INVESTFINANS AB
Terms and Conditions
Including

Information about Investfinans AB
the principles of order execution
(Execution Principles)

the information on how to deal with conflicts of interest as well the remuneration list
01/2018
Investfinans AB offers its clients financial services in the form of consultancy and brokerage services, in particular in connection with the acquisition and sale of real estate, securities, bonds, shares or shares in investment funds, assets and other financial instruments, as well as asset management. In some cases, Investfinans AB does not execute the client orders itself but forwards them to the executing partners named in the execution policy at their best discretion. The client always receives the report on the execution of the transaction from these execution partners. Insofar as Investfinans AB provides brokerage and / or advisory services through tied agents, it will separately advise. In asset management, the investment strategy individually agreed with the respective client is implemented. Investfinans AB is commission-based in consultancy and brokerage and active in asset management for remuneration. Independent fee advice is not provided. Details of the rules governing the remuneration and treatment of mediation and mediation fees are set out in No. 9 of the GTC and the Compensation List. The amount of funding for mediation and consultancy is disclosed on a product-related basis. The same applies to small non-monetary contributions in the provision of asset management. Investfinans AB distributes financial instruments designed by it. The principles of Investfinans AB for dealing with conflicts of interest are disclosed in the “Information on the Management of Conflicts of Interest”. The organizational and administrative measures taken to prevent or manage conflicts of interest are sufficient to ensure with reasonable assurance that the interests of customers are not harmed. The relevant language for the contractual relationship is Swedish, English and German. Investfinans AB is not obliged to accept further foreign language documents.

Information on the INVESTFINANS AB
Name and address of the institute
INVESTFINANS AB
Västertorpsvägen 135
129 44 Hägersten
Contact
Phone: +46 840 83 91 01
Email: info@investfinansab.eu

INVESTFINANS AB
Key details on the transactions

contract award
Orders to INVESTFINANS AB (hereinafter also referred to as the “Institute”) must be made by the customer in person, in writing, by telephone or by Fax.

1.1 Orders received by fax

1.1.1 The authenticity and completeness of orders sent by telefax in the absence of the original document can only be verified by reference to the fax received by the Institute. Forgeries are usually not readily apparent. The same applies to delays, distortions or other transmission errors.

1.1.2 Orders transmitted by fax shall be forwarded by the Institute at the risk of the customer. The customer shall bear all damages with the exception of damage to body and health resulting from the forwarding and subsequent execution of forged or falsified orders, if and to the extent that the institute has carried out the inspection with the necessary care. The Institute has taken the necessary care when the check for identifiable forgery or falsification has taken place.

1.2 Customer confirmation

The Institute is entitled, but not obliged, to obtain confirmations from the Customer prior to the forwarding of orders from the Customer or to carry out other inspections with regard to the orders. If the institution exercises this right, the order will not be forwarded until the confirmation has been submitted.

Free investment advice
The institute provides the investment advice (among other things as part of the deposit check) against existing and potential customers until further notice for these free of charge (commission-based investment advice). A change of the remuneration can be made by a change of the No. 9 of the AGB. A claim for the implementation of a free investment advice is not granted.

third fault
Insofar as clients and / or potential clients of the institute receive advice from a third party in connection with a product marketed by the institute, the institute accepts no liability for the recommendations, advice and information given by third parties, unless the institute confirms such Information from third parties in written form.

Authorization to store customer-related data
The institute will collect, store and process personal data of the customer, insofar as this is necessary for the purposeful execution of the business relationship. The Investfinans AB is supervised by the competent supervisory authority in Sweden, Finansinspektionen Supervisor Authority (FI), Brunnsgatan 3, 111 38 Stockholm. Investfinans AB is a member of the Compensation Scheme for Securities Trading Companies (EdW). The scope of the claims of the creditors protected by this indemnity is described in no. 12 of the GTC. Orders for the purchase and sale of securities and / or shares or shares in investment funds must be submitted to us in person, in writing, by telephone or by Fax. For telephone inquiries on orders, only the following number must be used: +46 840 83 91 01. The Investfinans AB is required by law to record electronic and telephone communications as far as these customer orders are concerned. Items of Investfinans AB’s services are primarily units or shares in investment funds and assets and securities (such as shares and bearer bonds) offered to the public or traded on a secondary market (eg Stock exchange). The corresponding offer documents (prospectus and / or annual report and / or semi-annual report) can in principle be requested from their respective provider / capital management company and are available on their website. Product Information Sheets (for example, Key Investor Information, PRIIP’s or Asset Information Sheets are provided by Investfinans AB.

