Compliance 

Stefnir is required to establish a compliance function and shall ensure that it is effective and independent of other aspects of operations. The role of Compliance is to ensure that the company’s operations comply with the laws and regulations on the securities markets. 

Compliance's areas of responsibility include the following:

• Implementation and monitoring of policy on conflicts of interest.
• Implementation and monitoring of rules on business transactions by employees.
• Training and advice to employees and senior management concerning the company’s obligations on the securities market.
• Other tasks, e.g. reporting to and liaison with the authorities. 

Policy on conflicts of interest

Stefnir hf. has adopted a policy on conflicts of interest established on the basis of Article 22 of the Alternative Investment Fund Managers Act No. 45/2020, Article 18 of the UCITS Act No. 116/2021, cf. Section III of Regulations No. 471/2014 on the Organizational Requirements for Management Companies of UCITS and Article 32 of the Markets in Financial Instruments Act No. 115/2021 concerning other services than managing funds for collective investments and related regulatory acts.

It is inherent in Stefnir’s operations that various parties may have different interests to protect. There is inevitably the inherent risk that this will lead to a conflict of interests when the interests of one or more party overlap with the interests of another. It is therefore the company’s policy to take all available measures to prevent conflicts of interest from occurring and adversely affecting the interests of clients and fund members. The company’s policy on conflicts of interest describes the measures which the company has introduced to analyze, prevent or tackle conflicts of interest. The policy is designed to protect clients and fund members and to safeguard the independence and reputation of the company and its employees.

All representatives of Stefnir are required to work with the best interests of clients and fund members in mind and to ensure that they do not show any preference for the interests of one group over another. Clients and fund members can be sure that the interests of Stefnir, related parties, employees and other clients do not have a negative impact on the company's representation of their interests.

There are numerous ways to prevent conflicts of interest from adversely affecting clients and fund members, and representatives of Stefnir are obliged to resort to these measures in specific circumstances. If the company's measures do not provide sufficient assurance that the interests of funds and fund members are adequately protected, the managing director and compliance officer must be informed immediately so that special measures can be taken. Fund members must be informed in a durable medium of such measures and the reasons why it was decided to apply such measures.

This text summarizes the main aspects of the company's policy on conflicts of interest. All further information can be obtained from the company.