Norron AB is an investment firm within the meaning of the Markets in Financial Instruments Directive (2004/39EC).
The Company has been granted a Licence, by Finansinspektionen, to carry out portfolio management in accordance with Chapter 2, Section 1, item 4 of the Securities Markets Act (SFS 2007:528).
In accordance with FSA regulations and guidelines (FFFS 2007:5) regarding disclosure of capital adequacy and risk management must Norron AB provide quarterly information on companies’ capital base and capital.
Calculation of requirements are carried out in accordance with the Act (2006:1371) on capital adequacy and large exposures, FSA regulations and guidelines on capital adequacy (FFFS 2007:1).
Norron publishes annual and interim financial statements in accordance with the Annual Accounts Act for Credit Institutions and Securities Companies. If you wish to obtain Norron’s financial statements, please contact Alexander Zetterquist, email@example.com.
As a portfolio manager, Norron AB ("the Company") has an obligation to take all sufficient steps to achieve the best possible results for the unit holders when the Company places buy and sell orders in financial instruments for execution with counterparties.
In order to achieve the best possible results when the Company carries out transactions on behalf of the funds, and to ensure that the Company acts in the best interests of the unit holders, the Company has established specific internal guidelines. These guidelines have been set up in accordance with the Swedish Securities Market Act (2007: 528), Chapter 9, Section 31-37 and the Commission delegated Regulation (EU) 2017/565.
The following information summarizes the Company's internal guidelines and aims to provide information to investors and/or potential investors on how the Company operates to achieve the best possible results for the unit holders.
It should be noted that, while the approaches described below are expected to lead to the best possible results for the funds, there is no guarantee that it can be accomplished for each individual transaction.
SELECTION OF COUNTERPART AND ORDER EXECUTION
The Company is not a member of any regulated market or other marketplace and always carries out transactions via a third-party. The execution of transactions takes place through the Company's order and execution management system in Bloomberg and orders are placed directly with the counterparty. The Company has carefully mapped the counterparties with whom transactions in financial instruments are carried out and only uses counterparties that are under supervision and obliged to comply with rules for best execution. These counterparties are regularly evaluated in accordance with the internal guidelines.
Transactions may only be carried out with counterparties that are approved by the Company's CEO. The requirements imposed on the counterparty include, amongst others, that they should:
be under supervision by the relevant financial authority
be well-known and established in the European financial market
demonstrate financial stability
display and offer competitive trading prices
The selection of counterparties shall be made by assessing the counterparty's ability to offer good order execution. The factors that the Company will regard include:
access to marketplaces
related prices and fees
quality of services offered
the counterparty's policies/routines for best execution
The company's ability to fulfill its obligations under the internal guidelines and other market regulation
The company evaluates, at a minimum annually, all counterparties.
THE RELATIVE IMPORTANCE OF THE FACTORS WHEN PLACING AN ORDER
In order to achieve the best possible result for the unit holders, the Company will consider all reasonable actions/measures when carrying out orders. They include:
Order size and type
Likelihood of execution and settlement
Any other consideration that, according to the Company's assessment, is relevant to a particular order
Normally, the Company will give price the greatest importance. In some cases, however, the Company may need to emphasize other factors than price, such as if the order, due to its size or type, may, according to the Company's assessment, have a significant effect on the cost of the execution, if the likelihood of the order being executed or settled may be affected by the order's characteristics or, if it is for other reasons relevant to give other factors than price greater importance.
In conjunction with the Company's placement of orders of OTC products, the Company checks/assesses whether the price offered is reasonable. This is done by using market data used in estimating the price of the relevant product and, if possible, by comparing with similar or comparable products.
DISRUPTIONS IN THE MARKET OR TRADING SYSTEM
In case of irregularities, breakdown or exceptional conditions on the market or disruptions in the Company's own systems, it may be impossible or inappropriate to conduct transactions in the manner specified above. In case the Company considers it necessary to exempt from what has been stated above, the Company is obliged to take all reasonable measures to in a different way achieve the best possible results for the unit holders.
REPORTING OF TRADING
During each trading day, the Company confirms transactions made to the Fund Administrator EFA (European Fund Administration S.A.). The confirmation contains essential information about the transactions. In connection with this, the Company also confirms all transactions to the relevant custodians.
The Swedish Securities Market Act (2007:528) sets up certain rules for investment firms regarding payments to and from third parties. According to the Swedish Securities Market Act investment firms shall not, in connection with the provision of an investment service or ancillary service, pay or be paid any fee or commission, or provide or be provided with any non-monetary benefit to or by any third party except the client or a person on behalf of the client, other than where the payment or benefit:
(i) is designed to enhance the quality of the relevant service to the client and does not impair compliance with the investment firm’s duty to act honestly, fairly and professionally in accordance with the best interest of its clients; and
(ii) the existence, nature and amount of the payment or benefit, or, where the amount cannot be ascertained, the method of calculating that amount, has been clearly disclosed to the client, in a manner that is comprehensive, accurate and understandable, prior to the provision of the relevant investment or ancillary service.