Terms and Conditions

Principles between Investfinans AB and the customers

No. 1 Scope and amendments to this

Terms and conditions

(1) Scope

The General Terms and Conditions apply to the entire business relationship between the customer and the domestic offices of Investfinans AB (hereinafter referred to as the “Institute”).

(2) Information and contract language

The relevant language for the contractual relationship and communication with the customer is Swedish or German. All documents and information are provided in Swedish or German language.

(3) changes

Changes to these terms and conditions and any special conditions will be announced to the customer in writing. Changes are considered approved if the customer does not object in writing or in text form. The institute will particularly point this out to him. The customer must send the objection to the institute within six weeks after notification of the change.

No. 2 Customer classification and consequences of classification

(1) General classification as a retail investor

The client of the institute is generally classified (classified) as a “private investor” (hereinafter referred to as “private investor”) within the framework of the business initiation and / or business relationship. This applies regardless of the client’s investment objectives, risk-bearing capacity or knowledge and experience of and with transactions in financial instruments and other investments.

(2) Promotion to other customer classes

Classification as a “Professional Customer” or “Appropriate Counterparty” is possible through a written agreement between the Customer and the Institute if and to the extent requested by the Client to the Institute and if he meets the relevant requirements for classification as a “Professional Client” or “Appropriate Counterparty “In writing proves. A downgrade to “private investors” is possible by written agreement between the customer and the institute, as far as the customer requests this in writing vis-à-vis the institute.

No. 3. Recording of telephone conversations and electronic communication with order reference

The Institute is required by law to record and keep records of telephone calls and electronic communications (such as e-mail, chat, video telephony, messenger service) in connection with the initiation / acceptance, transmission and execution of client orders on audio or data carriers. This applies irrespective of whether they are conducted with official or private telephones of the employees. A copy of the records of these discussions and communications with customers will be available upon request for a period of five years, if requested by FI Sweden or the Federal Financial Supervisory Authority, for a period of seven years. Before commencing the recording of telephone conversations, the customer will be informed of the purpose of the recording and asked to submit his consent, unless the customer has already given the Institute his general consent to record telephone conversations.

No. 4. Recording of telephone conversations without order reference

The Institute is legally entitled, but not obliged, to record telephone conversations in connection with the conduct of the customer relationship, which are not related to the order, on sound or data carriers and to keep these records. This includes, in particular, telephone calls about complaints. The recording takes place to fulfill legal obligations and proof purposes. Before commencing the recording of telephone conversations, the customer will be informed of the purpose of the recording and asked to submit his consent, unless the customer has already given the Institute his general consent to record telephone conversations. The recordings can be intercepted by employees of the institute. The Institute is entitled, but not obliged, to make transcripts of the records. The records may be used for evidence in any litigation. The customer will inform authorized representatives upon authorization that telephone calls can be recorded.

(1) Privacy

Subject to the provisions of data protection law, the institute is entitled to store and, if necessary, reproduce the personal data required for a proper and / or legal provision of order fulfillment and / or business relationship with customers, and at least within the legal retention periods to maintain and / or restore. The Institute is only entitled to pass on acquired information and / or data to third parties if this serves the proper execution of the order or is required by law.

(2) Telephone recordings

The provisions of paragraph 4 also apply to the recording of telephone conversations and electronic communication between customers and the Institute.

