1. To which laws and regulations is DWS Investment S.A. subject?
DWS Investment 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. DWS Investment 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 DWS Investment S.A. to have in place the following:
- organisational procedures;
- procedures for the management of conflicts of interest; and
- risk management procedures
In addition, DWS Investment 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 DWS Investment S.A. have in place?
DWS Investment 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 DWS Investment S.A. is located in Luxembourg at 2, Boulevard Konrad Adenauer, L-1115 Luxembourg, Grand-Duchy of Luxembourg.
DWS Investment S.A. keeps a detailed record of its internal organisation including the allocation of tasks and hierarchy structure. DWS Investment 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
DWS Investment S.A. utilises electronic systems and procedures which fully safeguard the security, integrity and confidentiality of information held by DWS Investment S.A.. Data processing is performed by a specialist service provider under the supervision of DWS Investment S.A..
Accounting Procedures
The accounting function is delegated to the administrative agent described in the Prospectus, subject to the ongoing supervision of DWS Investment S.A.. DWS Investment 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
DWS Investment S.A. meets, directly or through its service providers, all compliance and internal audit responsibilities under the relevant laws. In particular, DWS Investment S.A. employees are subject to a range of DWS Investment S.A.-specific and Deutsche Bank Group wide policies.
Personal Transactions
All employees of DWS Investment 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 DWS Investment S.A. have in place for managing conflicts of interest?
The potential conflicts of interest arising in the course of DWS Investment S.A.’s business are set out in the ‘Risk Factors’ section of the Prospectus. DWS Investment 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 DWS Investment S.A.’s risk management processes?
DWS Investment 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. DWS Investment S.A. uses a comprehensive range of quantitative tools and metrics for monitoring and managing risks. As a matter of policy, DWS Investment 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. DWS Investment 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 DWS Investment S.A. by these service providers. In addition, each service provider delivers an activity report to the Board of Directors and DWS Investment 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 DWS Investment S.A..
5. What is the procedure for making complaints to DWS Investment S.A.?
The process for making a complaint to DWS Investment S.A. is contained in a document that can be obtained, free of charge, on request from DWS Investment S.A..
6. How does DWS Investment S.A. exercise its voting rights?
DWS Investment S.A.’s policy on the exercise of voting rights is available, free of charge, on request from DWS Investment 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 DWS Investment S.A.’s best execution policy?
DWS Investment 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.
DWS Investment 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 DWS Investment S.A. on request free of charge.
8. Does DWS Investment S.A. enter into any soft commission arrangements?
DWS Investment 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 DWS Investment 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 DWS Investment S.A., which have been filed with the CSSF. The contents of these documents are not disclosed to investors in the funds.