However, payments or benefits which enable or are necessary for the provision of investment services and which by its nature cannot give rise to conflicts with the investment firm’s duties to act honestly, fairly and professionally in accordance with the best interests of its clients, are not subject to the requirements described above.
Certain additional rules apply for investment firms that provide portfolio management. Such investment firms shall not accept and retain fees, commissions or any monetary or non-monetary benefits paid or provided by any third party, or a person acting on behalf of a third party, in relation to the provision of the service to clients. However, minor non-monetary benefits are acceptable provided that such benefits are reasonable and proportionate and of such a scale that they are unlikely to influence the firm’s behaviour in any way that is detrimental to the interests of the relevant client. The following benefits should be considered as such minor non-monetary benefits:
(i) information or documentation relating to a financial instrument or an investment service, which is generic in nature or personalised to reflect the circumstances of an individual client.
(ii) Written material prepared by a third party that is commissioned and paid for by an undertaking that is an issuer or potential issuer to promote a new issuance by that institution, or where the third party is contractually engaged and paid by the issuer to produce such material on an ongoing basis. A condition for this is that the relationship is clearly disclosed in the material and that the material is made available at the same time to any securities institution wishing to receive it or to the general public.
(iii) Participation in conferences, seminars and other information events on the benefits and features of a specific financial instrument or an investment service.
(iv) Hospitality of a reasonable mimimis value.
NORRON AB’S PAYMENTS TO OR FROM THIRD PARTIES
Norron AB (”the Company”) provides portfolio management of the Norron funds in accordance with an investment management agreement (“IMA”) between the Company and SEB Fund Services S.A. (“the Fund Company”), where the Company places buy and sell orders in financial instruments for execution on behalf of the funds.
The Company only accepts and retain fees from the Fund Company. Such fees represent the investment management fee stipulated in the IMA – as well as in the prospectus of the funds – and are paid to the Company on a monthly basis. The fees paid by the Fund Company to the Company derive from the fund’s management fee and are based on the fund’s volume. The Company may also receive variable fees based on the fund’s performance, i.e. performance-based fees. Beyond the mentioned investment management fees from the Fund Company the Company may also accept minor non-monetary benefits in accordance with the provisions stated above. Furthermore, the Company does not accept any payments, fees, commission, discount or other benefit from any third party in order to direct any order to a certain market place or that could give rise to conflicts with the Company’s duties to act honestly, fairly and professionally in accordance with the best interests of the unit holders.
The Company does not pay or provide any non-monetary benefit to any third party in connection with the provision of an investment service. Payments in relation to the management of the fund, such as counterparty fees for executing orders, commissions or discounts to distributors and investors are managed by the Fund Company. Such payments derive from the management fees paid by the unit holders for the management of the funds.
In connection with the provision of the investment service the Company pays some third parties to provide the Company with research. The Company has decided to pay for the research with its own funds, i.e. the unit holders are not affected by this cost.
In order to counteract excessive risk taking behaviour and promote sound and efficient risk management in financial companies, the Swedish Financial Supervisory Authority (FSA) has established regulations (FFFS 2011:1) regarding remuneration structures in credit institutions and investments firms. According to the regulations, an investment firm is obliged to have a documented renumeration policy which outlines the basics and principles for how remuneration is determined, applied and followed up on. This policy shall encompass all employees and be designed and applied in a manner and to the extent that is appropriate to the size, internal organization and the nature, scope and complexity of the business activities. Furthermore, the remuneration policy shall comply with the company's strategy, objectives, values and long-term interests and ensure that the company's remuneration structure takes account of its clients in order to ensure that they are treated fairly and that their interests are not adversely affected by the remuneration structure applied by the company in the short, medium or long term.
In accordance with the FSA’s regulations, the board of Norron AB ("the Company") has established and documented a remuneration policy that sets out the principles and guidelines that apply to its employees regarding remuneration. Below follows a summary of this policy as well as information on how the Company complies with the requirements/regulations from the Swedish FSA.
INFORMATION ON COMPANY'S REMUNERATION POLICY AND REMUNERATION SYSTEMS
The Board has the ultimate responsibility for adopting a remuneration policy and to ensure that it is applied and followed up on. The Board also decides on the remuneration to the CEO and employees who have overall responsibility for any of the Company's control functions. It is also the Board’s responsibility to decide which measures to apply to ensure that the remuneration policy is adhered to. Remuneration to other employees is decided on by the Managing Director.
