Raiffeisen Kapitalanlage GmbH (Raiffeisen KAG) has both a concession to manage capital investment funds pursuant to the Austrian Investment Fund Act (InvFG) and a concession for investment consultation and portfolio management. Raiffeisen Immobilien Kapitalanlage-Gesellschaft m.b.H. (Raiffeisen Immobilien KAG) is licensed to manage alternative investment funds (AIF) in the form of real estate funds pursuant to the Austrian Real Estate Investment Fund Act and AIF with the investment strategy predominant AIF type “Fund of Funds”, AIF strategy “Other fund of funds” in accordance with point 10.d. of the pro-forma reporting template in Annex IV of the Commission Delegated Regulation (EU) No 231/2013. Within the framework of these activities, Raiffeisen KAG is subject to the supervision of the financial market authorities. As a company offering funds, Raiffeisen KAG and Raiffeisen Immobilien KAG pursue a honest, consistent investment policy, which is always oriented to serving the best interests of its clients.

CODE OF CONDUCT

In performing our activities as an asset management company, we are guided in particular by the Code of Conduct of the Austrian investment fund industry. Raiffeisen Capital Management is committed to the values of the RBI Group as defined in its Code of Conduct. Accordingly, the Code of Conduct also forms the basis for all of Raiffeisen Capital Management’s activities. The RBI GroupCode of Conductdefines the fundamental values of our bank, and it serves as the foundation for our ethically responsible corporate culture in conformance with statutory regulations. The Code of Conduct is binding for all employees of the RBI Group, and it ensures that the highest standards are observed in our business and ethical behaviour. The standards that are based on the following values:

• Customer orientation

• Professionalism

• Quality

• Mutual respect

• Initiative

• Teamwork

• Integrity

Good corporate governance is also included.

INVESTMENT PROCESS

Amongst other things, our investment process is based on the following principles:

• We are active managers, as we do not view the capital markets as efficient.

• Our goal is to generate long-term additional returns compared to the market and the competition.

• The main pillars of our business are successful, experienced fund managers with demonstrated ability to generate alpha and logical, transparent investment processes, which are well documented and are practiced consistently in our day-to-day operations.

• Generation of additional returns (alpha) is mainly based on fundamental research, supported with quantitative models.

• A number of independent strategies are pursued in the interests of risk diversification, and no single strategy is pre-dominant.

Based on the investments which are undertaken, the funds managed by Raiffeisen KAG and Raiffeisen Immobilien KAG also have membership and creditor rights, which we exercise in line with the principles we have formulated in these regards.

Provision of quality services is ensured by a suitable organisational framework at Raiffeisen KAG. This includes the structural and procedural organisation that has been developed, the internal controlling system and state-of-the-art risk management. A proprietary process has been established for the selection of external management partners, which ensures that Raiffeisen KAG only cooperates with contractual partners which guarantee the prudent, correct provision of services.

SUSTAINABILITY POLICY

Comments on Articles 3 and 4 of Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability-related disclosures in the financial services sector:

• Sustainability Policy for investment funds, portfolio management and investment advice at Raiffeisen Kapitalanlage-Gesellschaft m.b.H.
  Download: Sustainability Policy of Raiffeisen KAG

CONFLICTS OF INTEREST

Raiffeisen KAG has its own compliance organisation whose specific tasks include supporting the departments in the identification and resolution of conflicts of interest between the company and its funds and between the funds themselves in order to ensure that investors are not disadvantaged through such conflicts of interest. One measure that helps in the prevention of conflicts of interest is the creation of areas of confidentiality. This is intended to ensure that compliance-relevant information that originates or is registered in a specific department of Raiffeisen KAG does not leave this department and is only used to the extent necessary for the normal course of business. In order to prevent conflicts of interest and insider trading, Raiffeisen KAG has introduced special rules for employee transactions, i.e. the personal transactions of its staff, which are based on the Standard Compliance Code of the Austrian banking industry and have also been supplemented with additional rules that are specific to investment firms. Raiffeisen KAG’s compliance organisation is also audited by the Internal Audit division on an annual basis.

