Fund Prospectus 2021 - EVLI'S MUTUAL FUNDS OCTOBER 21, 2021 - Evli Bank
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CONTENTS General information 3 Mutual funds managed by the Management Company 5 Subscription and redemption of fund units 6 Fees and expenses 8 Responsible investment and addressing sustainability risks and impacts 10 Other information 17 Risks associated with investment instruments and the markets 18 Principles of ownership employed by mutual funds managed by Evli Fund Management Company and by Evli Fund Management Company as an asset manager 20 Evli Fund Management Company’s reporting to institutional investors 21 Taxation of the fund and unit holders 21 Evli’s continuous fund saving 22 Nav calculation errors 23 Information on mutual fund investments 24 Mutual funds’ fees and key figures 26 Mutual funds’ risk categories and investor target groups 28 Information for funds registered in Germany and for German investors 30 Information for Funds registered in Austria and for Austrian investors 32 Contact information 33 2
The information in the fund prospectus is complemented by each fund’s key investor information document and rules, and the funds’ price list. Before making an investment decision, investors are advised to familiarize themselves with this fund prospectus and the fund’s key investor information document and rules, which together form a complete entity. GENERAL INFORMATION Auditors This prospectus covers mutual funds and non-UCITS funds The auditor of the Management Company and all the mutual managed by Evli Fund Management Company Ltd, excluding funds under its control is PricewaterhouseCoopers Oy (with non-UCITS funds investing in real estate. Jukka Paunonen (APA) as the principally responsible auditor), with the deputy auditor being Mikko Nieminen (APA). Evli Fund Management Company Ltd. Depositary Evli Fund Management Company Ltd (hereinafter ‘the Man- agement Company’), founded on March 8, 1988, is a Finnish The Depositary of Evli’s mutual funds is Skandinaviska En- limited liability company as referred to in the Act on Com- skilda Banken AB (publ) Helsinki branch (registration number mon Funds whose line of business is to engage in mutual fund 0985469-4, address Eteläesplanadi 18, 00130 Helsinki, Finland). operations, asset management and other related activities. The Management Company also has a license granted by the The assets of a mutual fund are kept separate from the as- Finnish Financial Supervisory Authority to engage in activities sets of other mutual funds, the Management Company and related to Alternative investment funds (AIFMD). The Man- the custodian. The finances of the Management Company are agement Company is domiciled in Helsinki, Finland, and has fully separated from the assets of the fund and the fund’s share capital of EUR 1,700,000. The Management Company assets cannot be used to cover the debts of the Management is a fully-owned subsidiary of Evli Bank Plc (hereinafter ‘Evli Company or the custodian. A fund cannot go bankrupt, but Bank’). depending on the market conditions, the value of a fund unit can increase or decrease. The Management Company invests assets acquired from the public on behalf of the unit holders in accordance with the The Depositary’s task is to ensure that the law, the fund rules fund rules approved by the Finnish Financial Supervisory and the regulations issued by authorities are complied with Authority. The Management Company acts in its own name in the activity of the mutual funds and the Management on behalf of the fund and exercises the rights related to the Company, and shall attend to the other duties provided for assets in the fund. a depositary in the Act on Common Funds and the Act on Alternative Investment Fund Managers. The Depositary may, In its operations, the Management Company treats its unit in accordance with depositary agreement, legislation and holders equally. The Management Company aims to avoid regulations, delegate these tasks to one or more third parties. conflicts of interest in its operations and, in the event of The depositary may use one or more sub-custodians if neces- conflicts of interest, ensure that the mutual funds managed sary. Current information on the sub-custodians is available by the Management Company, their unit holders and other from the Management Company. clients are treated equally. The Depositary ensures to the best of its abilities that the Board of Directors and Managing Director mutual fund’s assets are kept separate from the assets of the Depositary or any sub-custodian in the event of their possible Chairman insolvency. The Depositary performs its activities and related Maunu Lehtimäki, Managing Director, Evli Bank Plc supervisory tasks for the benefit of fund investors separately from mutual fund operations. In order to manage and avoid Members conflicts of interest, the appropriate independence and segre- Kim Pessala, Director, Evli Fund Management Company Ltd gation of operations have been observed in the organization Outi Helenius, Head of Sustainability, Evli Bank Plc of the Depositary and mutual fund operations. Juho Mikola, Chief Financial Officer, Evli Bank Plc Petri Olkinuora*, M.Sc. (Tech), MBA, professional Board member Up-to-date information on the Depositary, provided in accor- Lea Keinänen*, MBA dance with the fund legislation in force at the time, is avail- *Independent Board Representative elected by the unit holders able to investors on request from the Management Company. Managing Director Tero Tuominen 3