Within the framework of the remuneration policy, the Company annually performs a risk assessment. This risk assessment is aimed at - in accordance with FFFS 2011: 1 and the Commission’s delegated Regulation (EU) 604/2014 – identifying employees whose professional activities have a material impact on the Company's risk profile but is also taking into account all other risks that the Company is or may be exposed to, including the risks associated with the Company's remuneration policy and structure.
The company's core business is to conduct portfolio management of the Norron funds. The unit holders’ investments/capital is thus held separately from the Company's capital. The potential risks in the Company are mainly associated with the development of achieved portfolio management results and their impact on the income statement and the balance sheet. The balance sheet is of a relatively small extent and consists primarily of necessary and accumulated working capital. The company's own capital is affected partly by the results achieved and partly by the company's dividend policy. The risks associated with the portfolio management of the funds are largely governed by fund regulations, as well as limits and discretionary asset management agreements. Besides, the number of employees that can affect the company's risk level, both directly and indirectly, are limited. In order to manage various risks in the Company and to ensure that the Company's operations are carried out in accordance with applicable laws, regulations and the Company's internal guidelines, ongoing audits of the business and the business processes are carried out by the Company's risk and compliance function as well as the Company's internal auditor. The internal auditing includes, amongst others, making a separate independent control of the Company's remuneration structure and policy.
In order to ensure that individual employees are not given incentives or have the opportunity to take unreasonable risks solely for the purpose of generating high variable remuneration, the Company has adopted a compensation model involving several parameters of varying nature. The Company's remuneration structure is largely regulated in the employment contracts, such as fixed remuneration and fixed pension benefits, which are not linked to future risk commitments. Salary and other employment benefits shall be such that the Company can attract and retain competent employees. Fixed salary should be in line with the market conditions and based on the employee's age, education and experience. There should be an appropriate balance between the fixed and variable remunerations. The fixed remuneration should therefore constitute a sufficiently large part of the total remuneration so that the variable remuneration can be set to zero. Any variable remuneration shall be based on both financial and non-financial criteria. In addition, the variable remuneration, especially for personnel whose duties mainly relate to the portfolio management, should not exclusively or predominantly be based on quantitative criteria, but also take into account appropriate qualitative criteria such as complying with applicable market rules and regulations, internal guidelines as well as the quality of the services provided to investors in the form of portfolio management.
The Company's assessment of the results on which the calculation of variable remuneration is based shall primarily be based on risk-adjusted profit targets, both current and future risks. The Company's remuneration system should be designed in such a way that it benefits both the long-term interests of the Company and is in line with the rules and principles that have been established in order to protect investors and shareholders. The compensation paid by the Company must not jeopardize the Company's long-term results and financial position. The Company's Board of Directors shall ensure that the variable level of compensation is not set too high so it limits the Company's ability to comply with statutory requirements for the Company's capital assessment under Pillar 1 and Pillar 2, and assessment of future investments.
The variable remuneration may amount to a maximum of 100 % of the fixed salary. Any variable remuneration is discretionary, and thus, the Company has the right to withhold any variable remuneration payments. A general prerequisite for the payment of variable remuneration is that it is justifiable in view of the Company's financial situation and justified by the Company, the business and the employee's results and goals relating to their function. Another important part of the decision making regarding variable remuneration is that the Company shall ensure that the total amount of variable remuneration does not limit the Company's ability to maintain a sufficient capital base or, if necessary, strengthen the capital base. Any additional criteria for the payment of variable remuneration are determined individually for each employee.
Any variable remuneration for internal control functions is determined in accordance with the Swedish FSA’s regulations and based on objectives relating to the control function. The variable remuneration shall be independent of the performance of the business areas controlled by the control function. Note that the same general conditions apply as for other employees who receive variable compensation, for instance that the payment of variable remuneration shall be justified in view of the Company's financial situation. Furthermore, the variable compensation for control functions shall be designed so that it does not threaten the objectivity and independence of that function. The total compensation for control functions should therefore be predominantly fixed.
In cases where the Company pays variable remuneration to employees whose professional activities have a material impact on the Company's risk profile, at least 40 % of the variable remuneration shall be deferred for at least three years before it is paid to the employee. Deferred compensation is paid once a year evenly distributed over the period of time that the remuneration has been deferred (pro rata). The first payment may be made at the earliest one year after the decision to grant variable remuneration. When deciding how much of the variable remuneration that should be deferred and for how long, the Company will take into consideration its business cycle, the risks of business operations, the employee's responsibilities and duties, as well as the amount of variable remuneration. Based on the rules of deferral, variable remuneration of less than 100,000 SEK may be exempted.
