1. To which laws and regulations is Deutsche Asset Management S.A. subject?
Deutsche Asset Management S.A. is subject to, and complies with, all laws and regulations including the Luxembourg law of 17 December 2010 relating to undertakings for collective investment (the “2010 Law”) and CSSF Regulation No 10-4 implementing Commission Directive 2010/43/EU, each as may be amended from time to time. Deutsche Asset Management S.A. is responsible for ensuring that each of the funds for which it acts as management company is UCITS IV compliant.
In particular, these laws require Deutsche Asset Management S.A. to have in place the following:
• organisational procedures;
• procedures for the management of conflicts of interest; and
• risk management procedures
In addition, Deutsche Asset Management S.A. has ensured and consistently monitors, through a process of due diligence, that all service providers described in the Prospectus meet these requirements to the extent required by the above laws and regulations.
2. What organisational arrangements does Deutsche Asset Management S.A. have in place?
Deutsche Asset Management S.A. is regulated in Luxembourg by the CSSF in the conduct of investment management activities. Pursuant to Article 102(1)(e) of the 2010 Law, the head office of Deutsche Asset Management S.A. is located in Luxembourg at 2, Boulevard Konrad Adenauer, L-1115 Luxembourg, Grand-Duchy of Luxembourg.
Deutsche Asset Management S.A. keeps a detailed record of its internal organisation including the allocation of tasks and hierarchy structure. Deutsche Asset Management S.A. also has detailed agreements with its service providers which outline the delegated tasks and the procedure for the monitoring of, and exchange of information with, each service provider.
Electronic Data Processing
Deutsche Asset Management S.A. utilises electronic systems and procedures which fully safeguard the security, integrity and confidentiality of information held by Deutsche Asset Management S.A.. Data processing is performed by a specialist service provider under the supervision of Deutsche Asset Management S.A..
The accounting function is delegated to the administrative agent described in the Prospectus, subject to the ongoing supervision of Deutsche Asset Management S.A.. Deutsche Asset Management S.A. is at all times able to identify every asset and liability of every fund and deliver financial reports in a timely manner which reflect a true and fair view of their financial positions and which comply with all applicable accounting standards and rules.
Compliance and Internal Audit
Deutsche Asset Management S.A. meets, directly or through its service providers, all compliance and internal audit responsibilities under the relevant laws. In particular, Deutsche Asset Management S.A. employees are subject to a range of Deutsche Asset Management S.A.-specific and Deutsche Bank Group wide policies.
All employees of Deutsche Asset Management S.A. are subject to strict policy restrictions when entering into personal transactions. In particular, the interests of investors in the funds are prioritised at all times.
3. What procedures does Deutsche Asset Management S.A. have in place for managing conflicts of interest?
The potential conflicts of interest arising in the course of Deutsche Asset Management S.A.’s business are set out in the ‘Risk Factors’ section of the Prospectus. Deutsche Asset Management S.A. is subject to a robust internal policy which outlines a series of measures designed to manage these conflicts of interest.
4. What are Deutsche Asset Management S.A.’s risk management processes?
Deutsche Asset Management S.A. uses various risk management tools that are tailored to manage the specific risk profile of each of the funds. Some risk management tools are applied at the development stage of the fund, prior to the fund being launched and distributed. Deutsche Asset Management S.A. uses a comprehensive range of quantitative tools and metrics for monitoring and managing risks. As a matter of policy, Deutsche Asset Management S.A. continually assesses the appropriateness and the reliability of its quantitative tools and metrics in the light of its changing risk environment. Some of these tools are common to a number of risk categories, while others are tailored to the particular features of specific risk categories. Deutsche Asset Management S.A. has delegated, under its own supervision and responsibility, and at its own expense, the risk management and supervision of investment management to the relevant investment manager and fund administrator/custodian named in the Prospectus. The risk control information is reported to Deutsche Asset Management S.A. by these service providers. In addition, each service provider delivers an activity report to the Board of Directors and Deutsche Asset Management S.A. in preparation for each Board meeting, containing internal control and risk management information. The risk controls of the service providers are independent from Deutsche Asset Management S.A..
5. What is the procedure for making complaints to Deutsche Asset Management S.A.?
The process for making a complaint to Deutsche Asset Management S.A. is contained in a document that can be obtained, free of charge, on request from Deutsche Asset Management S.A..
6. How does Deutsche Asset Management S.A. exercise its voting rights?
Deutsche Asset Management S.A.’s policy on the exercise of voting rights is available, free of charge, on request from Deutsche Asset Management S.A..
For the avoidance of doubt, the Board of Directors of the funds remain responsible for exercising the voting rights attached to the instruments held in the funds’ portfolio of assets. Further information may be obtained at the registered office of the relevant fund.
7. What is Deutsche Asset Management S.A.’s best execution policy?
Deutsche Asset Management S.A. always acts in the best interests of the funds it manages when executing decisions to deal or placing orders with third parties for execution.
Deutsche Asset Management S.A. is subject to a best execution policy. Conformity with this policy is monitored on a regular basis and the policy itself is reviewed both annually and whenever a material change occurs. The policy can be obtained from Deutsche Asset Management S.A. on request free of charge.
8. Does Deutsche Asset Management S.A. enter into any soft commission arrangements?
Deutsche Asset Management S.A. does not currently intend to give or receive soft dollar or cash commissions or other rebates to or from brokers or dealers in respect of transactions for the accounts of the funds.
Details of soft commission arrangements will be set out in the annual and semi-annual reports of the relevant fund.
9. What are the procedures Deutsche Asset Management S.A. implements to ensure that its service providers execute their duties under corresponding legal requirements?
The Board of Directors of the funds remains ultimately responsible vis-a-vis investors for the performance of the tasks and duties delegated to its service providers. The relevant procedures are set out in internal documents of Deutsche Asset Management S.A., which have been filed with the CSSF. The contents of these documents are not disclosed to investors in the funds.