No. 5 Liability of the institute – contributory negligence of the customer

(1) Liability principles

The Institute is liable for the performance of its obligations for any fault of its employees and the persons it engages in fulfilling its obligations. Insofar as any special conditions for individual business relationships or other agreements differ, these regulations shall prevail. If the customer has contributed to the occurrence of damage through culpable behavior (for example by breach of the duty to cooperate listed in no. 8 of these Terms and Conditions), the extent to which the institute and the customer are to bear the damage shall be determined in accordance with the principles of contributory negligence.

(2) Forwarded orders

If, in terms of its content, an assignment is typically carried out in the form that the institute entrusts a third party with further processing, the institute fulfills the assignment by forwarding it to the third party in its own name (forwarded order). This concerns, for example, the forwarding of an order or obtaining information from other institutions. In these cases the liability of the institute is limited to the careful selection and instruction of the third party.

(3) malfunction of the operation

The institute is not liable for damages caused by force majeure, riots, war and natural events or other events for which it is not responsible (eg strike, lockout, traffic disruption, high-level orders at home or abroad). Prior to reclassification, the institute will inform the customer in writing about the consequences of the new classification (see also No. 2 (3) of these GTC). Furthermore, a written confirmation of the customer is required for the change in the notice of this notice.

(4) consequences of classification

The classification as a “retail investor” means that the client enjoys the highest legal protection level in terms of investor protection and transparency in the business relationship. A re-qualification may have detrimental consequences for the client with respect to the scope of the institution’s audit obligations to the client prior to the execution of the order and, in the case of a “suitable counterparty”, also to the information obligations of the institution and execution of an order.

No. 6 Confidentiality and Due Diligence,Privacy, telephone records

(1) Confidentiality

The Institute is bound to secrecy about all customer-related facts and evaluations of which it becomes aware. Information about the customer may only be passed on by the institute if legal provisions and / or official orders dictate this or if the customer has given his consent.

(2) Scope of the information

Information provided by law and / or administrative order are governed by the statutory specifications and / or the requirements of the regulatory arrangement.

(3) Conditions for the provision of information

The Institute is authorized to provide information on legal persons and registered traders, provided the request relates to their business activities. However, the Institute does not provide any information if it has a different instruction from the customer. Information about other persons, in particular about private customers and associations, the institute only if they have generally or in individual cases expressly consented. An information is only given if the requesting party has credibly set out a legitimate interest in the requested information and there is no reason to believe that interests of the customer that are worthy of protection preclude the provision of information.

(4) Jurisdiction for certain foreign customers

The choice of court agreement also applies to clients who carry out a similar commercial activity abroad, as well as to foreign institutions that have legal interests with domestic legal entities or with a German public-law special fund are comparable.

No. 7 Obligation to cooperate with the customer

(1) changes of name, address or one of representative authority granted to the Institute

For the orderly conduct of business transactions, it is necessary for the customer to notify the institute immediately of changes to its name and address as well as the expiry or change of a power of representation (in particular a power of attorney) granted to the institution. This duty to notify exists even if the power of representation is entered in a public register (for example in the commercial register) and its cancellation or amendment is entered in this register.

(2) Clarity of orders

Orders of any kind must reveal their content beyond any doubt. Unclear orders may result in queries that may lead to delays. Above all, in the case of orders for the purchase and sale of financial instruments / securities, the customer must ensure the correctness and completeness of the name of the payee, the specified account number and the specified institution code, IBAN and BIC and the specified order currency. Changes, confirmations or repetitions of orders must be marked as such.

(3) Special instructions in case of urgent need of execution of an order

If the customer considers a particular hurry to be necessary when executing an order, he must notify the institute separately. For formally placed orders, this must be done outside the form.

(4) Review and objections to communications of the institute

The customer must check order confirmations, settlements, depot and income statements, other settlements, announcements about the execution of orders for their correctness and completeness immediately and raise any objections immediately.

No. 8 Limits of offsetting authority with the Institute

The customer can only offset against claims of the institute if his claims are undisputed or legally established or disputed and are ready for decision.