For employees whose professional activities have a material impact on the Company's risk profile and a variable remuneration over 500,000 SEK, at least 60 % of the variable compensation shall be deferred for at least three years. Payment of deferred remuneration shall be paid pro rata as per above, i.e. once a year evenly distributed over the period of time that the remuneration has been deferred (1/3 of deferred remuneration year 1, 1/3 year 2, etc.).
The deferred remuneration shall in these cases, as for any other staff, only be paid out or passed to the employee if it is justified in view of the Company's financial situation (linked to the Company's capital adequacy ratio) and supported according to the Company, the business unit and the employee's result. The deferred part of the remuneration could also be cancelled in full for the same reasons.
In order to ensure that the Company's remuneration policy is adhered to and that the remuneration structure in the Company is effective and appropriate, the Company has appointed the internal auditor to constitute an independent control function so as to monitor and control the remuneration policy. The internal auditor shall, when applicable, and as a minimum, annually review whether the Company's remuneration structure complies with the principles and guidelines laid down in the remuneration policy. This control is a fixed point in the annual review plan. The results of the audit shall be reported to the Board at the latest in connection with the adoption of the annual report. If the internal auditor finds that the Company's remuneration to individual employees differs from the remuneration policy, reporting to the Board shall be done immediately.
In the assessment and evaluation process that the Chairman of the Board carries out in accordance with the remuneration policy, representatives from appropriate control functions shall participate.
Norron AB (below Norron) is a Nordic asset manager with offices in Stockholm and Oslo. Norron manages seven funds with a focus on the Nordic capital markets and is owned by the founders, as well as the partners in the business, and the Norwegian listed industrial investment company Aker ASA.
Investment management is a responsible job. Managing other people's savings adds additional responsibilities. Norron trades exclusively in the common interest of the shareholders and the overall task is to deliver market-leading risk-adjusted returns. In order to optimize the return for the shareholders, we have a strategy and investment philosophy with four cornerstones that we follow, these are(i) common sense, (ii) competence, (iii) accessibility and (iv) transparency. A fifth aspect that is central to Norron's management is sustainability/ESG (more information about Norron's approach to ESG follows under the heading Other principles of material importance for shareholder engagement (ESG).
As portfolio managers of the funds, it is part of Norron's management assignment to represent the funds in ownership matters related to the ownership of the companies in which Norron invests. In order to inform the shareholders about how Norron acts on various ownership issues related to the shareholdings, Norron has established the following principles for shareholder engagement.
Please note that Norron does not only exercise shareholder engagement for holdings listed on the regulated market, but also for holdings that constitute so-called "case-investing" i.e., smaller companies on an mtf-platform as well as unlisted companies.
MONITORING OF RELEVANT ISSUES IN PORTFOLIO COMPANIES
The very starting point of Norron's fund management is that we invest in companies that we consider sound and the potential for development is good. In our active management, we see our role as a one that can make input to reinforce the positive that is happening in the portfolio companies and also serve as a sounding board to the company's management. It is not our intention to make decisions for the companies, provided that we do not believe that there is such a need. An important part of the investment process is that we have confidence in company management since they are the ones that will carry out the work that will generate returns to the shareholders.
This approach leads to a central part of the management being monitoring of relevant issues in the portfolio companies. Due to the large number of holdings in the funds, the monitoring may be more or less extensive depending on the strategy of the company in question. For example, supervision of the portfolio’s core holdings is more rigorous and extensive than is the case for companies representing only a smaller share of the fund portfolio or larger listed companies where Norron owns only a small proportion of the outstanding shares. In general, however, the monitoring covers all aspects of the portfolio companies, such as corporate governance, financial and non-financial performance and risks, capital structure and social and environmental impacts. Another important part of fund management is to evaluate and monitor the portfolio companies’ development strategy. It is our task to evaluate and assess the credibility of the strategy and also to determine if company management is capable of implementing it. If it turns out that the company does not live up to our high expectations, this may be a reason to overlook these positions and possibly disinvest.
For the above purposes, Norron has developed a detailed investment process. When we decide to invest in a company, we utilize the entire expertise that exists within the management organization. Thus, to the extent possible, companies are evaluated by a team of both equity and fixed income managers in order to evaluate the entire company's capital structure. The monitoring is then normally carried out through company visits and other scheduled communication such as capital markets days, analyst meetings and quarterly reports from the companies. These are important sources of information for us. We also study analysts' reports and statements etc. about the companies. However, when we access such third-party information, it is important that we establish our own view and understanding of the strategic work and, above all, the credibility of the strategic choices ahead and whether we believe that management has the right competence to execute the strategy.
The monitoring, as described above, of companies in our investment universe, which amounts to over 400 companies, renders a large amount of data to take into consideration in the investment process. In order to effectively monitor and follow up on these companies, Norron has clear internal procedures and processes as well as databases and support systems. This also includes Norron's work in relation to ESG, which is integral throughout the investment process.