Raiffeisen KAG and its subsidiaries have created a conflict of interest policy that defines guidelines for handling conflicts of interest, identifies potential conflicts of interest and explains how to deal with them. Download:

Conflict of Interest Policy
Conflict of Interest Policy (Raiffeisen Immobilien KAG)

INVESTOR PROTECTION

Legally mandated measures to separate functions serve to protect the invested assets and thus to protect our investors.

• For example, fund assets are qualified as special assets, which are not owned by the asset management company or depository bank, but always remain in the ownership of the unitholder and are thus separate from the assets of the management company, the depository bank and the other funds of the management company.

• Moreover, a depository bank is commissioned with storing the securities that belong to a fund, with managing the accounts for the fund and with disbursing and redeeming the investment units. Accordingly, safe-keeping of the securities is separate from Raiffeisen KAG resp. Raiffeisen Immobilien KAG, which is responsible for managing the invested assets.

• Calculation of the value of the fund is also carried out by the depositary bank and is one of the central elements in the division of powers. This ensures proper calculation and settlement.

• With regard to their unitholders, funds are subject to particularly stringent requirements in respect of transparency and disclosure. The net asset value of the fund is published on a daily basis for retail funds. Unitholders receive comprehensive information on their fund(s), in the form of a complete sales prospectus and key investor information (containing information on the company itself, a description of the investment goals, the profile of a typical investor, data on costs and fees), an accounting report and a semi-annual report, which provides specific information on the performance of the fund in the reporting period.

Information regarding investor compensation:
Raiffeisen Kapitalanlage-Gesellschaft m.b.H. is subject to Part 3 of the Austrian Deposit Guarantee Schemes and Investor Compensation Act (Einlagensicherungs- und Anlegerentschädigungsgesetz; ESAEG). It is a member of Österreichische Raiffeisen-Sicherungseinrichtung eGen.

The required information pertaining to investor compensation can be found on the website of Österreichische Raiffeisen-Sicherungseinrichtung eGen.

Summary of investors rights according to Article 4 para 3 Regulation (EU) 2019/1156 of the European Parliament and of the Council of 20 June 2019: Download

CONTROL

The activities of Raiffeisen KAG and Raiffeisen Immobilien KAG, the companies' legal compliance, and their proper, expedient operation are reviewed on an ongoing basis by the internal auditing department, in line with an annual auditing plan. The financial statement and consolidated financial statements together with the accounting, the management report and the consolidated management report, are audited by a bank auditor, which issues an unqualified opinion if all of the relevant conditions are fulfilled. The bank auditor also prepares an annex to the auditing report, which contains statements on compliance with the relevant legal supervisory standards and represents an important basis for the oversight operations of the financial market authorities in respect of Raiffeisen KAG respectively Raiffeisen Immobilien KAG.

PRINCIPLES OF BEST EXECUTION

In the course of Raiffeisen KAG’s activities, the company executes trade decisions and receives trade orders for execution. Trading orders are also executed in the course of the portfolio management for clients on behalf of the Raiffeisen banks. In order to achieve the best possible results for the funds/portfolios and their customers, these activities are performed according to the following principles of the Best Execution Policy.
Best Execution Policy

ENGAGEMENT POLICY INCLUDING PRINCIPLES OF THE EXERCISING OF VOTING RIGHTS

As an asset manager, Raiffeisen Kapitalanlage-Gesellschaft m.b.H. ("Raiffeisen KAG") is obliged according to § 185 (1) (1) Stock Exchange Act (BörseG) to establish an engagement policy describing how Raiffeisen KAG integrates its engagement as a shareholder into the investment strategy. A significant part of the engagement consists of exercising the voting rights conferred by the shares. Furthermore, Raiffeisen KAG is obliged under § 185 (1) (1) Stock Exchange Act (BörseG) to publish annually how its engagement policy has been implemented.
As an investment management company, Raiffeisen Kapitalanlage-Gesellschaft mit beschränkter Haftung (“Raiffeisen KAG”) is responsible for exercising shareholder voting rights either directly or via voting proxies. The company exercises these rights in respect of all Austrian equities as well as all equities with a significant share in market capitalization.

