Information.
for Investors.

The 1741 Group has established a process to meet the requirements of Best Execution and Broker Selection, so that the best possible results can be achieved when trading financial instruments.

This is on the one hand due to the legal regulatory requirements in Switzerland and in the EU / EEA region, but especially in the particular interest of investors in the investment funds managed by the 1741 Group. Whenever the 1741 Group is referred to below, this refers to each of the companies belonging to the Group which manage investment funds.

As the 1741 Group has partially delegated investment management to approved and supervised portfolio managers, it is contractually committed to ensure that its delegates comply with the requirements of this policy.

Basically, the 1741 Group, or its delegates, considers the following factors to achieve the best possible result of a transaction:

• Price
• Costs
• Speed ​​and probability of execution and settlement
• Scope and nature of the contract
• Other factors relevant to the execution

The weighting of these factors depends on the relative importance that the 1741 Group or its delegates attach to these factors in a transaction. The following criteria are decisive:

• Objectives, investment policy and specific risks regarding assets
• Order characteristics
• Asset characteristics
• Stock exchange characteristics to which the order will be placed to

When selecting the stock exchange, the execution venue is selected that will allow the best possible execution based on the above criteria.

The 1741 Group regularly monitors the effectiveness of this policy in order to detect any defects and to rectify them immediately.

1741 Group, 01.11.2023

In accordance with the law, the 1741 Group must disclose unavoidable conflicts of interest to investors in an investment fund and inform investors about the precautions and measures for dealing with conflicts of interest.

This is on the one hand due to the legal regulatory requirements in Switzerland and in the EU / EEA region, but especially in the particular interest of investors in the investment funds managed by the 1741 Group. Whenever the 1741 Group is referred to below, this refers to each of the companies belonging to the Group which manage investment funds.

Conflicts of interest relevant to the 1741 Group may inter alia occur between:

• the companies of the 1741 Group
• an employee and a customer of the 1741 group
• two or more customers
• an employee and the 1741 group
• two or more employees
• the 1741 group and a supplier

Conflicts of interest may arise in particular:

• in asset management for its own (sales) interest in the sale of financial instruments, in particular the Group’s own products
• upon receipt or guarantee of donations from or to third parties
• through a performance-related remuneration of employees
• in guaranteeing benefits to our employees
• by obtaining information that is not publicly known
• from personal relationships of our employees or the management or persons associated with them or
• in the participation of such persons in supervisory or advisory boards

In order to prevent non-relevant interests from influencing, for example, advice, order execution, asset management or financial analysis, the 1741 Group has committed itself to the highest ethical standards. The 1741 Group expects from all its persons involved at all times diligence and honesty, lawful and professional action, the observance of market standards, and in particular always the consideration of the customer’s interest.

The 1741 Group specifically takes the following measures to avoid conflicts of interest:

• Creation of organisational procedures and processes
• Arrangements for the acceptance and granting of benefits and their disclosure
• Creation of areas of confidentiality by setting up information barriers, separation of responsibilities and/or territorial separation
• Maintaining an insider or watch list to monitor sensitive information and prevent misuse of insider information
• Disclosure of securities transactions of such employees with the Compliance Agent where conflicts of interest may arise in the course of their activities
• Training of employees
• Ongoing monitoring and reporting of identified compliance conflicts

The 1741 Group regularly monitors the effectiveness of this policy in order to detect any defects and to rectify them immediately.

1741 Group, 01.01.2024

The 1741 Group has established an effective voting strategy adapted to the respective business model. This is on the one hand due to the legal regulatory requirements in Switzerland and in the EU / EEA region, but especially in the particular interest of investors in the investment funds managed by the 1741 Group. Whenever the 1741 Group is referred to below, this refers to each of the companies belonging to the Group which manage investment funds.

The 1741 Group always acts in the best interests of investors when exercising voting rights for the investment funds it manages. The following measures are implemented:

The 1741 Group actively pursues all relevant corporate events and agenda items with regard to the portfolios it manages. This measure ensures that all relevant events, such as general meetings on topics such as share capital changes, compensation programmes, etc., ensure that the interests of investors are exercised in accordance with the investment objectives and investment policy of the investment fund concerned.

The effective exercise of voting rights will normally only take place in those cases where the 1741 Group could exercise more than 5% of the voting capital of a company held on behalf of the funds it manages. However, the exercise is reserved in those cases in which this would correspond to the best interests of the investors.

Any conflicts of interest in connection with the exercise of voting rights are prevented as far as possible, otherwise disclosed.

If the 1741 Group has delegated the investment decisions to an external asset manager, it may make its recommendations regarding voting behaviour, even if the above threshold of 5% is not exceeded.