DIALOGUES WITH REPRESENTATIVES OF PORTFOLIO COMPANIES
Norron is an active manager with the view to coach rather than control the companies. We invest in a specific company because we believe in that particular company and not because of a specific index. This management strategy entails an obligation to have a close dialogue with the portfolio companies in order to be able to carry out solid probability analyses of company strategies and take an active position on capital structures, ESG etc.
It is neither possible nor appropriate to have a close dialogue with all holdings in the fund, since the funds managed by Norron consist of many different holdings and where the investment strategy for the investments may also differ. The size of the investments also varies, both as a share of the company and as a share of the fund. The companies with which we mainly have a close dialogue are the companies that we classify as core holdings in the funds. The core holdings are not necessarily the largest companies or holdings but may be important holdings for a particular strategy for the fund. The dialogues are normally conducted through conference calls, company visits, one-on-one meetings, participation in company presentations and capital markets days. We can also choose to express an opinion by means of a formal letter.
EXERCISE OF VOTING RIGHTS AND RIGHTS ATTACHED TO THE SHAREHOLDING
Through Norron's active management philosophy, we carry out advocacy work in several different ways. This includes, among other things, dialogues with the portfolio companies, but also voting at general meetings. Norron's funds are UCITS funds, which means that the funds must have a certain spread of risk and diversification. The funds thus have, as mentioned above, many different holdings and Norron does not have as a starting point to exercise its voting rights at all general meetings of the companies. On the other hand, Norron exercises its voting rights at general meetings where it is deemed necessary and where issues are dealt with that we consider to be in the common interest of the shareholders. In each such case, we make an individual assessment of the issue and take a position on how we will vote at the general meeting. It is above all in our case investments that we exercise our right to vote but can also do so in other holdings where there is reason to take a stand on a particular issue.
COOPERATION WITH OTHER SHAREHOLDERS AND COMMUNICATION WITH RELEVANT STAKEHOLDERS IN PORTFOLIO COMPANIES
In cases where this becomes relevant, Norron can have a dialogue and collaborate with other shareholders on various ownership issues. We do this mainly on issues of great importance and we believe that it is appropriate and in the interests of the shareholders that such dialogue should be conducted.
HANDLING OF ACTUAL AND POTENTIAL CONFLICTS OF INTEREST
Managing other people's money entails a great deal of responsibility and it is important that fund owners have confidence in Norron and its management. An important element in maintaining this confidence in Norron, but also in the financial market as a whole, is to identify and manage actual and potential conflicts of interest.
Conflicts of interest can arise in any type of business. A typical example in management activities is when the interests of the fund manager do not correspond to the interests of the shareholders. Norron, or its employees, should never be suspected of benefiting unduly from the knowledge of business/investor conditions or the financial market etc. that they may gain in their business. Norron shall and has an obligation to always act in the interests of the shareholders. The interests of the shareholders must therefore never be disregarded. This means that other interests of Norron or its employees must fold in the event of any conflicts of interest. This obligation places high demands on the business and that Norron constantly evaluates the risks of conflicts of interest and identifies these and, if necessary, also manages them. For this purpose, Norron has adopted specific guidelines for ethical issues and conflicts of interest. In this respect, ongoing discussions are also held to avoid conflicts of interest and regular checks are carried out to ensure compliance with the guidelines.
In the event of a conflict of interest in the exercise of voting rights and where this would entail a material risk of adversely affecting the shareholders, this conflict of interest shall, where possible, be prevented. If a conflict of interest can be avoided by appointing another appropriate representative, the CEO, together with the investment manager and the compliance function, shall appoint such person.
PRINCIPLES FOR OWN PARTICIPATION IN NOMINATION COMMITTEE WORK
Norron currently has no participation in any nomination committee. Instead, we strive to be an active sounding board to nomination committees around ideas of board members. However, we do not rule out that Norron will need to take a more active role in some major holdings’ nomination committees. This is assessed on a case-by-case basis.
HANDLING OF QUESTIONS ABOUT INSIDE INFORMATION IN RELATION TO SHAREHOLDER ENGAGEMENT
Norron's only business is portfolio management of Norron's funds, i.e. the buying and selling of financial instruments on behalf of the funds. It is in the common interest of Norron's employees to achieve the best possible returns for the shareholders. To achieve this, management relies on market information, which means that Norron's managers from time to time can access inside information in the form of market probes. To this end, Norron has established a strict policy and special procedures for managing market probes and other sensitive information that are continuously monitored by both systems and staff.
As regards inside information in relation to shareholder engagement, the general rule of Norron is that no employee shall be on the boards of companies that are within the scope of the funds' investment orientation, in order not to restrict or confine the investment freedom of the respective nominees. Should a fund manager disagree, this needs to be discussed with the CIO as well as the CEO and decisions shall be taken in consultation. If it emerges that it is in the best interests of the shareholders that Norron has a representative on the Board of Directors, there is a possibility to deviate from this strategy.