Agents In managing mutual fund activities, the Management Com- pany may use external management and advisory services including portfolio management, accounting, information technology and subscription and redemption order reception services. Fund unit subscription and redemption orders are re- ceived by Evli Bank. Fund units are also brokered by Elite Alfred Berg, Nordea Bank and Nordnet Bank in Finland, Avanza Bank, Fondmarknaden.se, MFEX Mutual Funds Exchange, Nordea Bank, Nordnet Bank and Swedbank in Sweden and ALLFUNDS Bank and Banco Inversis. Covering liability risks The Management Company has the sufficient additional own funds or indemnity insurance according to Chapter 6, sec- tion 4 of the Act on Alternative Investment Fund Managers to cover the damages that the alternative investment fund manager is responsible for according to this Act. Remuneration practices The objective of the Evli Group’s remuneration model is to support the implementation of the company’s strategy as well as promote its competitiveness and long-term financial suc- cess. A further aim is to contribute to a positive trend in Evli’s shareholder value, committing the company employees to the company’s objectives in the long run. A competitive fixed basic salary constitutes a solid foundation for maintaining and constantly developing basic functions. To promote both Evli’s short-term growth objectives and the attainment of its strategic goals, the company also has an annually adopted reward system based on annually varying salary elements. The long-term incentive systems, in turn, are in place to support the company’s strategic development and to commit the key persons to Evli’s operations. Further information on remuneration practices can be found at the address www.evli.com. Annual and semi-annual reviews Annual and semi-annual reviews of funds are available from the Management Company and website www.evli.com/funds. The financial year of the funds is calendar year. 4
MUTUAL FUNDS AND NON-UCITS FUNDS MANAGED BY THE MANAGEMENT COMPANY Equity funds Launch date Rules approved* Merger history** Evli Emerging Frontier 08.10.2013 01.07.2020 Evli Emerging Markets Equity (10.7.2014) Evli Equity Factor Europe 14.10.2015 01.07.2020 Evli Equity Factor Global 25.08.2020 01.07.2020 Evli Equity Factor USA 04.08.2016 01.07.2020 Evli Europe 30.08.2000 01.07.2020 Evli Europe Quant Index (30.9.2011), Evli European Smaller Companies (4.5.2009), Evli Euro 50 (3.10.2005) Evli Finland Select 16.10.1989 01.07.2020 Evli Finnish Small Cap 04.12.1992 01.07.2020 Evli GEM 25.01.2016 01.07.2020 Evli Russia (23.4.2019) Evli Global 08.04.1994 01.07.2020 Evli Climate (31.3.2014) Carnegie Multifund (15.2.2010) Evli Global X 31.05.2018 01.07.2020 Evli Japan 25.08.2005 01.07.2020 Evli Nordic 29.09.2006 01.07.2020 Head Nordic Select Dividend (20.1.2017), Evli Nordic TMT (25.6.2008) Evli North America 06.10.2003 01.07.2020 Evli Sweden Equity Index 30.05.2013 01.07.2020 Evli Swedish Small Cap 29.05.2008 01.07.2020 Evli Sweden Select (9.1.2019) Fixed income funds Evli Corporate Bond 14.09.1999 01.07.2020 Evli Emerging Markets Credit 10.10.2013 01.07.2020 Evli Ruble Debt (2.6.2014) Evli Euro Government Bond 16.12.1994 01.07.2020 Evli Inflation-Linked Bond (22.2.2012), Carnegie Euro Bond Fund (15.2.2010) Evli Euro Liquidity 31.01.1996 01.07.2020 Evli Money Manager+ (1.10.2010) Evli European High Yield 15.03.2001 01.07.2020 Evli European High Yield SEK (26.9.2012) Evli European Investment Grade 07.05.2001 01.07.2020 Evli Green Corporate Bond 17.08.2020 01.07.2020 Evli Nordic 2025 Target Maturity 02.02.2021 09.07.2020 Evli Nordic Corporate Bond 16.04.2007 01.07.2020 Evli Target Bond (18.8.2008) Evli Short Corporate Bond 30.09.1997 01.07.2020 Evli Euro Interest (3.10.2005) Evli Target Maturity Nordic Bond 2023 06.05.2019 01.07.2020 Balanced funds Evli Finland Mix 01.11.1995 01.07.2020 Evli Global Multi Manager 30 21.02.2002 01.07.2020 Evli Global Asset Allocation (22.4.2018) Evli Euro Mix (25.6.2008), Evli Global Multi Manager 25 and 50 (21.2.2002) Evli Global Multi Manager 50 16.11.1999 01.07.2020 Carnegie Optimum+ Fund (15.2.2010) Evli Wealth Manager 21.11.2006 01.07.2020 Non-UCITS funds Evli Factor Premia 01.11.2017 01.10.2020 Evli Leveraged Loan 31.08.2021 31.08.2021 Evli Q7 07.10.2016 01.10.2020 * Most recent date of approval of rules. The rules were approved in Finland. ** Funds that have merged into the fund and merger date. 5
SUBSCRIPTION AND REDEMPTION OF FUND UNITS received the required information on the subscriber or actual beneficiary and the subscriber’s identity. Subscription of fund units A subscription statement can be viewed and printed out The Evli Fund Management Company / Evli Bank accepts sub- through the My Evli online service after the transaction has scription orders on each (Finnish) banking day until 2.00 pm been carried out. Unless the Management Company is oth- (CET + 1). Fund units may also be subscribed for on My Evli erwise informed, the fund units will be registered as growth online service or at the address www.evli.com/funds. The rules units (B) and entered, free-of-charge, in the fund unit register of non-UCITS funds may on a fund-by-fund basis provide for maintained by the Management Company. fewer subscription opportunities and deadlines for submitting a subscription order. Precise information on the subscription of fund units and on the trading calendar is provided in the respective fund’s rules The minimum subscription in Evli’s mutual funds is normally and key investor information document and at the address EUR 1,000 (growth/series B units) or EUR 5,000 (yield/series www.evli.com/funds. A units). Ad¬ditional subscriptions may be made to all mu- tual funds with a minimum payment of EUR 500. The num- Redeeming fund units or transferring units from one ber of fund units received in conjunction with subscription fund to another is determined to the nearest four decimal places. Each unit holder’s fund units entitle him/her to a share of the mutual Mutual fund units may be redeemed (exchanged for cash) in fund’s assets that is proportional to his/her share of the total part or in full on every banking day. Redemption orders sub- number of fund units, taking into account the relative values mitted before 2:00 pm (Finnish time, CET+1) will normally be of the fund unit series and classes. The minimum subscription executed at the net asset value confirmed for the same bank- amounts per fund and share class of mutual funds and non- ing day. The rules of non-UCITS funds may on a fund-by-fund UCITS funds can be found at www.evli.com/funds