Best Execution Policy
Fondsfinans Kapitalforvaltning (FFKF) is a mutual fund management company that manages Fondsfinans funds. This means that FFKF makes investment decisions and implements these on behalf of the mutual funds. These guidelines provide an overview of how and where investment decisions are to be made in order to achieve the best possible results for unitholders.
Assessment of the best result when making investment decisions
FFKF will take all reasonable steps to achieve the best possible result for the mutual funds in terms of price, costs, speed, probability of execution and settlement, size, nature and other relevant factors. To determine the relative weight of these factors, the following criteria will be considered:
• the fund’s objectives, investment policy and risks as set out in the prospectus and, if applicable, articles of association
• the nature of the order
• characteristics of the financial instruments included in the order
• characteristics of the trading systems in which the order can be placed
In general, FFKF will place the most emphasis on:
All FFKF mutual funds aim to achieve the best possible risk-adjusted return for unitholders. The price achieved when trading in financial instruments is therefore essential when assessing best workmanship.
The transaction costs of trading in financial instruments affect the fund’s return and will be given weight when assessing best performance.
When selling larger items, it may in some cases be in the interests of unitholders to accept a higher cost or worse price in order to complete the transaction within a reasonable time.
Characteristics of the financial instruments included in the order
In some less liquid securities, FFKF may choose a more expensive form of transaction in order to achieve the best execution.
Assessment of the best result when placing orders
Once FFKF has made an investment decision, trading in securities must always be carried out by a broker who is on the list of approved broker connections. The brokers on the list are selected, among other things, on the basis of:
• Ethical conduct
• Transaction costs
The list of approved broker connections is approved annually by the Board of Directors of FFKF.
The CEO is responsible for ensuring that spot checks are carried out to ensure that the best results have been achieved for trades that have been completed. The results of the surveys are reported to Compliance, which logs the results.
Remuneration schemes in Fondsfinans Kapitalforvaltning AS
The Board of Directors of Fondsfinans Kapitalforvaltning AS (“Fondsfinans”) has adopted a remuneration scheme for the company’s employees and employee representatives. The remuneration scheme is in accordance with Regulation No. 1467 of 21 December 2011 to the Securities Trading Act and will be reviewed by the Board of Directors at least once a year. The remuneration system is designed to take sustainability risk into account and that risk-taking that is incompatible with the risk profile, articles of association or other memorandum of association for funds under management is not encouraged.
Fondsfinans aims to have competitive pay and employment conditions, without being a wage leader. Fixed salaries for senior executives, employees with tasks of significant importance for the risk exposure of the management company or funds under management, as well as employees with control tasks, shall be sufficiently high for the enterprise to fail to pay the variable remuneration.
Variable remuneration is based on a combination of the assessment of the person concerned and the performance of the relevant business unit, funds under management and the management company as a whole, over a period of at least two years. At least 40% of variable remuneration shall consist of shares in funds managed by Fondsfinans Kapitalforvaltning AS.
For employees in Fondsfinans Kapitalforvaltning, at least 40% of the variable remuneration is paid evenly over a period of at least three years. As a general rule, the total variable remuneration shall be substantially reduced or eliminated if the financial performance of the management company or fund is weak or negative.
Board members only receive fixed remuneration.
For 2021, employees of Fondsfinans Kapitalforvaltning AS received a total of NOK 29,064,110 in remuneration divided among a total of 18 employees.