SITUATIONS WHERE NORRON ACTS IN PORTFOLIO COMPANIES AND THE ESCALATION PROCEDURE
Our basic idea is to invest in companies that we consider to be sound and are in a positive development phase. Our engagement differs depending on what the substantive question is. If we do not believe that the company meets our expectations or if we see other problems with corporate governance, this may give rise to increased dialogue with the company in question to denounce the problems. In relation to this, it may also be necessary to gather a shareholder group that share our view. If there are no improvements, one last option is to sell the holding.
USE OF VOTING ADVISORS
In cases where Norron intends to exercise its voting rights at general meetings, Norron's aim is to always have such knowledge of the company in question and the issues to be addressed that the use of voting advisors is not relevant.
PRINCIPLES FOR EQUITY LOANS
The price of equity loans is governed by supply and demand. To the extent that situations arise where it is beneficial for shareholders that we lend shares in the funds, Norron may consider taking such action. An assessment would then be made on a case-by-case basis.
OTHER PRINCIPLES OF MATERIAL IMPORTANCE FOR SHAREHOLDER ENGAGEMENT (ESG)
For Norron, it is of central importance that the funds' holdings develop sustainably. The objective of sustainable investment shall be a strong economic return used to contribute to positive developments in social, environmental and policy issues in order to achieve joint improvements in these sectors. Following up on and influencing the sustainability work of the companies we own, and intend to invest in, is a significant and integral part of our analysis work and consequently also in our investment process. By actively relating to sustainability/ESG, we believe that we can meet our stakeholders' high demands on both long-term risk-adjusted returns and sustainable development in the companies we invest in. This approach, in turn, has a positive impact on the world we live in, both today and for future generations. The monitoring of the portfolio companies' ESG strategies follows the same philosophy as for other relevant issues and our portfolio companies are happy to provide guidance in the strategy work for ESG, as we believe that it benefits both shareholders and society at large.
It follows from the fund and securities market legislation that every year fund/asset managers must explain how the principles of shareholder engagement have been applied. This statement is published annually on Norron’s website.
Norron AB (”Norron”) is a Swedish investment firm authorised by the Swedish FSA (Sv. “Finansinspektionen”) to conduct portfolio management. In accordance with an investment management agreement between Norron and FundRock Management Company S.A. (“FundRock”) Norron carries out the portfolio management of the Luxemburg based umbrella fund Norron SICAV. Norron’s only business is to manage the portfolio of each sub-fund under Norron SICAV as well as marketing its own business, while FundRock handle the administration of Norron SICAV. This means that you, as an investor, is formally a client of FundRock’s.
However, should you want to submit a complaint or raise any concerns with regard to Norron’s business, such as the portfolio management of the funds, the marketing of Norron’s business or any other communication about the funds etc. you may contact the Complaints Manager at Norron via telephone, post or email. If your complaint regards any other part of the fund management, Norron will refer you to the Complaints Manager at FundRock. Submitting a complaint is always free of charge.
Jesper Laudon Meyer, Head of Compliance
Tel: +46 (0)73 736 6543
Postal address: Box 3054, 103 61 Stockholm
FundRock Management Company S.A.
Postal address: FundRock Management Company S.A., Attention: Complaints Handling, H20 Building, 33 Rue De Gasperich, Hesperange, L-5826, Luxembourg
We will normally process your complaint within two weeks and will in most cases reply in writing. Should you not be satisfied with the outcome of the matter you may contact any of the following external bodies:
The Swedish Consumers’ Banking and Finance Bureau (www.konsumentbankbyran.se)
The National Board for Consumer Disputes (www.arn.se)
Corporate legal entities are entitled to have their case heard by an arbitration board.
If you have any other questions or want more information regarding the handling of complaints, you are welcome to contact us.
For information about how Norron process personal data in relation to complaints, please click here
Investing in funds is associated with risk and a historical return is no guarantee of future returns. No account is taken of inflation. The risk specified for each fund is only the estimated risk and it is not possible to make accurate calculations of future risk. The value of the fund units can both increase and decrease and it is not certain that you get back the entire capital invested. Each investment decision is taken by the investor him/herself, who is also fully responsible for the investment. The Company is therefore not liable for any losses or damages (direct or indirect) arising from an investment in the Funds. The content on this website is general information and not adapted to anyone's individual needs or financial position and should therefore not be perceived as an offer or invitation to buy or sell fund units. The terms of investment made in the most recently updated and accepted prospectus are the only legally binding terms of investment in the Funds and the Company, or any branch of the Company, are not liable for any direct or indirect damage or loss resulting from investments in the funds based on any information on this website. You should always review the product sheets, KIID and prospectus (available on this website) before completing a purchase and discuss any investment with a professional investment advisor.
