AIFM Luxembourg – Our Policies

This section provides information regarding the policies of Alter Domus Management Company S.A. regarding best execution, voting rights, conflicts of interest, complaints handling and remuneration.

Best Execution Policy
When executing transactions on behalf of funds that Alter Domus Management Company S.A. manages (hereafter Client Funds), Alter Domus Management Company S.A. takes all reasonable steps to obtain the best possible results for the Client Funds or the investors in the Client Funds, where applicable. Alter Domus Management Company S.A. takes into account factors such as the characteristics of the order (eg price, costs, speed, order size and nature), the financial instruments subject to the order, the execution venues and the investment policy of the Client Funds. Alter Domus Management Company S.A. monitors and reviews the best execution policy on a regular basis and ensures the effectiveness of its processes, in order to identify and, where appropriate, correct any deficiencies.

Voting Rights Policy
Alter Domus Management Company S.A. applies adequate and effective strategies for determining when and how voting rights attached to securities held in the portfolios of Client Funds. Voting rights are exercised exclusively to the benefit of the Client Funds or the investors of the Client Funds, where applicable. Alter Domus Management Company S.A. monitors corporate events relating to the exercise of voting rights on a regular basis. Issues being voted at shareholder meetings are evaluated on a case by case basis.

Conflict of Interest Policy
Alter Domus Management Company S.A. is committed to investigate and monitor potential conflicts of interest that may arise within Alter Domus Management Company S.A. and within the Client Funds or the investors in the Client Funds, where applicable. Alter Domus Management Company S.A. has set a process whereby potential circumstances of conflicts of interests are monitored, and where necessary disclosed to the Client Funds of the investor of Client Funds, where applicable. A compliance officer of Alter Domus Management Company S.A. is in charge of the above-mentioned duties relating to the conflicts of interest monitoring.

Complaints Handling Policy
Our Complaints Handling Policy can be found here.

Remuneration Policy
Our Remuneration Policy can be found here.

Sustainability Risk Policy
Our sustainability risk policy can be accessed here.