INTRODUCTION
Storebrand Asset Management AS is a management company licensed to manage securities funds, undertake individual portfolio management and provide investment advice pursuant to the Securities Funds Act.
When managing the funds, the management company shall always act in the best interests of the securities funds and the client. However, there may be cases where the interests of the funds or the clients may conflict with each other, or cases where a conflict of interest may arise between the management company's employees and the securities funds. The objective of these guidelines is to identify possible conflicts of interest that may arise in the management company's activities and to describe what measures have been taken to prevent or manage these potential conflicts of interest.
The guidelines shall contribute to:
- That the way Storebrand Asset Management AS organizes and conducts all business activities is done in a way that reduces possible conflicts of interest
- To establish sufficient internal control measures to identify and manage possible conflicts of interest
- To manage conflicts of interest in the best interest of customers
These guidelines follow from the "Guidelines for handling conflicts of interest in the Storebrand Group", "Guidelines for handling conflicts of interest in Storebrand Asset Management AS", the Securities Funds Act § 2-15, the Securities Funds Regulations §§ 2-20 to 2-23 and the Securities Trading Act § 10-9.
POLICY STATEMENT
Storebrand Asset Management AS shall conduct its business in accordance with the principle that conflicts of interest must be identified and handled in a responsible manner.
DEFINITIONS
Conflict of interest
Conflicts of interest may arise between Storebrand Asset Management AS, funds managed by the company, external funds, clients/unit owners, between different interests within the Storebrand group, board members and employees. It is important to be aware of conflicts of interest that may arise as a result of the integration of sustainability risk into the management company's business operations, including the conflicts of interest that may arise from a client's sustainability preferences.
CONFLICTS OF INTEREST
Identification and measures for handling conflicts of interest
Specific and potential conflicts of interest that may arise in connection with the management company's operations, as well as the procedures and measures for handling them, are described below.
Potential conflicts of interest in the management of mutual funds
Storebrand Asset Management AS manages the clients' funds and the company's raison d'être is to deliver the best risk-adjusted return to its clients. Storebrand Asset Management AS is a long-term manager and has no incentive to prioritize short-term profit over long-term, trustworthy operations. However, there is a potential conflict of interest inherent in the nature of the business, where persons associated with the management company or the Storebrand Group may prioritize the company's earnings over the long-term interests of the mutual funds and unitholders. In order to avoid such conflicts of interest arising, it is important to ensure independence in a number of functions, and the management company has implemented general measures to achieve this:
- Routines for determining fund prices (NAV) where dedicated employees who are independent of portfolio managers determine the fund prices.
- Pricing is also subject to control by the company's compliance function.
- Each mutual fund must have a custodian. The custodian is a Credit Institution with permission to act as a custodian.
- The custodian shall, among other things, keep the assets of the securities fund or keep them in accounts in a securities register. The custodian shall also perform several checks. These are, among other things, related to whether the dispositions in the funds have been made in accordance with law, regulations and articles of association and whether the unit value is calculated in accordance with law, regulations and the fund's articles of association.
- Routines to prevent insider trading and market manipulation when exercising the management of the securities fund.
- Guidelines and procedures for best execution to ensure that Storebrand Asset Management AS takes all reasonable steps to achieve the best possible result for the unitholders.
- Ethical guidelines to prevent the management company's employees from obtaining benefits at the expense of the company's activities.
Potential conflicts of interest between Storebrand Asset Management AS and the funds it manages
Storebrand Asset Management AS will not normally trade in financial instruments but may exceptionally make certain strategic investments in companies. Before the management company makes such investments, the CEO must demonstrate that the investments do not conflict with the company's obligations under the Securities Funds Act or the Securities Trading Act or otherwise conflict with the funds' interests.
Potential conflicts of interest between the management company's employees and the funds that the company manages
Employees of Storebrand Asset Management AS may trade financial instruments for their own account. This may conflict with the funds' interests, for example where the fund and the employee attempt to buy the same security or where the employee attempts to exploit their knowledge that the fund is going to sell a security to buy it at a lower price.
In order to prevent employees from engaging in securities trading that must be assumed to be contrary to the funds' interests, exploiting information they receive for their own benefit or exploiting their position to obtain special advantages, Storebrand Asset Management AS has drawn up internal rules for employees' proprietary trading. The rules include, among other things, pre-clearance of purchases and sales of financial instruments, prohibitions on trading in the funds, retention periods and restrictions on which intermediaries may be used.
Storebrand Asset Management AS’ employees may from time to time be offered gifts or other benefits from the funds' unitholders, suppliers or others who provide services to the management company or the funds that are managed. To avoid a conflict of interest between the employee's interests and the funds, the company has established internal rules for employees' access to receiving gifts and/or other benefits.
Potential conflicts of interest between the funds under management
In order to avoid conflicts of interest between the various funds, the management company has established comprehensive procedures related to the management of securities funds. The procedures include:
- Registration and logging of orders placed and transactions executed
- If several funds are to buy or sell the same security, the trade must be entered into with the executing investment firm at the same time. If financial instruments are purchased for several portfolios and the order is not fully carried out, the deficit shall be distributed pro rata to each fund.
- The management company may only in special cases execute trades between the funds.
Potential conflicts of interest between different roles/functions in the Storebrand Group
The legal and functional organizational structure within the Storebrand Group may constitute a potential conflict of interest. If such a situation arises, documented measures are implemented. All employees have specific job descriptions and reporting lines. In addition, internal agreements regulate which services the different groups/functions shall provide to which companies in the Storebrand Group.
Handling conflicts of interest
Storebrand Asset Management AS must ensure that the interests of the customers and the integrity of the market are safeguarded in the best possible way.
In areas where conflicts of interest have been identified between customers, between customers and Storebrand Asset Management AS, between different companies and/or business areas in the Group or between different roles/functions, measures must be taken to handle the most significant conflicts of interest in order to secure the customers' interests in the best possible way.
The compliance function in Storebrand Asset Management AS must ensure that management confirms that conflicts of interest are identified, assessed, documented and handled adequately. Objective and documented criteria must be used to the greatest extent possible when managing conflicts of interest.
The company must regularly assess whether the management of identified conflicts of interest is adequate. The assessment by management will be presented to the board of directors at least annually.