management of conflicts of interest of Credit Suisse Fund Management S.A. (hereinafter referred to as “CSFM”)

In accordance with the Luxembourg Law of 17 December 2010 relating to Undertakings for Collective Investment, as well as in accordance with Chapter III of the CSSF Regulation Nr. 10-4, implementing Directive 2009/65/EC, and Circular CSSF 18/698, as well as the Luxembourg Law of 12 July 2013 on Alternative Investment Fund Managers and Commission Delegated Regulation (EU) No 231/2013 of 19 December 2012 supplementing Directive 2011/61/EU, as may be amended from time to time, CSFM is under the legal obligation to establish, implement, and maintain an effective conflict of interest policy.

In the conduct of its business, CSFM’s policy is to identify, manage, and, where necessary, avoid any action or transaction that may pose a conflict of interest between:

  • CSFM, including its managers, employees or any person directly or indirectly linked to CSFM by control, and the funds managed by CSFM or the investors in these funds; or
  • a fund or the investors in that fund, and another fund or the investors in that fund; or
  • a fund or the investors in that fund and another CSFM client; or
  • two CSFM clients.

CSFM strives to manage any conflicts of interest in a manner consistent with the highest standards of integrity and fair treatment. For this purpose, it has implemented procedures to ensure that any business activities potentially involving a conflict are conducted with an appropriate level of independence and that any conflicts are resolved fairly.

In the unlikely event that a conflict of interest could not be managed by CSFM, any such non-neutralized conflicts as well as the decisions made will be disclosed appropriately.

Best Execution Statement

Statement on best-execution principles of Credit Suisse Fund Management S.A. (hereinafter referred to as “CSFM”)

In accordance with the Luxembourg Law of 17 December 2010 relating to Undertakings for Collective Investment, as well as in accordance with Articles 28 and 29 of the CSSF Regulation Nr. 10-4 , implementing Directive 2009/65/EC, Circular CSSF 18/698, the Luxembourg Law of 12 July 2013 on Alternative Investment Fund Managers, and Commission Delegated Regulation (EU) No 231/2013 of 19 December 2012 supplementing Directive 2011/61/EU, as may be amended from time to time, CSFM is under the legal obligation to act in the best interests of the UCITS or the Alternative Investment Funds (hereinafter referred to as “funds”) it manages when executing decisions and/or when placing orders with other entities to carry out actions on behalf of the managed funds in the context of management of their portfolios.

In general, CSFM delegates the function of portfolio management, including the placement and execution of orders on behalf of the funds it manages, to third parties that are subject to regulatory supervision in an EU member state or, if the third party is domiciled in a non-EU country, subject to regulatory supervision that is deemed equivalent to the supervision in an EU country.

CSFM ensures that the third parties to which these activities are delegated are subject to best-execution rules and that they have implemented related policies and procedures, including a best-execution policy. The third parties shall, in particular, take all reasonable steps to obtain the best result for the funds, taking into account price, cost, speed, likelihood of execution and settlement, order size, and nature, or any other consideration relevant to the order.

In this context, the following criteria are relevant:

  • The objectives, investment policy, and risks specific to the funds on behalf of which the order is placed
  • The characteristics of the order
  • The characteristics of the financial instrument that is the subject of the order
  • The characteristics of the execution venues to which the order can be directed

The third parties shall monitor on a regular basis the effectiveness of their arrangements and policy for the execution of orders on behalf of the funds. The third parties must be able to demonstrate that they have executed and placed the orders on behalf of CSFM in accordance with their best-execution policy. CSFM has entered into contractual arrangements with the third parties that shall ensure the application of best-execution principles and that allow CSFM to perform appropriate due diligence and controls on the third parties. In this context, CSFM has established and implemented specifically designed policies and procedures in order to make sure that any risks of non-compliance are adequately mitigated.

The aforementioned principles do not apply where there is no choice of different execution venues.

Remuneration Principles

Remuneration principles of Credit Suisse Fund Management S.A. (hereinafter referred to as “CSFM”)

In accordance with the Luxembourg Law of 17 December 2010 relating to Undertakings for Collective Investment, as well as in accordance with Articles 28 and 29 of the CSSF Regulation Nr. 10-4, implementing Directive 2009/65/EC, Circular CSSF 18/698, the Luxembourg Law of 12 July 2013 on Alternative Investment Fund Managers and Commission Delegated Regulation (EU) No 231/2013 of 19 December 2012 supplementing Directive 2011/61/EU, as may be amended from time to time, and the Guidelines on Sound Remuneration Policies under the AIFMD, CSFM applies the remuneration principles and policies of Credit Suisse Group AG (hereinafter referred to as the “Group”). In addition, CSFM has developed an Appendix to the Group Compensation Policy to specify the remuneration standards at CSFM level.

The key objectives guiding CSFM’s remuneration approach as laid out in the Group Compensation Policy are:

  • Sound and effective risk management that does not encourage risk-taking activities
  • High conduct and ethical standards through a system of penalties and rewards
  • Teamwork and collaboration across the Group
  • Balanced distribution of profitability between shareholders and employees over the long term
  • Creation of sustainable value for the Group’s shareholders
  • Performance culture based on merit that differentiates and rewards excellent performance
  • Attraction and retention of employees who are motivated to achieve results with integrity and fairness
  • A proportion of variable compensation that is appropriate for the role and encourages appropriate behaviors and actions

The Group has a Compensation Committee that supervises compensation policies and practices, procures independent external compensation advice, recommends changes to the Compensation Policy or overall plans to the Board of Directors, and approves the compensation of Executive Board members and the Board of Directors, among other tasks.

In addition, CSFM has defined a group of employees identified as “Risk Takers” (e.g. managers in charge of the control functions – Risk Management, Compliance, Internal Audit).
The main parameters for the remuneration may comprise some or all of the following:

  • Fixed component (such as annual salary)
  • Variable component (such as performance bonus)
  • Complementary pension scheme
  • Other additional benefits

Data Protection and Disclosure

Data protection and disclosure

You can find information on data protection and disclosure for AM CS entities here: www.credit-suisse.com/ch/en/legal.html

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