and in this basis include fewer redemption possibilities and deadlines for fund prospectus. the submission of redemption orders. Fund units for C and I share classes may only be acquired by Fund unit redemption/transfer orders may be submitted by Institutional Investors who meet the requirements established telephone, fax or on My Evli online service. The assets obtained from time to time by the Management Company. The I units from redemption, are paid into the unit holder’s cash account are designed principally for investment of assets of Institu- at Evli Bank. If the fund has to sell securities it owns, the ex- tional Investors, such as insurance companies, pension funds, ecution of the redemption transaction may be delayed due to fund management companies and collective investment the market conditions and the liquidity of the target markets. schemes, credit institutions, investment firms or other profes- The redemption will then be executed at the value of the fund sionals in the financial sector acting on their own behalf or on unit confirmed for the day on which it is possible to carry out behalf of their underlying customers within the framework of the redemption (or partial redemption). A redemption state- a discretionary mandate, even if such a customer would not be ment can be viewed and printed out on My Evli online service qualified as an institutional investor itself, national or regional after the transaction has been carried out. authorities, or family offices provided that they are portfo- lio companies through which a family manages its financial A unit holder may switch fund units to units in another Evli interests. The Management Company may, in its absolute dis- fund, or switch from one fund class or series to another within cretion, delay the acceptance of any subscription/purchase for a fund, subject to the limits on switching of units. Switches C or I share classes until such date as it has received sufficient are executed in the same way as subscriptions and redemp- evidence of the qualification of the investor as an Institutional tions. At the discretion of the Management Company, trans- Investor. If it appears at any time that a holder of C or I units is fers from one fund to another may be carried out so that the not an Institutional Investor, the Management Company will subscription takes place on the same day as the redemption. switch such units into class B units in the relevant fund and notify the relevant unit holder of such switch. The Manage- Precise information on the redemption of fund units and the ment Company may waive applicable minimum investment trading calendar is provided in the respective fund’s rules and requirements for I and C share classes in its discretion. key investor information document and at the address www. evli.com/funds. We respectfully ask our customers to inform Evli Bank of the subscriber’s name, address, telephone number, social security number/business code and country of taxation as well as the name of the fund and unit class (growth (B) or yield (A)) by telephone +358 (0)9 4766 9701 prior to paying the subscrip- tion amount. The subscription amount is paid to Evli Bank’s account by using a personal reference number. This refer- ence number is provided when the client relationship is set up. A client relationship is required in order to subscribe for funds. The Management Company has the right to leave the subscription or subscrip¬tion order unexecuted if it has not 6
Order execution and payment schedule Ordinary funds Subscription and redemption orders given before the cut-off time are executed at the net asset value (NAV) confirmed for the same banking day. If the order is given on a day that is not a Finnish banking day or the day is not trading day for the fund, it will be executed at the net asset value confirmed for the next possible banking day or the fund’s trading day. Subscriptions and redemptions will be paid two banking days from the trade date. The payment schedule for Evli Euro Liquidity fund differs from other ordinary funds: subscriptions and redemptions will be paid one banking day after the trade date. Order date Trade date Payment date Cut-off time for orders (T)* Execution (T)* Transfer of payment from/to account 2:00 pm. Orders received before the cut-off time will T+2 (Finnish time, CET+1) be executed at NAV confirmed for the same trading day. Evli Euro Liquidity: T+1 Examples Subscription Redemption Order is given on Friday by 2:00 pm. The sub- Order is given on Friday by 2:00 pm. The scription is executed at NAV confirmed for redemption is executed at NAV confirmed Friday and the subscription amount is debited for Friday and the redemption amount is from the account on Tuesday. credited to the account on Tuesday. Evli Euro Liquidity: Evli Euro Liquidity: Order is given on Friday by 2:00 pm. The sub- Order is given on Friday by 2:00 pm. The scription is executed at NAV confirmed for redemption is executed at NAV confirmed Friday and the subscription amount is debited for Friday and the redemption amount is from the account on Monday. credited to the account on Monday. T = Trade date * Delayed funds In delayed funds the subscription and redemption orders given before the cut-off time are executed at the net asset value (NAV) confirmed for the following banking day. If the order is given on a day that is not a Finnish banking day or the day is not a trading day for the fund, it will be executed at the net asset value confirmed two days after the order date. Subscriptions and redemptions will be paid two banking days from the trade date. The following Evli funds are delayed funds: Evli GEM, Evli Japan, Evli Global and Evli Global X. Order date Trade date Payment date Cut-off time for orders (T-1)* Execution (T)* Transfer of payment from/to account 2:00 pm. Orders received before the cut-off time will T+2 (Finnish time, CET+1) be executed at NAV confirmed for the next banking day following the order day. Examples Subscription Redemption The order is given on Friday by 2:00 pm. The The order is given on Friday by 2:00 pm. The subscription is executed at NAV confirmed for redemption is executed at NAV confirmed Monday and the subscription amount is deb- for Monday and the redemption amount is ited from the account on Wednesday. credited to the account on Wednesday. T = Trade date * 7
