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: email@example.com
or by post:
LRI Invest S.A. 9A,
Rue Gabriel Lippmann
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 or the LRI Invest S.A. Complaints Officer.
You can reach the Complaints Officer:
LRI Invest S.A. Complaints Officer 9A,
Rue Gabriel Lippmann
by email: firstname.lastname@example.org
by fax: (+352) 42 74 54
We have set ourselves high standards in the resolution of complaints. Within 10 business days following receipt of your complaint, you will receive an initial response and relevant information about what happens next and the time needed for processing.
As a second step, if you are unsatisfied with the response, you may write to the responsible member of the management board for complaints, Mr Thomas Grünewald.
If you do not receive a satisfactory response within a month, you will have the third step of using the out-of-court resolution procedure for appeals to the CSSF (CSSF Regulation 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:
Commission de Surveillance du Secteur Financier Département Juridique II
110, route d’Arlon
by email: email@example.com
by fax: (+352) 26 25 1 - 601
We are not obliged to participate in dispute resolution proceedings before a consumer arbitration board within the meaning of § 36, para. 1 Consumer Dispute Resolution Act.
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: firstname.lastname@example.org
or by post:
LRI Invest S.A.
9A, Rue Gabriel Lippmann
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.
Voting rights policy
Reference to dispute settlement procedures and the Ombudsman Office for members
Sub-custodian of the Depositary
European Depositary Bank – http://www.europeandepositarybank.com/de/
Hauck & Aufhäuser – https://www.hauck-aufhaeuser.com/fileadmin/Impressum/List_of_Sub-Custodians_Hauck___Aufhaeuser_April_2020.pdf
Caceis - https://www.caceis.com/de/ueber-uns/compliance/
Royal Bank of Canada – https://www.rbcits.com/en/who-we-are/governance/privacy.page
Credit Suisse – https://www.credit-suisse.com/about-us/en/our-company/our-governance.html