Engagement Policy including principles of the exercising of voting rights
Engagementreport

INFORMATION ON THE CURRENT REMUNERATION POLICY OF RAIFFEISEN KAG AND RAIFFEISEN IMMOBILIEN KAG

The remuneration guidelines issued by Raiffeisen KAG (“Remuneration Guidelines”) form the binding framework for implementing the requirements for the remuneration policy and practices set forth in § 17a to 17c InvFG and § 11 AIFMG and Appendix 2 to § 11 AIFMG. In accordance with the legal requirements, the Remuneration Guidelines specifically contain detailed regulations relating to the general remuneration policy, including rules on the appropriate determination of fixed and variable remuneration components and voluntary old-age pension components, and on the design and measurement for the “bonus pool”, rules on the allocation and payment of variable remuneration and the assessment of performance, as well as special rules for employees with control functions. Furthermore, the Remuneration Guidelines contain requirements for the selection of “identified staff” in the sense of § 17a InvFG and § 11 AIFMG (“Identified Staff”) and special rules relating to their remuneration, in particular in relation to the entitlement to, payment of and risk adjustment for variable remuneration components. More

Raiffeisen KAG ensures that its remuneration policy adequately reflects sustainability risks. Thus, the remuneration policy appropriately promotes sound and effective risk management with respect to sustainability risks whereas the structure of remuneration does not encourage excessive risk‐taking with respect to sustainability risks which is incompatible with the risk profiles or terms and conditions of the investment funds which it manages and is linked to risk‐adjusted performance. Likewise, the remuneration policy appropriately fosters that the investment advice given promotes sound and effective risk management with respect to sustainability risks. This is particularly done by including appropriate sustainability measures in the setting of targets in the Performance Management Process of functions working in the affected areas.

More information on the composition of the Compensation Committee can be found here:imprint

Raiffeisen Immobilien KAG ensures that its remuneration policy adequately reflects sustainability risks. Thus, the remuneration policy appropriately promotes sound and effective risk management with respect to sustainability risks whereas the structure of remuneration does not encourage excessive risk‐taking with respect to sustainability risks which is incompatible with the risk profiles or terms and conditions of the real estate funds which it manages and is linked to risk‐adjusted performance. This is particularly done by including appropriate sustainability measures in the setting of targets in the Performance Management Process of functions working in the affected areas.

At Raiffeisen Immobilien KAG, the Supervisory Board is responsible for matters of remuneration. Raiffeisen Immobilien KAG does not require a separate remuneration committee.

INFORMATION ON THE IMPLEMENTATION OF PROVISIONS ON THE ASSESSMENT OF THE SUITABILITY OF MEMBERS OF THE MANAGEMENT BODY, THE SUPERVISORY BODY AND KEY FUNCTION HOLDERS (§ 5 (1) 6, 7, 9 and 9a, 28a (5) 1 to 5; and InvFG 2011 § 6 (1) 10 and § 5 (2) 1 AIFMG)
Articles 5 (1) 6 to 11 and 13, 28a (3) and (5), and 30 (7a) BWG stipulate certain requirements for the members of the management body and the chair and members of the supervisory body of credit institutions, financial holding companies and mixed financial holding companies. Amongst other things, these requirements pertain to personal reliability, professional aptitude, the required experience for exercising management and supervisory functions and adequate availability (“fit and proper” requirements).
Above and beyond this, the Guidelines on the assessment of the suitability of members of the management body and key function holders dated 22 November 2012 (EBA/GL/2012/06) published by the European Banking Authority (EBA) established criteria and procedures which credit institutions must observe in the assessment of the suitability of members of the management bodies in management and supervisory functions. In May 2013, the Financial Market Authority published a Circular Letter on the Assessment of the Suitability of Executives, Supervisory Board Members and Key Function Holders (“fit and proper” circular).
As the “fit and proper” requirements are be observed by the institutions both at the individual level and at the banking group level (§ 30 BWG), RBI – as the parent credit institution of the RBI Banking Group – has issued a corresponding RBI Fit and Proper Group Guideline, which determines minimum standards for the members of the RBI Banking Group which are subject to “fit and proper” requirements.

