By clicking “Accept All Cookies”, you agree to the storing of cookies on your device to enhance site navigation, analyze site usage, and assist in our marketing efforts. View our Privacy Policy for more information.
PreferencesDenyAccept

Access denied.

Your profile does not have permission to view this content.

Ok

Terms and conditions of use

Please read the IMPORTANT INFORMATION below before proceeding, as it explains certain restrictions on the distribution of information available on this website.

This website - hereinafter the "Site" - is operated by RAM Active Investments S.A. - hereinafter "RAM".

An investment in the RAM funds should only be made after reading carefully the details relating to the sale restrictions that can be found in documents such as Key Investor Information Document (KIID), the management regulations, latest prospectuses, annual and semi-annual reports. These documents can be all be obtained free of charge from the funds' representatives in each country where the funds are incorporated or registered. The latest versions of the prospectus, Key investor information Documents (“KIIDs”), annual report and semi-annual report translated into the language of your country of residence conform with any requirements laid down in the laws or regulations of that country.

The value of investments may be subject to fluctuations and, under certain circumstances, investors may not get back the full amount invested. Past performance is not an indication or guarantee of the future performance of the investment. The performance shown does not take account of any commissions or costs charged when subscribing to or redeeming units. For hedged shareclasses, only the investment fund's consolidation currency is hedged into the shareclass currency. Finally, changes in foreign-exchange rates may also cause the value of investments to go up or down. No information or material at the Site is to be relied upon for the purpose of making or communicating investments or other decision.

No solicitation/sales restrictions

The Site not intended for legal entities or individuals who by virtue of their nationality, registered office, place of residence or for any other reason are governed by a legal system which prohibits or restricts in particular the publication of the content of the Site, access to the Site, the activities of a foreign financial services provider or the approval of products (such as investment funds). 

This prohibition applies in particular to citizens of the United Statesor to persons who are residents of this country. Access to the Site is prohibited for persons subject to any such restrictions.

Other people using the Site accept the following rules. 

This notice and the rules contained in this document are intended for all users of the Site.

The content of this Site is purely informative, and is not aimed at promoting the services of RAM. It is intended to provide general information about the company. No information appearing on this Site shall be deemed as a financial, legal, accounting, tax or investment advice or an offer for services or products, in particular investment funds, from RAM, nor as an offer or the solicitation for a purchase or sale of securities or of any other investment product. Nothing on this Site shall be deemed as a public call nor selling, whatever its form, qualification or denomination nor shall it be construed as a proactive behaviour from RAM towards third parties. Every contact with the Company from third parties must be considered as the latter's sole initiative.

Neither the investment funds nor RAM Active Investments SA provide investment advice to, or receive and transmit orders from, investors in the investment funds. They do not carry on any other activities with or for such investors that constitute "investment services" or "ancillary services" for the purposes of the Markets in Financial Instruments Directive.

Limitation of liability

RAM makes every effort to ensure that the information on this Site is accurate and complete at the time of its inclusion. However, although this information is obtained from sources that are believed to be reliable, RAM does not guarantee, explicitly or implicitly, that it is accurate, reliable, up-to-date or exhaustive. The information and opinions contained in the RAM Site are provided for personal use and informational purposes only and are subject to change at any time without notice. Nothing contained on the RAM Internet Site constitutes investment, legal, tax or other advice nor is to be relied on in making an investment or other decision. Any investment decision should be based on appropriate professional advice specific to the investor's needs. RAM assumes no responsibility for any direct or indirect loss or consequential loss suffered in connection with use of information contained in this Site.

The latest versions of the prospectuses, simplified prospectuses, annual reports and semi-annual reports of the investment funds are the only versions deemed to be official fund publications on which investment decisions may be based.

These documents may be obtained free of charge from the investment fund representative in the countries of domicile of the funds in question or in the countries in which the funds are registered.

Products and services described on this Site may be subject to restrictions for some persons or in some countries. It is incumbent upon interested persons to take all appropriate steps to ensure that they do not solicit RAM for products and services which, due to the laws of their native country, or of any other country they may be concerned with, may be forbidden or require special authorization for such persons or for the company. It is the responsibility of readers of this disclaimer to ascertain that access to this Site is authorized from the country from which he/she is connecting.

Under no circumstances, including but not limited to negligence, shall RAM be liable for any special or consequential damages that may result from the access to or use of, or the inability to access or to use, the materials at the Site.

Use of the Site shall be made subject to the laws of Switzerland, which shall exclusively govern the interpretation, application and effect of all the above conditions of use. The courts of Geneva shall have exclusive jurisdiction over all claims or disputes arising in relation to, out of or in connection with the Site and its use.

Investment funds

This Site contains information on investment funds registered and managed in different jurisdictions. It is your responsibility to ascertain that you are authorised to access to investment funds pages. 