Deviating funds The Investor shall be liable for any costs and damages incurred by the fund as a direct or indirect result of late or non-pay- In some non-UCITS funds, the receipt and execution of orders ment and cancellation of the fund units, and costs incurred by differs from that described above. In these funds, subscriptions the Management Company in taking proceedings against the and redemptions will be received and executed as described Investor. Costs and damages payable by the investor include, in the fund rules and at the times specified in the fund rules. without limitation, interest expenses charged by the custodian, any movement in price of the fund units between the transac- The following fund is deviating fund: Evli Leveraged Loan Fund tion date (subscription) and the cancellation date (redemption), and any other related costs. The Management Company may Payment of subscription and consequences set-off costs or damages from the receivables of the investor. of payment default FEES AND EXPENSES Retail investors’ subscriptions are processed on actual mode basis. Subscriptions are confirmed, in accordance with fund Fees payable to the Management Company specific rules, at the NAV of the banking day or the following bank day when the subscription order has been received be- A management fee, which may consist of a fixed or a fixed and fore the cut-off time and investor’s Evli Bank cash account has performance-based component, is payable to the Manage- sufficient funds for the subscription payment. A reservation ment Company for its services. The management fee includes equal to the subscription payment is made on to the investor’s the fee payable to the custodian for custody of the securities cash account. The subscription payment is debited from the and related tasks. The maximum amount of the fixed manage- investor’s cash account retrospectively at Payment Date. ment fee and its determinants are specified in section 11 of the fund’s rules. The fixed (and any performance-based) fee Subscriptions from institutional investors or distributors is taken into account when calculating the daily net asset (whether on behalf of institutional investors or non-institu- value of the fund unit, and is not charged separately from tional investors) are handled on a contractual mode basis. the unit holder. The Management Company can agree upon Subscriptions are confirmed, in accordance with fund specific the amount of the management fee that the client is charged, rules, at NAV of the banking day or the following bank day considering the overall client relationship or other justifiable when the subscription order has been received before the reason. It can also pay fee reimbursements to the client. Fee cut-off time and before the subscription payment is available reimbursements may primarily concern management fees col- at investor’s Evli Bank cash account. Subscription payment lected for share classes A and B. is debited retrospectively at Payment Date. The subscription payment must reach Evli by 3:00 pm. (Finnish time, CET+1) Mutual funds may charge a performance-based management at Payment Date. The Management Company has at its own fee if rules of the fund so provide. The performance-based discretion the right to demand that the subscription payment fee is determined on each valuation day on the basis of the is made available for the fund on the subscription day on amount by which the return (increase in the value of the investor´s Evli Bank cash account to ensure timely payment of growth unit after the deduction of the fixed fee before de- subscriptions. Such discretion may be exercised, for example, ducting the performance-based fee) of the fund unit series if there are recurring payment delays or institutional investor exceeds the hurdle rate or the return of the benchmark index. or distributor is deemed to have insufficient internal controls The hurdle rate or benchmark index applied in the calcula- to ensure timely payments. tion of each fund’s performance-based fee is presented in the fund’s key investor information document. Fund units are issued upon acceptance of a subscription order on the condition that complete subscription payment is re- The following two conditions must be met for the perfor- ceived from the investor by the Payment Date. Until complete mance-based fee to be charged: payment for the fund units is received from the investor, the 1. The value of the fund unit series exceeds its highest his- fund units are pledged for the benefit of the fund. During this torical value; and period, voting rights and entitlements to dividend payments 2. The return of the fund unit series exceeds the hurdle rate are suspended, and the investor cannot switch or transfer the or benchmark index return calculated for each valuation subscribed fund units. date over the last 24 months. If subscription payment has not been received in accordance The highest historical value of a fund unit refers to the value with the fund’s payment schedule, the Management Company of the fund unit for which a performance-based fee was may cancel the fund units immediately without prior notice previously charged or, if no performance-based fee has been to the investor, or delay dividend payments on existing hold- charged, the first published value of the fund unit series. ings in fund units and other receivables to the investor until complete payment for the subscribed fund units have been If both conditions are met, two return figures are calculated: received by the fund. Any money returnable to the investor 1. The return between the value of the fund unit series on held by the Fund Management Company will be held without the valuation date and the historical highest value. payment of interest. 2. The return between the value of the fund unit series on the valuation date and the value of the fund unit series 8
