INTRODUCTION

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

• Price
• Costs
• Speed
• 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.

OTC PRODUCTS

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.

RESEARCH/INVESTMENT ANALYSIS

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.

INTRODUCTION

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.

Complaints

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.

Norron AB
Jesper Laudon Meyer, Head of Compliance
Tel: +46 (0)73 736 6543
Email: jesper.laudonmeyer@norron.com
Postal address: Box 3054, 103 61 Stockholm

FundRock Management Company S.A.
Email: FRMC_qualitycare@fundrock.com
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)
• Court

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

Disclaimer

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.