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HQ Trust GmbH

PRI reporting framework 2018

You are in Strategy and Governance » Investment policy

Investment policy

SG 01. RI policy and coverage

New selection options have been added to this indicator. Please review your prefilled responses carefully.

01.1. Indicate if you have an investment policy that covers your responsible investment approach.

SG 02. Publicly available RI policy or guidance documents (Not Applicable)

SG 03. Conflicts of interest

03.1. Indicate if your organisation has a policy on managing potential conflicts of interest in the investment process.

03.2. Describe your policy on managing potential conflicts of interest in the investment process.

In order to prevent extraneous interests affecting the services of HQ Trust, we have committed ourselves and our employees to high ethical standards and to compliance with the regulations of the WpHG and its supplementary provisions, together with our internal Compliance Guidelines and staff Code of Conduct. HQ Trust employees are carefully selected, and they are expected at all times to act lawfully and professionally, and in particular to safeguard the interests of clients.

The Compliance Officer is responsible for identifying, avoiding and managing conflicts of interest at HQ Trust. The Compliance Officer conducts regular analyses of potential conflicts of interest, specifies measures to counter them and monitors compliance with these. Employees are regularly notified by the Compliance Officer of significant changes in statutory and internal provisions governing the conduct of investment services.

Other individual measures that are taken include the following:

-Employee transactions in financial instruments with the potential for conflicts of interest are not permitted (monitored by the Compliance Officer).

-Internal allocation principles are specified where client orders are aggregated, and compliance is monitored by the Compliance Officer.

-No profit-related remuneration for the referral or recommendation of individual products.


03.3. Additional information. [Optional]

SG 04. Identifying incidents occurring within portfolios (Private)