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AS Avaron Asset Management

PRI reporting framework 2019

Asset class implementation gateway indicators [OO 10 - 12] Peering questions [OO LE 01 - HF 01]

Investment policy [SG 01 - 04] Objectives and strategies [SG 05 - 06] Governance and human resources [SG 07 - 08] Promoting responsible investment [SG 09 - 11] Outsourcing to fiduciary managers and investment consultants [SG 12] ESG issues in asset allocation [SG 13 - 15] Asset class implementation not reported in other modules [SG 16 - 17] Innovation [SG 18] Communication [SG 19]

Direct - Listed Equity Incorporation

ESG incorporation in actively managed listed equities [LEI 01 - 10] Implementation processes [LEI 01 - 10] (A) Implementation: Screening [LEI 04 - 06] (C) Implementation: Integration of ESG factors [LEI 08 - 10] Outputs and outcomes [LEI 12 - 13]

Direct - Listed Equity Active Ownership

Overview [LEA 01] Engagement [LEA 02 - 08] Outputs and outcomes [LEA 09 - 11] (Proxy) voting and shareholder resolutions [LEA 12 - 21]

Confidence building measures

Confidence building measures [CM1 01 - 07]

Export Public Responses

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Basic information

OO 01. Signatory category and services

01.1. Select the services and funds you offer

Select the services and funds you offer	% of asset under management (AUM) in ranges
Fund management	0% <10% 10-50% >50%
Fund of funds, manager of managers, sub-advised products	0% <10% 10-50% >50%
Other	0% <10% 10-50% >50%
Total 100%

Further options (may be selected in addition to the above)

Hedge funds

Fund of hedge funds

01.2. Additional information. [Optional]

Avaron Asset Management is a fund management company established in 2007. Avaron holds a license from the Estonian Financial Supervision Authority to manage investment portfolios and funds, and is also a registered Investment Advisor with the US Securities and Exchange Commission. The Company manages UCITS funds and institutional investors’ managed accounts investing in listed equities in Emerging Europe region.

OO 02. Headquarters and operational countries

02.1. Select the location of your organisation’s headquarters.

Estonia

02.2. Indicate the number of countries in which you have offices (including your headquarters).

2-5

6-10

>10

02.3. Indicate the approximate number of staff in your organisation in full-time equivalents (FTE).

19 FTE

02.4. Additional information. [Optional]

Avaron is headquartered in Tallinn, Estonia. As of end-2018 Avaron employed 20 people (2017: 17) of which 65% were male and 35% female. The average tenure of our staff was 5.0 years, similar among male and female employees.

OO 03. Subsidiaries that are separate PRI signatories

03.1. Indicate whether you have subsidiaries within your organisation that are also PRI signatories in their own right.

Yes

03.3. Additional information. [Optional]

OO 04. Reporting year and AUM

04.1. Indicate the year end date for your reporting year.

31/12/2018

04.2. Indicate your total AUM at the end of your reporting year.

Include the AUM of subsidiaries, but exclude advisory/execution only assets, and exclude the assets of your PRI signatory subsidiaries that you have chosen not to report on in OO 03.2

Total AUM
Total AUM	trillions	billions	millions	thousands	hundreds
Currency
Assets in USD
Assets in USD	trillions	billions	millions	thousands	hundreds

Not applicable as we are in the fund-raising process

04.4. Indicate the total assets at the end of your reporting year subject to an execution and/or advisory approach.

Not applicable as we do not have any assets under execution and/or advisory approach

04.5. Additional information. [Optional]

As of end 2018 Avaron managed 386 million euros, out of which the core Emerging Europe listed equity strategy accounted for 376 million euros. Fixed income investments accounted for 1% of the total assets under management. The Company manages two mutual funds domiciled in Estonia, which are open to any investor that has a European bank account. Avaron Emerging Europe Fund (AUM €61M) is focused solely on Emerging Europe ex-Russia listed equities (UCITS V). Avaron Flexible Strategies Fund (AUM €10M) is an asset allocation fund combining predominantly Emerging Europe cum-Russia listed equities, fixed income and money market instruments but based on fund prospectus can invest globally (non-UCITS).

In addition to the Estonian domiciled mutual funds, Avaron provides sub-investment management services to third party funds and managed accounts. Investment management services to professional investors in the form of third party funds and managed accounts have been an increasing business line for the Company over the years and accounts now for more than 80% of the assets under management. The total size of institutional investors’ mandates in the end of 2018 was 310 million euros. Besides that Avaron also manages 5 million euros worth of portfolios for high net worth individuals.

OO 06. How would you like to disclose your asset class mix

06.1. Select how you would like to disclose your asset class mix.

as percentage breakdown

	Internally managed (%)	Externally managed (%)
Listed equity	>50% 84	0 0
Fixed income	<10% 1	0 0
Private equity	0 0	0 0
Property	0 0	0 0
Infrastructure	0 0	0 0
Commodities	0 0	0 0
Hedge funds	0 0	0 0
Fund of hedge funds	0 0	0 0
Forestry	0 0	0 0
Farmland	0 0	0 0
Inclusive finance	0 0	0 0
Cash	10-50% 15	0 0
Money market instruments	0 0	0 0
Other (1), specify	0 0	0 0
Other (2), specify	0 0	0 0

as broad ranges

06.2. Publish asset class mix as per attached image [Optional].

06.3. Indicate whether your organisation has any off-balance sheet assets [Optional].

Yes

06.5. Indicate whether your organisation uses fiduciary managers.

Yes, we use a fiduciary manager and our response to OO 5.1 is reflective of their management of our assets.

No, we do not use fiduciary managers.

06.6. Provide contextual information on your AUM asset class split. [Optional]

OO 07. Fixed income AUM breakdown

07.1. Provide to the nearest 5% the percentage breakdown of your Fixed Income AUM at the end of your reporting year, using the following categories.

Internally managed

0 SSA

58 Corporate (financial)

42 Corporate (non-financial)

0 Securitised

Total 100%

OO 08. Segregated mandates or pooled funds (Not Applicable)

OO 09. Breakdown of AUM by market

09.1. Indicate the breakdown of your organisation’s AUM by market.

20 Developed Markets

48 Emerging Markets

32 Frontier Markets

0 Other Markets

Total 100% 100%

09.2. Additional information. [Optional]

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