No. 9 Right of disposal after the death of the customer

After the death of the customer, the institution may request the presentation of a certificate of inheritance, an executory certificate or other documents necessary for the clarification of the right of disposal; Foreign language documents are to be submitted in Swedish translation at the request of the institute. The institute may refrain from submitting a certificate of inheritance or an executory certificate if it is accompanied by a copy or a certified copy of the last will (testament, inheritance contract) together with the corresponding opening memorandum. The Institute may regard as entitled, the person entitled to be the heir or the executor of the will, let him have it and, in particular, render him liberating. This does not apply if the Institute was aware that the person named there was not authorized to dispose of it (for example, after contestation or nullity of the will) or if the Institute did not become aware of it as a result of negligence.

No. 10 Relevant Law, Jurisdiction

(1) Validity of the law

For the business connection between the customer and the institute, the legislation in the tax domicile of the customer applies.

(2) Jurisdiction for certain domestic customers

If the customer is a merchant and the disputed business relationship is attributable to the operation of a commercial business, the institution may sue the customer at the registered office of the institution or at another competent court; the same applies to a legal entity under public law and to special funds under public law. This jurisdiction agreement does not limit the right of the customer in question to bring proceedings before another competent court. Nor does the initiation of proceedings before one or more other jurisdictions preclude the initiation of proceedings at another jurisdiction, if and insofar as this is legally permissible. The Institute itself can only be sued by these clients to entities responsible for asset management if and to the extent that asset management claims are made. The Institute and the Customer agree that the donations / s respectively disclosed to the Customer prior to the provision of the service do not conflict with the proper provision of the service in the best interests of the Customer. If and insofar as the customer is entitled to surrender the goods due to the agreements referred to in this paragraph against the institute, the customer assigns this claim to the institute which hereby accepts the assignment. Details of the benefits received and granted will be provided to customers prior to the provision of the Services.

(3) Charges outside the private customer business
Outside the retail banking business, unless otherwise agreed, the institution determines the amount of charge at its reasonable discretion
(4) Modification of fees
The fee for services typically used by customers in the course of the business relationship (eg checking the composition of the portfolio, execution of customer orders) may be changed by the Institute at its discretion.
(5) Right of termination of the customer in case of increases of charges
The institute will notify the customer of any changes to fees according to paragraph 4. In the event of an increase, the customer may, unless otherwise agreed, terminate the business relationship affected with immediate effect within six weeks of notification of the change if a term has been agreed for this.
(6) Notification of the Institute in the absence of of messages
If the customer does not receive statements of account and deposits, he must inform the institute immediately. The obligation to notify also exists in the absence of other notifications the customer expects to receive (eg securities settlements, account statements after the execution of orders by the customer).
(6) Notification of authorized representatives of the recording of telephone conversations
Insofar as the institution is in a legal dispute with a customer, the customer must inform a possible authorized representative that the institute has the right to record telephone conversations.
(7) Special notification obligations
Insofar as the customer does not provide the required information / evidence required by law for the initiation / execution of certain transactions in financial instruments (eg proof of representation rights, legal entity identifiers for certain financial market participants), the institution is entitled to refrain from performing orders and / or other services, whereby the institution must inform the customer immediately of non-execution.

