Rules and articles
| Articles of Association |
| Remuneration Policy |
| Stefnir Data Protection Notice |
| Wolfsberg form |
The documents released on this part of the company’s website are a translation of the original documents, written in Icelandic. In the case of any discrepancy between the English and the Icelandic texts, the Icelandic versions shall prevail and questions of interpretation will be addressed solely in the Icelandic language.
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.
Complaints Committee on Transactions with Financial Firms
The Financial Supervisory Authority (FME) accommodates the Complaints Committee on Transactions with Financial Firms, which deals with disputes between consumers and financial companies.
See website of FME for further details
Consumer service
The FME operates an information and guidance service for customers of financial companies.
See website of FME for further details
The Consumer Agency is a governmental agency which provides a range of information on consumer issues.
See website of Consumer Agency for further details.
Courts
Customers can refer disputes to the courts. The Icelandic Bar Association (LMFÍ) offers free legal aid to the general public.
See website of the Icelandic Bar Association (LMFÍ) for further details
Complaints Handling Policy
The Complaints Handling Policy has been established to ensure a transparent, fair, and efficient procedure for addressing complaints submitted to Stefnir hf.
Complaints to Stefnir should generally be submitted in writing. Complaints can be sent by email to kvortun@stefnir.is. The complaint should state the reason(s) for the complaint and include a brief description of the matter in question.
Complaints will be responded to in writing by email no later than four weeks from the date of receipt. If the complaint cannot be resolved within that timeframe, the client will be informed of the reason for the delay and provided with an estimated response time.
Privacy Policy
Stefnir has established a Privacy Policy in accordance with Act No. 90/2018 on Data Protection and the Processing of Personal Data. Clients have the right to access their personal data and, in certain circumstances, to request correction, deletion, or restriction of processing.
Clients may direct any inquiries regarding the implementation of the Act to Stefnir’s Data Protection Officer via email at personuverndarfulltrui@stefnir.is. Clients also have the right to lodge a complaint with the Icelandic Data Protection Authority.