adjusted by either the hurdle rate or the benchmark re- Example 3. turn, calculated and published on each of the previous 24 months, of which the smaller is selected. The annual hurdle rate applied in the calculation of the fund’s performance-based fee is 8%. A performance-based fee was The smaller of the two previous return figures is selected previously charged from the fund on February 9, 2021, when as the basis for charging the performance-based fee. The the value of the fund unit series was 216.393. The value of the amount of the performance-based fee is the percentage (typi- fund unit on February 12, 2021 was EUR 216.61672 before the cally 20%), in accordance with the fund’s rules, of the above- charging of the performance-based fee. mentioned return figure. The amount of both the fixed and the performance-based fee will be calculated in accordance The conditions for charging the performance-based fee are with the fund’s valuation cycle and deducted from the value fulfilled, as the fund has generated annual return of over 8% of the fund unit series as a debt of the fund to the Manage- in each period calculated during the previous 24 months and ment Company. The performance-based fee and its amount the value of the fund unit is higher than the value for which a are specified in the fund-specific rules of each fund. performance-based fee was previously charged. Examples of applying the performance-based fee: 1 day 2 days 3 days .. 24 mo Return 0.1205% 0.3859% 0.1034% .. 32.50% Example 1. Annual 43.98% 70.43% 12.58% .. 15.10% On December 31, 2020 the value of the fund unit series is EUR return 110, while on December 31, 2018 it was EUR 80, meaning Benchmark 0.0213% 0.0427% 0.0640% .. 16.64% that the fund unit has returned 37.5% during the previous index return 24 months (annual return: 17%). The applicable (annualized) Return 0.099% 0.343% 0.039% .. 15.860% hurdle rate is 8%. A performance-based fee was last charged differential from the fund unit series on May 13, 2015, when the value of the fund unit was EUR 120. First, the smallest return differential between the fund unit and the benchmark index over 24 months is calculated, which The conditions for charging a performance-based fee are not is 0.039%. In addition, the return in relation to the value of met on December 31, 2020. The return of the fund unit series the fund unit for which a performance-based fee was previ- exceeds the hurdle rate requirement in accordance with the ously charged is calculated (216.61672/216.393-1), which is hurdle rate (17% is greater than 8%) calculated for every val- 0.103%. After this, the smaller of the return figures is selected uation date over the previous 24 months, but the value of the (0.039% vs. 0.103%), from which the performance-based fee fund unit series does not exceed its highest historical value is charged. If the performance-based fee is 20%, 0.039% * (110 is less than 120). Therefore, the first condition required 20%, which equals 0.0078%, would be charged from the fund for charging the performance-based fee is not fulfilled, and unit as performance-based fee. charging the performance-based fee requires both the first and the second condition to be fulfilled. Replacement of benchmark index Example 2. Should the benchmark administrator used in calculating the performance-based fee discontinue or substantially change In this example as well, the annual hurdle rate applied in the the administration of the index, the Management Company calculation of the fund’s performance-based fee is 8%. The will endeavor to replace the benchmark with another compa- value of the fund unit series was EUR 143 on December 31, rable index in accordance with its continuity plan. The bench- 2020. A performance-based fee was previously charged from mark administrators that may be used in the calculation of the fund on June 30, 2017 when the value of the fund unit performance-based fees are listed in the register maintained series was EUR 120. The fund values are calculated twice a by the European Securities Market Authority (ESMA) as re- year, and the fund has generated the following returns on quired by the Benchmarks Regulation. December 31, 2020: Other costs to be charged from the fund 6 mo 1 yr 1.5 yrs 2 yrs Return 9.16% 12.60% 16.26% 11.72% The costs that may be charged to the fund’s assets include not only the management fee and securities transaction costs, Annual return 18.32% 12.60% 10.84% 5.86% but also the investment research and analysis expenses in ac- cordance with an annually approved budget, transaction fees The conditions for charging a performance-based fee are not of foreign sub-custodians related to the custody, transfer or met on December 31, 2020. The value of the fund unit series registration of securities between the registers kept by differ- exceeds the fund’s previous historically highest value (143 is ent sub-custodians, as well as third party services related to greater than 120), but the return of the fund unit series does these, including services offered by a notary public, registra- not exceed the return according to the hurdle rate calculated tion authority or tax or legal service providers. for every valuation date over the previous 24 months (5.86% is less than 8%). Therefore, the second of the conditions for charging the performance-based fee is not met. 9