No. 9 Remuneration, benefits and expenses
(Commission-based and paid services)
(1) Fees in the private customer business In the private customer business the customer fees for the achievements of the institute are not separately charged, as far as no deviating agreement in these general business conditions beside “remuneration list” was made. For the services not listed in this list, which are provided on behalf of the customer or in his alleged interest and which, judging by the circumstances, can only be expected to be remunerated, the institution may determine the amount of the fees in its reasonable discretion.
(2) Contributions for the settlement of services and agreement on the assignment
of any claims of the customer in favor of the institute The customer and the institute agree on the basis of the provision of paragraph 1 sentence 1 that the institute receives monetary and non-monetary benefits in the provision of mediation and consultancy.
(3) Termination for cause without compliance a notice period
A termination without notice of the entire business relationship or of individual business relationships is permitted if there is an important reason which makes the continuation of the business unreasonable, even taking into account the justified interests of the customer. Such reason shall be, in particular, where the Customer has provided incorrect information about its financial circumstances that were of material importance to the institution’s decision on its client classification or other transactions involving risks to the institution (for example, the exercise of discretionary mandates), or if a material deterioration of the financial circumstances of the customer occurs or threatens to occur and thereby the fulfillment of a liability to the institute is endangered or if obligations to cooperate within the meaning of no. 8 para. 7 of these GTC are not fulfilled. If the important reason lies in the breach of a contractual obligation with the exception of the obligations under no. 8 (7) of this AG, the termination is only permitted after the unsuccessful expiry of a reasonable period for remedy or after unsuccessful warning, unless this is because of the specifics of the individual case dispensable.
(4) Settlement after termination
In the event of termination without notice, the Institute will grant the customer a reasonable period of time to complete the transaction, unless an immediate settlement is required.
No. 10 Compensation and dispute resolution
(1) Expenses The Institute is entitled to charge the Client for expenses incurred if the Institute acts on its behalf or its alleged interest (in particular for long-distance calls, porti). (2) Indication of additional costs There may be the possibility for the client to incur additional costs and taxes when executing the transferred orders and from transactions in the financial instrument or investment service that are not paid or invoiced by the institution, No. 11 Right of termination of the customer (1) Right of termination at any time The customer may terminate the entire business relationship or individual business relationships for which neither a term nor a different termination agreement has been agreed at any time without observing a notice period. (2) Termination for good cause If a term or a different termination agreement has been agreed for a business relationship, termination without notice may only be pronounced if there is good cause for this, which is unreasonable for the customer, even taking into account the justified interests of the institution be able to continue the business relationship. (3) Legal Termination Rights Legal termination rights remain unaffected.
No. 12 Termination rights of the Institute (1) dismissal with notice, the Institute, the entire business relationship or individual business, for which neither a term has been agreed a diverging termination provision at any time by reasonable notice period. In determining the notice period, the institution will take into account the legitimate interests of the customer. Principles of order execution (Execution Policy) (contract broking and asset management of InvestfinansAB) – (hereinafter referred to as “the Institute”) as of 01/2018 contents of the execution policy Investfinans AB as a security services company in the context of the transmission of orders aimed at The purchase and sale of financial instruments, and to take measures within the framework of asset management by law, in order to obtain the best possible forwarding of orders for the clients and the execution of orders by the respective execution partner. In order to achieve this, the institution has made reasonable provision and set out order-routing and asset management policies that, in its view, typically result in “best possible” results. was carried out assessing the best possible result in principle at least five exemplary partners for each class of financial instruments particularly in view of execution factors such as the price quotation for each class of financial instrument and the costs, speed, likelihood of execution and qualitative criteria of the design partner as human and technical Equipment, timely information about changes in processes and used clearing system and emergency backups. However, determining the best possible execution venues does not entail any guarantee of achieving the best possible result for each individual order. The decisive factor is that the process used typically leads to the best possible result for the customer. No. 1 Scope Concurrent Clients This executive policy applies to orders from private investors and professional investors who are seeking to purchase or dispose of financial instruments (investment mediation). These principles also apply if the institution acquires or sells financial instruments in fulfillment of its duties under an asset management agreement with the customer on its behalf, whereby the institution generally forwards the order to the respective execution partner. The institution does not execute the orders itself except for the issue of self-issued financial instruments. Principle – forwarding of orders and exception own order execution The execution of customer orders is basically possible via different execution ways or at different execution places. The Institute conducts for clients (1) claims To the extent does the compensation scheme for securities trading company or a representative of their payments to a customer, go its claims against the institution of an equivalent amount with all ancillary rights train to train to the Compensatory Fund of Securities Trading Companies over. (2) Provision of information The Institute has the power to provide the Securities Trading Company or any of its agents with all information required in this connection and to provide documentation.