You will be required to indicate your place of residence before being allowed to access information relating to the said investment funds. Please note that access by private investors to the said information shall be limited to the investment funds authorized for sale to the public in their country of residence. Consequently, your access is limited to funds registered for sale in your country of residence.

 The “Investment Funds” pages are not addressed to U.S. Persons. RAM investment funds have not been or will be licensed for marketing, offer or sale to the public in the United States in accordance with the US Investment Company Act of 1940 or the US Securities Act of 1933.

The above-mentioned investment funds must not in any circumstances be offered or distributed: (i) in the United States of America, in any of its States or in any other political subdivision of the United States of America, or (ii) to or on behalf of or for the benefit of any United States Person (as defined in Regulation S of the "United States Securities Act" of 1933).

Singapore

For Singapore investors, the investment funds mentioned in this website are not authorized or recognized by the Monetary Authority of Singapore and are not allowed to be offered to the retail public. They are exclusively intended for (i) institutional investors as defined under Section 304 of the Securities and Futures Act, Singapore Statute Cap. 289 ("SFA"), (ii) to a relevant person pursuant to Section 305(1), or any person pursuant to Section 305(2), and in accordance with the conditions specified in Section 305, of the SFA, or (iii) any other person otherwise pursuant to, and in accordance with the conditions of, any other applicable provision of the SFA.

United Kingdom

All RAM entities are based out of the United Kingdom and therefore not covered by the standards and regulations for investor protection issued by the Financial Conduct Authority. UK residents have no right to claim compensation through the Financial Ombudsman Service following losses resulting from failure to comply with certain obligations arising from the relevant regulations.

Tax

Tax treatment depends on the personal circumstances of the investor and is subject to change. Investors are advised to seek specific professional advice before making any investment decision.

Brands and copyright

RAM Active Investments SA (RAM) and the other RAM Group brands mentioned on the website are registered trademarks or service marks of RAM. Unless otherwise indicated, the entire website is protected by copyright.

‍

Ok
Skip to main content
Investor type

Regulatory Information

Table of Contents

h2
Example H2
h3
Example H3
h4
Example H4
h5
Example H5
h6
Example H6

1. Voting Rights and Shareholders Engagement Policy

The Policy details the general principles applicable for exercising the voting rights attached to the securities held in the CIS managed by Mediobanca Management Company SA and, with respect to securities issued by corporations having their registered office in the European Union (the “EU”) and whose shares are admitted to trading in a regulated market located or operating in the EU.

This Policy is subject to the local governance requirements and shall also take into consideration relevant provisions of the Luxembourg law of 1st August 2019 relating to the exercise of certain shareholder rights at general meetings of listed companies.

Engagement principles: shareholder engagement is generally understood as the active monitoring of companies by shareholders, engaging in a constructive dialogue with the company’s board, and using shareholder rights, including voting, to improve the governance and financial performance of the company. By way of principle, RAM AI considers the exercise of voting rights and shareholder engagement aspects in accordance with the best interest of the relevant CIS and its investors. Recognizing the value of different forms of engagement, RAM AI prioritizes collaborative engagement where possible and combines these engagements with individual engagements. Under these circumstances, RAM will take an active role in collaborative engagement in the form of (co-)leadership. Whilst RAM AI might use such platforms for collaborative engagement, RAM AI will not outsource our engagement responsibilities to third parties. The engagement process is launched whenever RAM is aware that any invested company is object of any relevant adverse media, has breached any key convention and/or has adverse impacts on the sustainability factors monitored by the CIS (the “Triggers”). Engagement may also be part of the environmental or social investment strategy carried out by each CIS.

Breaches to key conventions mainly refer to severe and structural breaches of the principles of the United Nations Global Compact in the areas of human rights, labor, environment and anti-corruption, ILO Declaration on Fundamental Principles and Rights at Work, the United Nations Global Compact, OCDE Guidelines for Multinational Enterprises controversies. The engagement may also result in excluding a company from the investment universe of RAM. However, RAM believes that a constructive dialogue with the companies in which the CIS’ invest is more effective than excluding companies from our investment universe.

When RAM detects any of the above-mentioned Triggers, RAM shall take any of the following 3 approaches:

i) decide to exclude a company from its investment universe;

ii) engage with the company and, depending on the severity of the breach , allowing a temporary regime so that the company takes actions and improves its behavior;

iii) seeking collective engagement.

The RAM Engagement Policy will be reviewed on a regular basis by the firm’s SRI & CSR committee. The CIS’s investors receive full and detailed information on all engagement activities which may be treated as confidential.

Proxy voting principles: RAM AI is committed to active ownership. RAM AI advocates sustainable corporate practices and proper corporate governance, which is essential for long-term shareholder value creation.

RAM AI maintains an adequate and effective strategy for determining when and how voting rights attached to the instruments held in the portfolio of the relevant CIS are to be exercised, to the exclusive benefit of the relevant CIS and its investors. RAM AI shall ensure that no significant influence is exercised through the voting rights attached to instruments held across different portfolios under its ultimate control.

