Compliance 

Stefnir is required to establish a compliance function and shall ensure that it is effective and independent of other aspects of operations. The role of Compliance is to ensure that the company’s operations comply with the laws and regulations on the securities markets. 

Compliance's areas of responsibility include the following:

• Implementation and monitoring of policy on conflicts of interest.
• Implementation and monitoring of rules on business transactions by employees.
• Training and advice to employees and senior management concerning the company’s obligations on the securities market.
• Other tasks, e.g. reporting to and liaison with the authorities. 

Policy on conflicts of interest

In accordance with Regulations No. 471/2014 on the organizational requirements for management companies of UCITS and Article 15 of the Securities Transactions Act No. 116/2021 Stefnir hf. has established a policy on conflicts of interest. The policy has been established following an analysis of the company's operations and the roles that its employees carry out.

In the course of the company’s activities different parties will naturally have different interests. There is inevitably the inherent risk that this will lead to a conflict of interests when the interests of one or more party overlap with the interests of another. It is the company’s policy to take all available measures to prevent conflicts of interest from adversely affecting the interests of its clients.

Employees of the company are required to work with the interests of the clients in mind at all times and to ensure that they do not show preference for the interests of one group over those of another. By doing this the clients can be sure that the interests of Stefnir, related parties, employees and other clients do not have a negative impact on the company's protection of their interests.

Conflicts of interest in the company’s operations chiefly occur in the following circumstances: Between Stefnir and the company’s clients, between an employee of the company and clients, between the clients of the company – including two or more funds – and between unit holders.

There are numerous ways to prevent conflicts of interest from adversely affecting the interests of clients. If available measures are inadequate to ensure that interests of clients are sufficiently protected, the client in question must be informed of the circumstances and told what measures will subsequently be taken.

The implementation of the policy on conflicts of interest is the responsibility of the company which shall keep a record of conflicts of interest occurring in the course of activities and the measures subsequently taken. The compliance officer will provide a report annually, or more often if deemed necessary, to the company’s board of directors on how the policy has been implemented. 

This text summarizes the main aspects of the company's policy on conflicts of interest. All further information can be obtained from the company.