The information on this website has been prepared by Norron AB ("the Company") as portfolio manager of the Luxembourg-based fund Norron SICAV, which has six sub-funds. Some information on the website is made by third parties that the Company considers reliable. The information on the Company's website is updated regularly and the Company constantly seeks to keep the information updated and correct. However, the Company cannot guarantee that the information is, at all times, accurate, reliable or complete. The Company disclaims all liability, in the event that the information on the website or such information the Company relates or links to is incorrect or misleading. Also note that the Company is purely portfolio manager of the sub-funds under Norron SICAV and that this management assignment is governed by an investment management agreement with the fund company SEB Fund Services S.A. The company is only authorized to conduct portfolio management and thus does not offer investment advice in any form and the information on the website should therefore not be regarded as such. The information on the website is adapted to the countries where the funds can be marketed, which are currently Sweden, Norway, France and Switzerland. The information and services described on this website and any other material available are not directed to any person or company domiciled in any country in which the publication or disclosure of the material is prohibited, limited or otherwise contrary to the laws and regulations of such jurisdiction. This applies in particular to, but is not limited to, countries such as the United States, Canada, Japan and Australia.
All information on this website belongs to the Company and is copyright protected as long as nothing else is expressly stated. It is not allowed to copy or use any part of this website for your own or other purposes unless the Company has given prior written approval.
The Company reserves the right to change the website content at any time and is not required to notify any party about such changes,
By using this website you confirm that you have read and understood the information contained in this disclaimer. Swedish law applies to the information provided on this website and any dispute of any kind should be referred to the Swedish court.
The General Data Protection Regulation (EU) 2016/679 (“GDPR”) is a new EU-regulation which enters into force on 25 May 2018. GDPR replaces the Swedish Personal Data Act and strengthens the individual’s rights through stricter requirements for companies on how to process your personal data.
Norron AB (the ”Company”) is a Nordic investment manager with offices in Stockholm and Oslo. The Company manages UCITS-funds with primary focus on the Nordic capital markets. The Company only carries out the investment management of the funds. The day-to-day operations and administration of the funds are conducted by SEB Fund Services S.A., the Management company. Since the Company only focuses on the investment management, and is excluded from the administration of the funds, the Company does not hold any data about the funds’ investors and therefore the processing of personal data with regard to third parties is limited.
It is important for the Company that the personal data that the Company collects and uses is processed in a secure and transparent way and in compliance with the GDPR. Thus, the Company has established this policy to provide you with information about what personal data that the Company processes about you, for what purposes we use it, how we process the personal data, and for how long we keep your personal data.
What type of personal data do we process about you and why?
The Company may process personal data about you for different purposes. For example the Company stores personal contact details for communication purposes and/or to be able to provide you with information about our investment management or to invite you to events. The company also processes personal data about you if you apply for employment with the Company or submit a complaint about the Company. More information about what personal data the Company processes is to be found below.
The Company does not process any special categories of personal data (article 9 GDPR) about you.
Records of contact information, communication and marketing The Company stores and uses information about those who have a business relationship with the Company or have been in contact with the Company for any other matters, such as email correspondence, arranging meetings or contact through other means of communication. The information we store about you for these purposes is mainly contact details – i.e. name, phone number, email address, title, company/employer – but could also be notes from meetings etc. The Company keep emails or similar communication information for one year or for such a period that the Company finds it necessary to fulfil the purpose for which the personal data was collected. The Company must also consider our need to answer any queries, to comply with legal requirements under applicable laws, to attend to any legal claims/complaints, and for safeguarding purposes.
It is important for the Company that your personal data is kept safe and that the Company can keep track of the information that we process. For this purpose, the Company uses a CRM-system to store and manage your contact information. By using this system, the Company can customise its mailings so that you only receive the information that you have requested such as information about the Company’s business and/or invitations to different events hosted by the Company. In the CRM-system we only store your contact details such as your name, phone number, email address, title/role, and company.
Hiring of personnel When the Company is going through a hiring process it is necessary for the Company to process applicants’ personal data. In such a process the Company must store a larger amount of personal data about you compared to the above. In addition to your contact details we must also store your CV, information about previous experience, references, personal ID number, and potentially a picture of you if you decide to add that to your application. This is necessary so that we can make an informed decision of whom we decide to hire and also to evaluate your suitability for the position. If you apply for a vacant position with the Company that has been advertised, the Company will store the applicants’ personal data throughout the hiring process. If you submit an application for a position that has not been advertised, the Company will store your personal data during a reasonable period of time until the Company has been able to assess whether or not you can be relevant for a future hiring process. For safeguarding purposes the Company will store information about each applicant for a period of two years upon completion of a hiring process.
