If incentives are paid or given to - or paid by - a third party, the fee/commission or benefit in kind must be designed to increase the quality of the fund operation/service concerned. It must also not prevent the Fund Management Company from acting in the interests of unitholders/customers.Below you will find information about the forms of incentives that occur in the Fund Management Company’s activities.

Swedbank Robur Fonder AB’s remuneration policy and regulations (IPAM) are designed with the aim of promoting sound and effective risk management and counteracting risk-taking that is incompatible with Robur’s funds’ risk profile and fund regulations. The remuneration policy and its application are further designed so that Robur can fulfil its obligation to act in the interests of the fund unitholders

IPAM is Robur’s discretionary variable compensation program based on quantitative (financial) and qualitative (non-financial) criteria. The purpose of IPAM is to encourage employees (or fund managers) to make extraordinary efforts for the benefit of Robur’s unitholders. When assessing the employee’s (or fund managers') performance, both financial (quantitative) and non-financial (qualitative) criteria must be taken into account. Variable remuneration is only paid if quantitative return targets or qualitative targets relating to the Fund’s long-term sustainable strategic move are met. According to Robur, a sustainable strategic move is a prerequisite for achieving a long-term financially sustainable return. This means that maximum return cannot be generated without taking into account both the return targets and the sustainability targets

Remuneration Policy (pdf)

Information on what forms of incentives exist

Investments in other funds

If the Fund invests in funds managed by the Management Company, the Fund is compensated for the fixed management fee and any performance-based fee in the underlying fund. When the Management Company’s so-called fund-in-funds invest in funds managed by other managers (external managers), the fund is compensated for the fee that the respective external manager defines as the fixed management fee in the underlying fund (often referred to as “management fee”). The Management Company has entered into agreements with certain external managers that the Management Company shall receive a certain proportion of the fixed management fees that amount to the investments made by the Funds in the external managers’ funds. As a result, the Fund Management Company receives compensation for part of the management fees that the Fund Management Company reimburses the Fund for.

Dealerships

The Fund Management Company uses distributors for the distribution of the Fund Management Company’s funds. These distributors receive brokerage fees in accordance with a distribution agreement entered into with the Fund Management Company. The fee is calculated as a percentage of the management fee and amounts to between 10 and 90 per cent of this fee.

As a customer, you only pay management fees to the Fund Management Company according to the percentage stated in the information brochure for each fund. The compensation received by the Distributor will not incur any additional cost for you. When a customer acquires a fund through Swedbank AB or the Savings Banks, the customer is informed of the incentives described above. When a customer acquires the Fund Management Company’s funds through an external distributor from the Swedbank Group, this distributor has, in accordance with the distribution agreement and the law, to independently report the incentives the distributor receives from the Fund Management Company.

Discretionary Portfolio Management

Swedbank Robur provides discretionary portfolio management and is not permitted by law to receive and retain remuneration from anyone other than the customer within the framework of the investment service, with the exception of certain minor non-monetary remuneration, see below.

Minor non-monetary benefits

In addition to what has been informed above, Swedbank Robur may receive minor non-monetary remuneration from a third party when providing discretionary portfolio management, which is designed to improve the quality of the service concerned and which does not prevent the Management Company from protecting the interests of its customers. Such minor non-monetary remuneration may, as follows from the Swedish Financial Supervisory Authority’s regulations, be, for example, documentation about financial instruments or investment services that are of a general nature or adapted to a customer’s circumstances, participation in conferences, seminars and other information events concerning the characteristics of financial instruments or certain investment services, and entertainment up to a reasonable value.

Additional information

Further information on incentives can be obtained from your contact person or Compliance at Swedbank Robur Fonder AB.

The starting point is that all errors must be corrected and that the fund management company must compensate the fund and unitholders so that they are placed in the same situation as if the error had never occurred. Compensation to unitholders is paid in the form of new units in the fund and provided that the compensation exceeds SEK 100.

However, in order for compensation to be paid, an assessment is always made by the fund management company if the error is considered to be material. In the event of material errors, the Fund and the unitholders must always be compensated if they have been adversely affected. Errors in the fund unit value that occur as a result of the fund management company’s breach of its obligations, such as incorrect calculation of fees or investment of the fund’s funds in violation of law or fund regulations, must always be considered material.

In assessing whether errors other than those mentioned above are material or not, account shall be taken of how large the price fluctuations (volatility) are normally in the fund. The smaller the fluctuations in the fund’s unit value, the smaller the errors should be considered material. The tolerance levels for how large the errors are to be considered material are based on the Fund’s risk category (scale 1-7). The fund’s risk category is stated in the fund’s fact sheet and reflects the fund’s sensitivity to price fluctuations in the market. Normally, an equity fund has a higher risk category and therefore higher volatility than, for example, a fixed income fund, which results in a higher tolerance level.