No. 13 No assignment of compensation claims (1) assignment regulation The assignment of claims of the customer for damages from the business relationship with the Institute to third parties is excluded. The judicial assertion of such claims by third parties is also excluded. (2) Streitgenossenschaft The customer and the institute agree that the customer can not assert claims for damages arising from the business relationship in court with other customers. (3) Traded Financial Instruments – Appointment of an Execution Partner For traded financial instruments, the institution will mandate an execution partner to conclude contracts for the purchase and sale of financial instruments for its clients. For this purpose, the execution partner concludes a purchase or sale transaction (execution transaction) with another party on a suitable market for the account of the customer. (4) Non-traded financial instruments – direct and best execution for direct execution In the case of non-traded financial instruments, the institution forwards orders from its client to acquire or return the financial instrument directly to the counterparty. (5) Own issues The institution is only the execution partner of an order for the purchase or sale of a financial instrument if it is also its issuer and the respective instrument can not otherwise be acquired / sold on the market. In this case, the institute is regularly only the sole implementing partner. For the execution of the order, the customer will not be charged any separate fees / costs by the institute, so that the customer-friendliest execution is. A consolidation of orders does not take place. At the customer’s request, the institute will provide additional information about consequences of this type of execution. (6) Applicability of legal provisions, terms and conditions The execution transactions are subject to the laws and conditions applicable to securities trading at the execution venue. Furthermore, the general terms and conditions of the execution partner or other trading partner and the contracting party of the execution partner or other trading partner apply.
(7) Price for Execution Business, Fees, Expenses The institute regularly instructs execution partners to execute customer orders. When an execution partner is commissioned, the latter settles the execution transaction directly with the customer. For customers classified as private investors, the most favorable execution partner in terms of execution costs is selected, as far as several execution partners exist. In the case of direct transactions in products of which the issuer is the institution, the institution will not charge the customer any fees. Orders to buy or sell financial instruments as investment agents or, as asset managers, on behalf of and for the account of the customer to the execution partner. When executing the business of acquiring or disposing of other financial instruments as units in investment companies, the institution commissions an execution partner who concludes a purchase or sale transaction (execution transaction) on behalf of the customer, unless this is directly with the issuer or other trading partner for the customer be acquired or sold to them. The purchase and sale of units in investment companies (execution transactions) is carried out via execution partners at the investment company by acquisition or return on account of the customer (and not via the secondary market). Special features of units or shares in investment funds When issuing or redeeming units or shares in investment funds, corresponding orders are generally executed in accordance with the German Investment Code and settled by the management company and third parties commissioned by it. In that regard, there is the possibility for the customer, the institution according to instructions. No. 2 para. 6 of the execution principles, according to which an acquisition or the sale of such shares should take place on the stock exchange or the secondary market (alternative execution option). In this case, the institution will commission an execution partner to settle on the stock exchange or the secondary market. No. 14 Execution of customer orders for the purchase and sale of financial instruments (1) Audit customer order or asset management mandate Customer orders are executed in accordance with the product risk with the customer classification and the target market determination of the respective product, as far as the customer order is appropriate; otherwise, the customer will be advised of the lack of appropriateness. The asset management takes place only in the financial instruments suitable for the respective customer taking into account the individually agreed investment strategy and the target market of the respective product. The purchase of products outside the target market is permissible in the case of deviations from positive target market criteria according to the best judgment of asset managers. An acquisition in case of non-observance of the negative target market (for example, lack of suitability for private investors / retail investors) is only permitted with explicit customer instruction.
(2) Place of execution and execution in case of customer instruction, priority of the customer instruction and its consequences The customer can determine the execution venue and the type of trading and the execution partner for a single transaction or in general. In this case, the institution is not obliged to forward the order in accordance with its best execution principles. The Institute will record such customer statements for documentation purposes. In the case of client instructions, the institution may not take any action it determines and implements as part of its execution policy in order to obtain the best possible results in executing the orders in respect of the financial instruments covered by the instructions in question. (3) Place of execution and type of execution in case of missing customer assignment Insofar as the customer does not give instructions to the institute for the forwarding of mediations or placing orders with asset managers, the statements under no. 8. Unless otherwise instructed by the customer, the institute is not obliged to carry out the execution on anything other than that described under no. 9 listed execution partners and / or execution venues to cause. (4) Selection of execution venues and execution partners The choice of execution venue and execution partner, which leads one to expect the best possible execution for the respective class (type) of financial instruments, is mainly based on the total fee for order execution and development (price for the financial instrument plus all the costs associated with the execution of the order, such as handling costs and any reimbursements for the benefit of the institute) as well as the quality of the execution partner and the previous experience of the institute in cooperation with the execution partner. Insofar as several execution venues and / or several execution partners expect an equally good execution, the institute will make a choice between them at its best discretion. When selecting the execution partner, the following criteria for execution quality and execution probability have been taken into account:

Total fee for order execution and settlement
Cost of order execution
Speed of order execution
Previous experience in cooperation
Access to execution venues
Security and risk-free execution of the order
Scope and nature of the order
Staff / technical equipment
Clearing system
emergency system
Fulfillment of the applicable for the execution partner
Transparency requirements Scope and nature of the contract Until further notice, the institution will consider the following execution venues for the execution of buy and sell orders for the following types of traded financial instruments and the following execution venues for non-traded financial instruments: The (selected) Criteria for the probability of execution over the respective execution partner are as follows:

Total value discounts / discounts
Total value of all costs
Number of orders received / offer questions
Number of transactions performed
Total value of completed transactions
Number of canceled / withdrawn
Order or offer questions

Median / average business sizes
Number of designated marketmakers
The detailed specification / publication of these criteria by the institute in relation to the execution partner and the indication of their source will be made immediately after their disclosure by the execution partner. Class of financial instruments Domestic shares and bonds Foreign shares and bonds with domestic issues Foreign shares and bonds with foreign notes Shares / shares in investment funds Other securities (participation certificates, subscription rights, etc.) Execution venue (for non-traded financial instruments) With the issuer or other trading partner who holds the financial statements (5) Contributions from Execution Partners The Institute will receive payments from the Executing Partner [taking into account the funding regime applicable to the Institution [which may be up to 90% of the Issue Price / Repurchase Price of the Product that is the subject of the Order as well as non-monetary benefits. The grants may be retained by the institute. Decisive basis for this are the regulations to charges and donations in No. 9 of the AGB of the institute. (6) Information and other reporting If, in the context of the execution principles, the institution has given another market participant a buy or sell order by forwarding or commissioned a commission agent (for all traded financial instruments) to conclude an execution transaction, it is not obliged to monitor whether this order has been executed immediately. Such an obligation is not justified for the institution even if the order is not executed by the other operator over a longer period of time. Incidentally, the institute is not obliged to prepare and transmit reports and / or settlements to the customer if and to the extent that reports and / or invoices are transmitted to the customer of third parties (eg custodian bank, execution partner) primarily responsible for the transmission of reports and / or settlements become. In this case, the institute adopts the reports and / or billing of the third party. The institute will inform the customer immediately about the execution, the execution venue and the execution type, if it has completed the execution transaction itself (direct business). Insofar as the institute does not forward orders to an execution partner or does not execute them itself, it will inform the customer immediately. The customer is entitled to demand information from the institute with regard to its strategies or provisions as well as its review procedure regarding the execution principles, as far as the information has to be given at due discretion taking into account the scope / conditions of the transactions / s made by the customer. When conducting retail orders, the Retail Institute will provide the client with a summary of the applicable execution policies, focusing on the total cost to the client. The Institute is entitled but not obliged to provide reports to the Customer in a protected area against unauthorized access on its website.

