As Luxemburg Management Company and AIFM we are regulated by the Luxembourg financial authority Commission de Surveillance du Secteur Financier (CSSF).
LRI Invest S.A. acts as Super Management Company (Super ManCo) being authorised as Alternative Investment Fund Manager (AIFM) and UCITS Management Company in Luxembourg.
Our governance rules cover the exercise of equity voting rights in the interests of investors, dealing with complaints, avoiding conflicts of interest and optimal order execution.
As member of Association of the Luxembourg Fund Industry (ALFI) we also subscribe to the ALFI Guidelines and Recommendations such as the Code of Conduct for Luxembourg Investment Funds.
Best execution policy
LRI Invest S.A. introduced principles to execute customer orders which are subject to regular reviews and updated if necessary. The decision regarding how to use trade orders depends on a number of factors. The price of the asset is one of the key factors in taking a decision, but not the sole criterion. Other criteria may be the cost of executing the order, the speed and/or the likelihood of execution or processing. If you would like more detailed information about the principles used for the execution of customer orders, please write to: info@lri-invest.lu
or by post:
LRI Invest S.A. 9A,
Rue Gabriel Lippmann
L-5365 Munsbach.
Best execution policy (129.39 kB, PDF)
Complaints policy
Customer satisfaction is very important to us.
We at LRI Invest S.A. feel ourselves obliged to provide our services in the interests of and to the full satisfaction of our clients and investors.
If you should find yourself nonetheless dissatisfied for any reason, please contact in the first instance your personal relationship manager of LRI Invest S.A, or LRI Invest S.A. Compliance Department
You can reach LRI Invest S.A.:
by post:
LRI Invest S.A.
Compliance Department
9A, rue Gabriel Lippmann
L-5365 Munsbach
by email: compliance-department@fundrock-lri.com
We have set ourselves high standards in the resolution of complaints. Within 3 business days following receipt of your complaint, you will receive a response. In case the processing of your complaint due to high complexity or other circumstances takes longer than three bank working days, you will receive within three bank working days an interim notification on the status of processing as well as, continually until remedy of the complaint, a regular, at least weekly notification of the current status of processing.
If you do not receive a satisfactory response we hereby inform you about the possibility of using the out-of-court dispute resolution procedure for appeals to the CSSF (Regulation CSSF No. 16-07). Please note that the application must be submitted to the CSSF within a period of one year from the date an appeal was lodged with our relevant board. If the time limit passes, the request is inadmissible.
CSSF contact information:
by post:
Commission de Surveillance du Secteur Financier
Legal Department & Consumer Protection/Financial Crime,
283, route d’Arlon,
L-1150 Luxembourg
by email: reclamation@cssf.lu
Complaints Policy (103.98 kB, PDF)
Conflicts of interest policy
LRI Invest S.A. introduced principles to deal with conflicts of interest which are subject to regular reviews regarding their relevancy and updated if necessary. Client interests always take precedence over those of the company. If you would like more detailed information about how our company deals with conflicts of interest, please write to: info@lri-invest.lu
or by post:
LRI Invest S.A.
9A, Rue Gabriel Lippmann
L-5365 Munsbach
Conflicts of Interest Policy (134.15 kB, PDF)
Voting rights policy
Voting Rights Policy (72.51 kB, PDF)
Shareholder Rights Directive II - Engagement Policy
Engagement Policy (114.00 kB, PDF)
Reference to dispute settlement procedures and the Ombudsman Office for members
Reference to dispute settlement procedures and the Ombudsman Office for members (22.18 kB, PDF)
Sub-custodians of the respective Depositary
European Depositary Bank – https://www.europeandepositarybank.com/en/custody/list-of-sub-custodians/
Hauck & Aufhäuser – https://www.hal-privatbank.com/en/imprint
Caceis - https://www.caceis.com/de/ueber-uns/compliance/
Royal Bank of Canada –https://www.rbcits.com/assets/rbcits/docs/gmi/appointed-subcustodians.pdf
Credit Suisse – https://www.credit-suisse.com/media/pb/docs/lu/privatebanking/services/list-of-credit-suisse-lux-sub-custodians.pdf
Citi Luxembourg – https://www.citigroup.com/rcs/citigpa/akpublic/storage/public/Luxembourg-list-of-sub-custodians.pdf
ESG / SFDR
Sustainability Risk Policy
Sustainability Risk Policy (234.28 kB, PDF)
Remuneration policy
The remuneration policy plays an important role in the implementation of LRI Invest S.A.'s corporate objectives with regard to sustainable growth prospects and is of central importance for the further development of the employee base and service quality for customers as well as for investor protection. It is also in line with the interests of clients and managed funds.
To the extent that LRI Invest S.A. has outsourced the functions of portfolio or risk management, it ensures that these agents are subject to comparable remuneration policy regulations.
Remuneration Policy (157.61 kB, PDF)
Principal Adverse Impacts (PAI)
No Consideration of adverse impacts of investment decisions on sustainability factors
PAI Policy (239kB, PDF)
PAI Statement (93.78 kB, PDF)