In order to implement these provisions, Raiffeisen KAG has issued a Fit and Proper Guidelines, which establishes a process for carrying out suitability assessments of members of the Managing Board and the Supervisory Board, as well as key function holders, and determines responsibilities and criteria for the assessment of suitability and personal reliability. According to this, Raiffeisen KAG will assess and document the professional aptitude and personal reliability of members of the Managing Board or Supervisory Board and key function holders based on the legal requirements, prior to the appointment or reappointment of such. Furthermore, a process was established for regular internal suitability assessments of the members of the Managing Board and Supervisory Board and key function holders (evaluation).

Information and documents, such as curriculum vitae, criminal records, statements on availability and potential conflicts of interest from the member of the Managing Board or Supervisory Board or key function holder to be appointed are used in the assessment of suitability. A positive overall assessment (“fit and proper”) is given if the professional aptitude and personal reliability meet the established criteria and statutory requirements. The Financial Market Authority is notified of the appointment of members of the Managing Board and Supervisory Boards in accordance with the statutory requirements, with the attachment of the assessment documentation.

If you have a suggestion or a complaint, please contact us via the following channels:

Phone: +43 1 711 70-0
Fax: +43 1 711 70 76-0
kag-info@rcm.at, www.rcm.at
Mooslackengasse 12, 1190 Wien

We will get back to you as soon as possible. Your request will be processed by the responsible customer advisor with the goal of finding a mutual solution. You can communicate with us in German and in the local languages of our sales countries. This service is free to you as an investor in our products.

Customer feedback allows us to better understand the needs of our customers and thus improve our products and services. Therefore, please inform us if we did not fully meet your expectations or you have a complaint. We appreciate constructive feedback very much and take all comments and complaints seriously. Please note the following information to help us process your case quickly and efficiently:

• Please state your full name and your address.

• Please describe the reason you are dissatisfied in as much detail as possible.

• If documents are relevant for the processing or you have questions about the processing, please include them.

• If you have a suggestion for how we can solve the cause of your complaint, please share it with us.

Please contact our complaint office by e-mail or post. You will receive a confirmation of receipt immediately and our response as soon as possible. If the processing of your message will take a bit longer, we will naturally notify you of this and inform you about the current status of the processing.

We will get back to you as soon as possible. Your request will be processed by the responsible customer advisor with the goal of finding a mutual solution. You can communicate with us in German and in the local languages of our sales countries. This service is free to you as an investor in our products.

Joint Conciliation Board of the Austrian Banking Industry

If, in individual cases, no agreement can be reached regarding your complaint, you can contact the Joint Conciliation Board of the Austrian Banking Industry (JCBABI).

The JCBABI is an institution for the out-of-court settlement of disputes between consumers residing in Austria or any other country in the European Economic Area and a credit institution based in Austria or any other institution specified in § 1 Austrian Banking Act (BWG) relating to obligations stemming from a banking transaction pursuant to § 1 BWG. The JCBABI is responsible for complaints filed by persons who are not consumers to the extent that an EU directive or a law – such as the Payment Services Act (Zahlungsdienstgesetz) – provides for conflict resolution for this group of persons. The JCBABI is part of the Banking and Insurance sector of the Austrian Federal Economic Chamber. Its independent and autonomous ombudsperson is responsible for the procedures.

Gemeinsame Schlichtungsstelle der Österreichischen Kreditwirtschaft

Wiedner Hauptstraße 63, 1045 Wien
Phone: +43 1 505 42 98
Fax: +43 (0) 590900-118337

office@bankenschlichtung.at, www.bankenschlichtung.at