Execution of orders Money transfer to client’s contra 50 € normal account in a foreign bank without 100 € express The Management Company allocates the execution of equity deductions trading investment decisions made on behalf of funds to a (Evli covers the costs charged by the recipient bank. separate unit (execution desk) at Evli Bank that is specialized If the foreign bank charges additional fees later, in the execution of orders. The persons responsible for the the customer will be responsible for these.) funds’ portfolio management do not, as a main rule, partici- pate in the execution of investment decisions. The execution RESPONSIBLE INVESTMENT AND ADDRESSING desk is responsible for the competitive execution of orders and SUSTAINABILITY RISKS AND IMPACTS for observing the best execution requirements that are related to these by forwarding the orders to the counterparties ap- Responsible investment (ESG, SRI) proved by the Management Company. The Management Company monitors the execution and quality of Evli Bank’s Evli Fund Management Company takes account of sustain- and counterparties’ trades. Evli Bank’s execution desk collects ability risks in its investments and in particular of the invest- a trading fee for its work, which includes the counterparties’ ments’ principal adverse impacts on sustainability factors in trading fees. accordance with Evli Group’s Principles for Responsible In- vestment. Sustainability risk refers to an environmental, social Funds may also invest their assets in the units of other mutual or governance event or condition that, if it occurred, could funds managed by the Management Company. Such invest- cause an actual or a potential material negative impact on the ments are subject to management fees in accordance with value of the investment. Sustainability factors refer to envi- the target funds’ price lists but are not subject to subscription ronmental, social and employee matters, respect for human or redemption fees. rights, and anti-corruption and anti-bribery matters. Signifi- cant sustainability risks can affect the financial performance Fees collected for subscription and redemption of fund of investment instruments, and therefore the return of funds. units Evli Group’s Principles for Responsible Investment are asset class-specific and cover all the active investments under Evli’s The Management Company may collect a fee for subscription management. Evli Group’s Principles for Responsible Invest- or redemption of fund units, the maximum amount of which ment are publicly available on Evli’s website at www.evli.com/ and the determinants are specified in section 10 of the fund’s en/responsibility/responsible-investing. rules. The subscription fee will be collected from the sum paid by the customer to the mutual fund’s account. The redemp- At Evli, responsible investment has been integrated into in- tion fee will be collected from the sum redeemed by the cus- vestment decisions and systematic processes have been put tomer. In connection with a subscription or redemption, the in place for it. Evli’s Principles for Responsible Investment Management Company may transfer the deducted fee partly and Climate Change Principles determine Evli’s responsible or wholly to the fund to cover the trading costs arising from investment practices. The Principles for Responsible Invest- the fund’s investment activity. ment and the Climate Change Principles are included in the fund prospectus after the presentation of the fund-specific The Board of Directors of the Management Company will con- responsibility processes. In addition, Principles of Ownership firm the valid list of service fees, by which the fees charged at define practices for engagement, voting and proxy voting, and any particular time are determined. The list of service fees is are also included in the prospectus. available at the address www.evli.com/en/servicefees, or from the Investor Service. Evli’s funds are divided into two categories for exclusion: gen- eral exclusion funds and wider exclusion funds. The sectors Other fees excluded by funds exercising wider exclusion are described in the fund-specific texts below. Switch from one unit class to another EUR 20 Additional report of fund holdings or EUR 25 General exclusion covers manufacturers of controversial statement by mail weapons (landmines, cluster munitions, nuclear weapons, Registration of change in ownership EUR 20 depleted uranium, chemical weapons and biological weapons) relationship with 0% revenue threshold, as well as tobacco manufacturers and adult entertainment producers and companies practicing in controversial lending (including so-called quickie loan com- Payment of redemption transaction: panies) with 5% revenue threshold. A company that violates EU money transfer (EU transfer) to 0€ the principles of the UN Global Compact may be excluded client’s contra account from investment targets if the company is not anticipated to EU money transfer (EU transfer) to other 20 € change its operating practices or the company is not ready to than client’s contra account react to engagement attempts. In addition, Evli’s funds do not invest in the shares of Evli Bank. Money transfer to client’s contra 25 € normal account in a foreign bank (excluding 60 € express accounts in Swedish banks and EU transfers) In line with Evli’s Climate Change Principles, the funds avoid investing in companies where at least 30% of their revenue 10
comes from thermal coal mining, the use of thermal coal in Evli Global Multi Manager 30 8 energy production or the extraction of oil sands. This exclusion Evli Global Multi Manager 50 8 may be waived if the company has a clear plan to change its Evli Global X 8 operations. In addition, companies producing peat for energy production are excluded. Evli Green Corporate Bond 9 Evli Japan 8 In accordance with the Sustainable Finance Disclosure Regu- Evli Leveraged Loan 6 lation (SFDR), Evli’s funds are classified into three categories Evli Nordic 8 with respect to sustainability factors: article 6 (so-called Evli Nordic 2025 Target Maturity 8 mainstream) funds do not address sustainability factors, Evli Nordic Corporate Bond 8 article 8 (so-called light green) funds promote sustainability factors among other features, and article 9 (so-called dark Evli North America 8 green) funds aim to make sustainable investments. Informa- Evli Q7 6 tion related to the Sustainable Finance Disclosure Regulation Evli Short Corporate Bond 8 is presented, where applicable, as part of the fund prospec- Evli Sweden Equity Index 6 tus and on Evli’s website at www.evli.com/en/responsibility/ Evli Swedish Small Cap 8 responsible-investing. Evli