Contracts The Company will store information about anyone who enters into contract with the Company. What type of personal data that will become necessary to store depends on the purpose of the contract, but will mainly concern information such as name, phone number, email address, title/role, and company. The information will be stored throughout the duration of the contract or during such period the Company finds necessary considering legal requirements under applicable laws and for safeguarding purposes.
Complaints In the case of the Company being subject to any complaints from investors the Company must process information necessary to manage the complaint. The Company has a legal obligation to store and keep a record of each complaint that it receives. For that purpose, the Company will store all necessary data in relation to such complaint for five years, including your personal contact details and any other information in relation to the complaint that the Company finds necessary to keep.
Miscellaneous The Company may also in other cases than the above need to process personal data of a third party if such processing is necessary for the purposes of the legitimate interests pursued by the Company except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject.
The lawfulness of the Company’s processing of personal data
Processing of personal data based on consent If the Company is processing personal data about you based on your consent, you will in advance receive all necessary information in relation to the purpose of the processing in accordance with GDPR. You have the right to withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
Processing of personal data necessary for the fulfilment of a contract The Company store personal data in fulfilling obligations related to agreements.
Processing of personal data based on the Company’s legitimate interests The Company may process personal data based on the Company’s legitimate interest. In these cases the Company considers the Company’s or third parties’ legitimate interest of the processing of the personal data to override the interests or fundamental rights and freedoms of the data subject, which requires protection of personal data. However, you will always receive relevant information of the processing of your personal data in accordance with GDPR. This is usually the case when the Company collects personal data for the purposes of communication in relation to the above, marketing, hiring of personnel and processing of complaints.
Period during which the personal data will be stored
The Company stores personal data for the period it finds necessary in fulfilling the purpose for which each specific personal data was collected, including the consideration of being able to meet the data subject’s specific needs and queries, complying with applicable laws and regulations as well as for safeguarding purposes. When the Company no longer considers the processing of personal data to be necessary, the Company will delete the data. Thus, the processing of personal data is depending on the purpose of the processing, but also on what legal ground the processing of personal data is based on. If the processing of personal data is based on consent the Company will delete the data if the data subject withdraws his/her consent. The Company keeps emails or similar communication for one year or for such period that the Company finds necessary to fulfil the purpose for which the personal data was collected. Contact details for business partners and others will be stored for the period the Company finds necessary to fulfil the purpose for which the personal data was collected. However, the data subject always has the right to object to the processing of its personal data, please see below.
Rights of the data subject
To the extent that the Company processes personal data the data subject has certain rights in relation to the Company;
the right to access the personal data;
the right to rectification and erasure of the personal data;
iii. the right to request restriction of the processing of personal data and the right to object the processing;
the right to withdraw consent to the processing of personal data (where applicable); and
the right to data portability.
If the data subject enforces any of its rights above, the Company will, without undue delay and under any circumstances within a month after the request by the data subject, respond to the data subject regarding what measures has been taken by the Company due to the request. If the request is deemed complex by its nature by the Company, the Company may extend such period to up to two months.
Any queries in relation to the above should be sent electronically to firstname.lastname@example.org.
In case the data subject is of the opinion that the Company has been in breach of the provisions under GDPR, the data subject has the right to file a complaint to the competent authority. In Sweden this is Datainspektionen (www.datainspektionen.se) and in Norway Datatillsynet (www.datatillsynet.no).
In order to always improve its services, the Company stores information about how users navigate the website. The purpose of this is to track which pages on the website that users find the most interesting, so that these pages can be easier to access in the future.
If you do not want to accept a cookie you can use your in-built browser or device settings to deny or accept specific or all cookies. Previously stored cookies can also be deleted in your web browser. However, please be aware this may impact the website access.
You can find more information about cookies on website on Kommunikationsmyndigheten Post- och telestyrelsen (PTS). If you have any further question with regards to the Company’s usage of cookies, please send an email to email@example.com.
Processors and other recipients of the personal data
The Company may use processors to store and process personal data on behalf of the Company. This mainly concerns the processing of data through IT-solutions, cloud services, CRM-system etc. Where the processing is to be carried out on behalf of the Company, the Company only uses processors providing sufficient guarantees to implement appropriate technical and organisational measures in such a manner that the processing will meet the requirements of the GDPR and ensure the protection of the rights of the data subject.
The Company may also share/transfer the personal data to recipients if necessary and in accordance with applicable laws and regulations.
The Company will not share/transfer any personal data to a third country outside the EU/EES, provided that the Company has not ensured that such country has an adequate protection of personal data.
Security of processing
The Company has in accordance with applicable laws and regulations implemented appropriate technical and organisational measures to ensure a level of security appropriate to the risk of the processing of personal data.
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