At the same time, the 1741 Group contractually informs its asset managers that they are authorised but not required to exercise the voting rights resulting from the investments. The 1741 Group also reserves the right to exercise such rights itself. If the asset manager wishes to exercise voting rights himself, he informs the 1741 Group in advance.

The 1741 Group regularly monitors the effectiveness of this policy in order to detect any defects and to rectify them immediately.

1741 Group, 01.11.2023

Participation Policy 1741 Fund Management AG 

1741 Fund Management AG, Vaduz, (hereinafter “1741 FM”) as part of the 1741 Group falls under the term “asset manager” according to Art. 367a No. 3 of the Liechtenstein Persons and Companies Act (PGR) and therefore has to describe its participation policy in terms of Art. 367h PGR.

1741 FM does not exercise any shareholder rights within the meaning of Art. 367h para. 1 items 1 and 4 PGR which are based on participation in corporations in which 1741 Fund Management AG has invested within the framework of asset management mandates. In particular, no rights related to the general meetings of stock corporations are exercised. The right to a share in profits as well as to subscription rights are pursued in consultation with the clients.

The monitoring of important matters of the companies within the meaning of Art. 367h para. 1 item 2 PGR is carried out by taking note of the legally required reporting of the companies in financial reports as well as ad hoc announcements.

There is no exchange of opinions with the corporate bodies and stakeholders of the companies within the meaning of Art. 367h para. 1 item 3 PGR.

There is no cooperation with other shareholders within the meaning of Art. 367h para. 1 items 5 and 6 PGR.

In the event of conflicts of interest within the meaning of Art. 367h para. 1 no. 7 PGR, disclosure is made to the parties concerned in accordance with the statutory provisions and clarification of the further course of action with them is provided.

An annual publication on the implementation of the participation policy within the meaning of Art. 367h Para. 1 No. 2 PGR does not take place, because a corresponding exercise of rights does not take place.

There is no publication of voting behavior within the meaning of Art. 367h para. 1 item 3 PGR, because there is no participation in voting.

Vaduz, 01.11.2023

In accordance with the currently applicable legal and regulatory requirements, the 1741 Group has defined principles for its remuneration system that are compatible with and supportive of a sound and effective risk management system. The 1741 Group thus fulfils the regulatory requirements in Switzerland, the EU and the EEA as well as the special interests of investors. When the 1741 Group is referred to below, this refers to the companies belonging to the Group that manage investment funds.

Remuneration decisions are generally taken by the company’s Management Board. Decisions on the remuneration of the Management Board itself are made by the Board of Directors. Due to the size of the company and based on the principle of proportionality, a remuneration committee is not appointed.

To implement the remuneration principles, the 1741 Group has issued internal regulations aimed at achieving a balanced relationship between fixed and any variable remuneration components in the remuneration of its own employees. The main purpose of this guideline is to find a reasonable remuneration basis for its own employees without motivating them to take increased risks.

The 1741 Group identifies the relevant employee categories that are subject to the requirements of the remuneration guidelines (“identified employees”). Identified employees are managers, risk takers, employees in control functions and other employees who receive total remuneration that is in the same income range as that of managers and risk takers and whose professional activities have a material influence on the risk profile of the company or the funds under management.

Employee remuneration can include both fixed and variable components as well as monetary and non-monetary fringe benefits, whereby the variable remuneration is merely a supplement to the fixed remuneration and therefore does not incentivise the taking of inappropriate risks. The elements are measured in accordance with market practice and appropriateness. When determining the components, it is ensured that there is no significant dependency on the variable remuneration on the one hand and an appropriate ratio of variable to fixed remuneration on the other. The aim is to have a flexible remuneration policy that can also provide for the variable component to be waived.

The performance measurement of individual employees is based on qualitative and quantitative indicators, with a focus on sustainable business development and protecting the 1741 Group from excessive risks. Due to the principle of proportionality, variable remuneration typically comprises an annual bonus, which is paid out after the end of the performance year. The total variable remuneration to be provided company-wide depends on the company’s business performance and risk position and therefore fluctuates from year to year.

The remuneration policy supports the appropriate management of all relevant business risks, including through the inclusion of sustainability risks as defined in the Disclosure Regulation. The sustainability risks reflect the relevant environmental, social and governance aspects as well as the main material negative impacts and are defined in such a way that the remuneration structure does not encourage excessive risk-taking in relation to direct or indirect sustainability risks.

The remuneration principles are reviewed at least once a year and adjusted if necessary in order to ensure that the statutory and regulatory requirements are met.

1741 Group, 15.12.2023