Target Maturity Nordic Bond 2023 8 The terms ESG and UN Global Compact are used in the fund- Evli Wealth Manager 6 specific texts below. ESG refers to Environmental, Social and Governance factors. The UN Global Compact is made up of Equity funds ten principles which are derived from the United Nations’ (UN) Universal Declaration of Human Rights, the International Evli Emerging Frontier Labour Organization’s (ILO) Declaration on Fundamental Prin- SFDR classification: article 8, light green ciples and Rights at Work, the UN Rio Declaration on Envi- ronment and Development and the UN Convention Against The fund promotes sustainability factors as part of investment Corruption. The principles of the UN Global Compact require operations by integrating responsibility factors into invest- the observance of human rights and environmental issues and ment analyses and by engaging with and excluding compa- the implementation of anti-corruption activities, for example. nies. ESG aspects are integrated into investment decisions not only by considering their financial impacts on the company, SFDR classification of Evli’s funds: but also by assessing unquantifiable good governance factors and compliance with the principles of the UN Global Com- Article 6 (mainstream) funds pact. The fund’s investment strategy is based on stock selec- do not address sustainability factors. tion, and therefore focuses on the ESG risks relevant to each Article 8 (light green) funds individual company. Whenever a company has a significant promote sustainability factors among other features. and unresolved ESG issue, as defined by the research process, the company becomes ineligible for investment. The analysis Article 9 (dark green) funds is performed by the fund’s portfolio managers, who meet with aim to make sustainable investments. the management of the company before making an invest- Fund Article ment decision. In addition to Evli’s general exclusion practices, the fund excludes alcohol and weapons manufacturers, gam- Evli Corporate Bond 8 bling companies and companies mining, extracting and drill- Evli Emerging Frontier 8 ing fossil fuels from its investments. The fund does not have a benchmark index. Evli Emerging Markets Credit 8 Evli Equity Factor Europe 8 Evli Europe, Evli GEM, Evli Global, Evli Japan, Evli Equity Factor Global 8 Evli North America, Evli Nordic Evli Equity Factor USA 8 SFDR classification: article 8, light green Evli Euro Government Bond 6 The funds promote sustainability factors as part of investment Evli Euro Liquidity 8 operations by integrating responsibility factors into invest- Evli Europe 8 ment analyses and by engaging with and excluding compa- Evli European High Yield 8 nies. ESG aspects are integrated into investment decisions not Evli European Investment Grade 8 only by considering their financial impacts on the company, Evli Factor Premia 6 but also by assessing unquantifiable good governance factors Evli Finland Mix 8 and compliance with the principles of the UN Global Compact. The funds’ investment strategies are based on stock selection, Evli Finland Select 8 and therefore focus on the ESG risks that are relevant to each Evli Finnish Small Cap 8 individual company. Whenever a company has a significant Evli GEM 8 and unresolved ESG issue, as defined by the research process, Evli Global 8 the company becomes ineligible for investment. Analyses are 11
carried out by the funds’ portfolio managers with the support phase and in discussions with the companies’ management. of MSCI’s ESG database and research and Evli’s Responsible The fund follows Evli’s wider exclusion practices. In addition Investment team. The funds follow Evli’s general exclusion to Evli’s general exclusion practices, the fund excludes compa- practices. The companies invested in by the funds are moni- nies with significant business in the following sectors: alcohol, tored for violations of UN Global Compact standards and weapons, tobacco, adult entertainment or gambling. In addi- the Climate Change Principles, and they are engaged with or tion, fossil fuel extracting, mining and drilling companies are excluded if violations are detected. The ESG indicators of the excluded from the fund’s investments. The companies invest- funds are reported in fund-specific ESG reports, which are ed in by the fund are monitored for violations of UN Global updated four times a year. The funds’ benchmark indexes are Compact standards and the Climate Change Principles, and market-based indexes that do not consider sustainability risks they are engaged with or excluded if violations are detected. or sustainability factors. The benchmark index used by each The fund’s ESG indicators are reported in a fund-specific ESG fund can be found in the relevant fund-specific key investor report which is updated four times a year. The fund’s bench- information document. mark index is a market-based index that does not consider sustainability risks or sustainability factors. The benchmark Evli Global X index used by the fund can be found in the fund-specific key investor information document. SFDR classification: article 8, light green The fund promotes sustainability factors as part of investment Evli Equity Factor Europe, Evli Equity Factor Global, operations by integrating responsibility factors into invest- Evli Equity Factor USA ment analyses and by engaging with and excluding compa- SFDR classification: article 8, light green nies. ESG aspects are integrated into investment decisions not only by considering their financial impacts on the company, The funds promote sustainability factors as part of investment but also by assessing unquantifiable good governance factors operations by integrating responsibility factors into invest- and compliance with the principles of the UN Global Compact. ment analyses and by excluding them. The funds’ investment The fund’s investment strategy is based on stock selection, and process is quantitative and is based on academically verified therefore focuses on the ESG risks relevant to each individual