Regulatory Disclosures

Complaints Management

Munich Re Investment Partners (hereinafter “Investment Partners”) considers it very important to have a trusting working relationship with our clients at all times. We therefore strive to clarify your query as quickly and transparently as possible.

 

Please contact Investment Partners with your query:

Munich Re Investment Partners GmbH

Königinstrasse 107

80802 München, Germany

Telefon: +49(89)3891-0

E-Mail: info@munichreinvestmentpartners.com

 

We register your query as soon as it is received. Your complaint will be promptly acknowledged and investigated by the complaints management function which is independent from the functions and circumstances giving rise to the complaint. Throughout the investigatory process we will keep you up to date with our progress and aim to provide you with a substantive response. If you are not satisfied with the proposed solution, you can assert your rights with a court of law or seek a settlement of your dispute in an alternative procedure.

Complaints can also be addressed to: Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin) Dienstsitz Bonn: Graurheindorfer Straße 108 53117 Bonn Dienstsitz Frankfurt am Main: Marie-Curie-Str. 24 - 28 60439 Frankfurt am Main

Code of Conduct

The Munich Re Group Code of Conduct also applies at Munich Re Investment Partners https://www.munichre.com/en/company/about-munich-re/corporate-governance/code-of-conduct-munich-re-group.html.

Conflicts of Interest

Principles for avoiding conflicts of interests

Munich Re Investment Partners (hereinafter “Investment Partners“) has put controls, policies and procedures in place to identify and to prevent or manage conflicts of interest between Investment Partners and its clients, as well as between one client and another that arise as a result of the Firm providing regulated activities and services including investment services and activities under the Markets in Financial Instruments Directive 2014/65/EC.

Conflicts of interest can arise, for example, between Investment Partners, other companies of Munich Re Group, Investment Partners management, staff or other persons affiliated to Investment Partners, its clients or between the clients themselves.

 

Organisational measures in the event of conflicts of interests:

In order to counteract potential conflicts of interest before they arise, Investment Partners took care to ensure separation of functions when structuring its organisation, especially functions that are incompatible with each other. The principle of keeping functions separate applies all the way up to Executive Board level. Investment Partners also has a compliance function to identify, prevent and manage conflicts of interest.

The Company also obliges its staff to observe high ethical standards. It expects the greatest of care and integrity at all times, lawful and professional conduct, the upholding of market standards and especially observance of the clients' best interests.

 

Despite these organisational precautions, conflicts of interest could arise carrying out investment services and activities including, but not limited to, the following:

  • When receiving inducements from third parties in the form of gifts, dining invitations or travel in the context of offering securities services;
  • From predominantly success-related remuneration of employees;
  • When obtaining information not yet publicly known (insider information);
  • From personal relationships of employees or management or people related to or acquainted with them;
  • When these persons are active in supervisory boards or other advisory bodies;
  • Due to Investment Partners being part of a group of companies;
  • Where Investment Partners is acting as a discretionary portfolio manager for more than one client, in particular in respect of issues relating to allocation;
  • When clients have identical interests in purchasing a share of an investment;
  • When grouping together similar buy/sell orders (block trades);

 

We counteract or prevent these potential conflicts as follows, by:

  • ensuring that the Code of Conduct and organisational guidelines are upheld;
  • keeping a watch list to counter possible conflicts of interest, for example by prohibiting certain transactions;
  • ensuring compensation governance practices that avoid conflicts of interests by fostering long term thinking;
  • having controls in place ensuring that only certain acceptable minor non-monetary benefits are permitted;
  • creating areas of confidentiality by erecting information barriers, separating responsibilities and/or through spatial separation (Chinese walls);
  • keeping insider and observation lists that monitor the emergence of sensitive information and prevent the misuse of insider information;
  • ensuring disclosure and supervision of personal account dealing and outside activities of employees who may be confronted with conflicts of interest within the course of their work;
  • ensuring that investors' best interests are served by when delegating tasks;
  • monitoring the portfolio turnover rate;
  • checking for conflicts of interest when designing new products;
  • regulating dealings with block trades;
  • regularly training the staff in matters of compliance.

 

Disclosure:

We should only use disclosure as a measure of last resort where organisational precautions put in place to prevent or manage its conflicts of interest from adversely affecting clients’ interests are not sufficient to ensure, with reasonable confidence, that the risk of damage to the interests of one or more clients will be prevented.

Last update: August 2021