(7) Review of the Principles The Institute will examine regularly, but at least once a year, whether the selection of execution partners and execution venues in accordance with these principles would lead one to expect the best execution possible for each type of financial instrument. If and to the extent that there are indications that essential criteria are no longer valid or need to be weighted differently when determining the execution partners and / or execution venues, the institution will carry out additional reviews. The institute will immediately inform the customers about changes in the selection of execution partners and trading venues. Such changes will be effective even without the consent of the customer. Information on how to deal with conflicts of interest at Investfinans AB Conflicts of interest can not always be ruled out in the case of a financial services institution which provides a number of investment services to its clients and / or partly also designs (co-finances) financial instruments. The Institute has therefore established in writing effective, its size and organization as well as the nature, scope and complexity of the business / service principles of scope with conflicts of interest and will implement them permanently. These principles take into account i.a. Also, that the institute provides services to market participants with whom it is not affiliated and who are the concept (providers) of products distributed by the institute. The organizational and administrative measures taken to prevent or manage conflicts of interest are sufficient to ensure with reasonable assurance that the interests of customers are not harmed. Conflicts of interest may arise between our institute, our management, our employees and our customers or between our customers. Conflicts of interest may arise in particular from:
the area of financial portfolio management, in particular
between employees and customers of the institute as well as other (institutional) customers and customers;

the field of investment advice, especially between
Employees and customers as well as other customers and customers;

from contractual relationships institute with issuer /
Concepts of financial instruments, such as participation in emissions, cooperations;

from other business activities of our house,
in particular the sale of own issued financial instruments; in particular the distribution of such units / shares in self-managed or advised investment funds in which the institution is involved in the fund administration as an investment advisor and / or asset manager;

through performance-related remuneration of employees;
by obtaining information that is not
are publicly known;

from personal relationships of our employees or the
Management or persons associated with them;

in the participation of these persons in supervisory or
advisory boards; We have committed ourselves and our employees to high moral standards in order to avoid any interference with the provision of services by impartial interests that influence, for example, advice, order execution or asset management. We expect at all times diligence, lawful and professional action, the observance of market standards and, in particular, always the consideration of the best possible customer interest. In our company, an independent compliance officer is responsible for the direct identification and management of conflicts of interest. In detail, we have taken the following measures:

Creation of organizational procedures to safeguard the
the best possible customer interest in providing the services (eg approval procedure for new products – so-called target market definition);

Observance of the legal regulations on acceptance
and granting and disclosing benefits;

No collection of fees and granting of
Grants for direct trades on own issues

Creation of confidentiality areas through construction
of information barriers, the separation of responsibilities and / or spatial separation and as far as an exchange of information is required to regularly control this.
Display of intended securities transactions and
other personal affairs of the employees in products distributed or advised by the institute to the compliance office and execution of such transactions only with the consent of the institute;

Training of our employees;
Conflicts of interest that can not be avoided
We disclose this information to the affected customers prior to a transaction or consultation. Special features of asset management: In asset management, the client mandates the institution to make decisions on the composition of a portfolio of financial instruments and to implement those decisions in due discretion by buying and selling financial instruments. As part of the investment guidelines / strategy agreed with you, the bank makes the decisions on purchases and sales without obtaining the customer’s consent. This constellation can reinforce an existing conflict of interest. The institute addresses the resulting risks through appropriate organizational measures, in particular an investment selection process geared to the interests of the client. Another asset conflict typical of asset management can arise when agreeing a performance fee. Here it can not be ruled out that the administrator assumes disproportionate risks in order to achieve the highest possible performance and thus an increased remuneration. A risk reduction is achieved here, inter alia, by combining it with another fixed remuneration component. This risk is also reduced by adhering to the statutory loss disclosure threshold (10 percent). Grants The amount of the grants for placements and consultations is disclosed on a product-related basis before the service is provided. The same applies to small non-monetary benefits in the provision of asset management. Activity Placement of shares or shares in investment funds or shares Remuneration based on the brokerage of other financial instruments Price in Euro 0, – Refund
Once a maximum of 6% of the issue price / redemption price will be collected by the Institute for the placement. This fee will be partially paid from the initial charge / redemption charge.
Compensation list and benefits
Further details about donations will be made available to our customers upon request. Foreign costs and expenses are passed on in the same amount.

INVESTFINANS AB
Västertorpsvägen 135
129 44 Hägersten

Sverige

Phone: +46 840 83 91 01

www.investfinansab.eu

January 2018