Proxy voting scope: RAM AI has adopted voting guidelines to ensure that proxy votes are casted in the best interest of investors.
RAM AI concentrates its efforts on positions held in a wide proportion in its assets under management and participate efficiently and effectively at shareholders’ meetings of companies in which RAM AI’s collective investment schemes hold a significant proportion of the capital. Voting criteria may evolve as RAM AI is implementing and testing the full integration of the proxy voting process.

Proxy voting guidelines: it is RAM AI’s policy to primarily vote on shareholder proposals following guidance from ESG-favoring voting advisors.
The decision by RAM AI to retain the services of ESG-favoring voting advisor is based principally on the view that the services provided, subject to oversight by RAM AI, generally will result in proxy voting decisions which serve the best sustainable economic interests of the holding and consequently the CIS and its investors.

RAM AI retains the full discretion on the voting process and the casted votes. Indeed, RAM AI may cast votes on holdings inconsistent with the ESG advice if it believes that it is in the best sustainable economic interest of the CIS and its investors. In all cases, RAM AI will retain a written record for the decision to vote.

Proxy voting process: RAM AI has entered into an agreement with an independent service provider, to handle the administrative process of proxy voting execution of securities owned by CIS’ managed by RAM AI.

It should be noted that votes are cast in compliance with the conflicts of interest policy in order to identify, prevent and manage possible conflicts of interest. The votes will be exercised in relation to the shares available at the custodian banks of the managed CIS at the time of the general meeting. If you wish to obtain further information, please make a request by email here.

Annual implementation: RAM AI annually discloses the implementation of the Voting Rights and Shareholder Engagement Policy via its website. Please see the latest voting report here and the engagement report here.

2. Conflict of interest policy

As a general principle, the directors and employees of all RAM group companies must always to act in the best interests of the investors of the RAM Funds. RAM’s policy is to take all reasonable steps to maintain and operate effective organizational and administrative arrangements to identify and manage relevant conflicts. It conducts its business in accordance with the principle that it must manage conflicts of interest fairly, both between itself and the managed Funds (incl. investors) and between one Fund and another (incl. respective investors). The aim is to take all reasonable steps to identify and adequately manage conflicts of interest entailing a material risk of damage to the Funds’ and the Funds’ investors’ interests.

Management is responsible for ensuring the Firm’s systems, controls and procedures are adequate to identify and manage conflicts of interest. The Compliance team assists in the identification and monitoring of actual and potential conflicts of interest. The conflict of interest policy is available on request by clicking here.

3. Best execution policy

The Markets in Financial Instruments Directive (“MiFID”) requires all investment firms when executing orders on behalf of clients to take reasonable steps to obtain the best possible result.

As part of its management of UCITS RAM Active Investments SA (“RAM”) has established and implemented a best execution policy setting out the most important and/or relevant factors that it has put in place to comply with the best execution obligation.

The criteria for best selection of execution venues are set down in this procedure and are continuously reviewed by RAM managers.

RAM selects carefully its counterparties, always seeking to optimise costs and services offered to investors.

As Investment Manager, RAM must take all sufficient steps to obtain the best possible results for the collective investment schemes. This obligation is known as the duty of “best execution” and must take taking into account:

  • price,
  • costs,
  • speed,
  • likelihood of execution and settlement,
  • order, size and nature or any other consideration relevant to order execution.

In determining the relevant importance of each of the above factors, the Investment Manager will take into account the following best execution criteria:

  • the objectives, investment policy and risks specific to the collective investment scheme, as indicated in the prospectus;
  • the characteristics of the order;
  • the characteristics of the financial instruments that are the subject of that order;
  • the characteristics of the execution venues to which the order can be directed.

RAM does not have soft commission agreements with its counterparties.

4. Client complaints handling procedure

We pay a particular attention to our investors’ satisfaction and the protection of their interests holds a high priority for us.

Consequently, and as per applicable regulatory requirements, we have established a quick and simple procedure in order to grant each of our investors with the faculty to contact the Management Team easily, should one of them need or wish to express dissatisfaction as regards the quality and carrying out of the services rendered by RAM Active Investments SA, its employees and/or Funds services providers.

Thus, we invite you to communicate to us free of charge your dissatisfaction and more generally any complaint that you may have by sending an email by clicking here.

You will receive acknowledgement of receipt of your complaint within 2 business days of its receipt by RAM Active Investments SA, and it shall be answered within 5 business days following the receipt date unless your complaint requires deepest investigation, what you would then be informed of without delay. Please kindly note that a complete description of the complaints handling policy of RAM Active Investments SA is available free of charge to investors upon request by using the above-mentioned email address link.

5. Sustainability & ESG Exclusion Policies

As financial market operator, RAM Active Investments SA, is required to publish its sustainability policy following the REGULATION 2019/2088 on sustainability‐related disclosures in the financial services sector. This policy is available here.

‍