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Our policies

TMF Fund Management S.A. (“TMF”) qualifies as a regulated investment fund manager (“IFM”) authorized for the management of undertaking for collective investment on transferable securities (“UCITS”) and alternative investment funds (“AIFs”) (jointly hereafter referred to as the “Funds”).

This section provides information regarding the policies of TMF.

Investors in the Funds may request free of charge additional information by writing to

TMF has established a remuneration policy, which sets out principles applicable to the remuneration of the senior management, all staff members having a material impact on the risk profile of the financial undertakings as well as all staff members carrying out independent control functions.

TMF has elected to apply the proportionality principle as provided by the guidelines, and the remuneration policy has therefore been conceived in a way and to an extent that it is appropriate to its size and internal organization as well as the nature, scope and complexity of its activities.

The policy seeks appropriate balance between fixed and variable remuneration elements in line with the business strategy, objective, value and interest of the IFM.

The policy also integrate sustainability risks in the investment decision making process according to the roles and responsibilities allocated to TMF staff members.

When executing orders, TMF acts in the best interests of the Funds at all times and will take all reasonable steps to obtain the best possible result for its clients taking into account the following factors:

  • Price of the financial instrument;
  • Costs;
  • Speed;
  • Likelihood of execution;
  • Likelihood of settlement;
  • Size of the trade;
  • Nature of the trade;
  • Any other consideration relevant to the execution of the order.

The relative importance of the aforementioned best execution factors are based on experience and judgement, per product type, with respect to available market information at the time and taking into account the characteristics of the investment strategy of the fund and the characteristics of the client (including its categorization).

The provisions described in the Complaints Policy, here below summarized, give account of how potential complaints are governed within TMF. By implementing this policy, TMF ensures that complaints are dealt with diligently and within an acceptable time frame.

This policy is designed for handling complaints received from investors in the Funds managed by TMF during the fulfilment of its professional activities.

The purpose is to analyze any possible claim done by Investors to impartially assess the case.

Here are the additional information for Fund’s Shareholders to file a complaint.

TMF strives to exercise shareholder voting rights in the best interests of the investors of the Funds, independent of the interests of third parties, and in accordance with the objectives of the investment policy of the respective Fund. If the portfolio management function is delegated to an external portfolio manager, the exercise of voting rights is also delegated to the external portfolio manager. In this case TMF ensures during its initial due diligence and ongoing monitoring that the delegate’s strategy has an adequate and effective strategy for determining when and how voting rights attached to instruments held in the managed portfolios are to be exercised, to the exclusive benefit of the Fund and its investors.

TMF is committed to investigate and monitor potential conflicts of interest that may arise within TMF and within the Funds and its investors, where applicable. TMF has set a process whereby potential circumstances of conflicts of interests are monitored, and where necessary disclosed to the Funds and its investors, where applicable. A compliance officer of TMF is in charge of the above-mentioned duties relating to the conflicts of interest monitoring.

Our sustainability risk policy can be accessed here.

The disclosures related to SFDR can be accessed here.

The list of sub-custodians can be accessed here.

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