factors, ESG integration and broad diversification. The ESG company. Whenever a company has a significant and unre- process is also systematic, and the ESG criteria are fully inte- solved ESG issue, as defined by the research process, the com- grated in the funds’ strategies and are always the same when pany becomes ineligible for investment. Analysis is carried out making investment decisions. by the fund’s portfolio managers with the support of MSCI’s ESG database and research and Evli’s Responsible Investment The funds’ ESG process is based on excluding certain sectors team. The fund follows Evli’s wider exclusion practices. In ad- and companies and selecting the best companies in their in- dition to Evli’s general exclusion practices, the fund excludes dustry in terms of ESG score. First, companies with significant companies with significant business in the following sectors: business in the following sectors are excluded: weapons, alco- alcohol, weapons, tobacco, gambling, fossil fuel mining, ex- hol, tobacco, mining of thermal coal, gambling or adult enter- traction, drilling and refining, nuclear power, adult entertain- tainment. Second, red flag companies determined by the MSCI ment or GMOs. The fund may additionally exclude individual or the ISS ESG (companies with serious breaches of standards, companies on the basis of international business standards. including those that have breached UN Global Compact stan- The companies invested in by the fund are monitored for dards) are excluded from the funds. Third, companies that are violations of UN Global Compact standards and the Climate in the top 5% in carbon intensity are excluded from the funds. Change Principles, and they are engaged with or excluded if Fourth, companies holding fossil reserves are excluded from violations are detected. The fund’s ESG indicators are reported the funds. Fifth, the funds’ equities are selected from a group in a fund-specific ESG report which is updated four times a of companies that belong in the top 80% of their industry on year. The fund’s benchmark index is a market-based index that the basis of an ESG score determined by MSCI. In addition, the does not consider sustainability risks or sustainability factors. funds follow Evli’s general exclusion practices. The benchmark index used by the fund can be found in the fund-specific key investor information document. The companies in the funds are monitored for violations of the Climate Change Principles, and they are engaged with or Evli Swedish Small Cap excluded if violations are detected. The ESG indicators of the funds are reported in fund-specific ESG reports, which are SFDR classification: article 8, light green updated four times a year. The funds’ benchmark indexes are The fund promotes sustainability factors as part of investment market-based indexes that do not consider sustainability risks operations by integrating responsibility factors into invest- or sustainability factors. The benchmark index used by each ment analyses and by engaging with and excluding compa- fund can be found in the relevant fund-specific key investor nies. In the investment process the portfolio manager assesses information document. the company from an ESG perspective as part of the overall investment decision. In the ESG analysis, the portfolio man- Evli Sweden Equity Index ager sets the most important ESG themes and risks for the SFDR classification: article 6, mainstream company and the company’s sector. Identifying companies’ key ESG themes and risks helps the portfolio manager focus As the fund is a passive index fund and tracks the index below, on the most important areas in the investment monitoring its investment decisions do not take sustainability factors into 12
account. The fund follows Evli’s general exclusion practices, Evli Target Maturity Nordic Bond 2023 except for tobacco manufacturers. The fund’s ESG indicators SFDR classification: article 8, light green are reported in a fund-specific ESG report which is updated four times a year. The fund promotes sustainability factors as part of investment operations by integrating responsibility factors into invest- Evli Finland Mix, Evli Finland Select, Evli Finnish Small Cap ment analyses and by engaging with and excluding compa- nies. Before an investment decision, the ESG analysis focuses SFDR classification: article 8, light green on matters that are quantifiable through the quality of a cor- The funds promote sustainability factors as part of investment porate bond. Especially in company analysis, the fund focuses operations by integrating responsibility factors into invest- on the main ESG risks of each company. If a company has ment analyses and by engaging with and excluding compa- significant and unresolved ESG issues, the company becomes nies. In the investment process the portfolio manager assesses ineligible for investment. Analysis of ESG factors is based on the company from an ESG perspective as part of the overall the portfolio manager’s overall picture of the company based investment decision. In the ESG analysis, the portfolio man- on the information provided by the company, the portfolio ager sets the most important ESG themes and risks for the manager’s own analysis and MSCI’s ESG data. The fund fa- company and the company’s sector. Identifying companies’ vors companies with higher ESG scores in its investments; i.e. key ESG themes and risks helps the portfolio manager focus the fund uses positive selection. In addition to Evli’s general on the most important areas in the investment monitoring exclusion practices, the fund excludes alcohol and weapons phase and in discussions with the companies’ management. manufacturers, gambling companies and fossil fuel min- The funds follow Evli’s general exclusion practices. The gen- ing, extracting and drilling companies from its investments. eral meetings of the companies in the funds are attended on The companies invested in by the fund are monitored for the basis of a company-specific assessment. The companies violations of UN Global Compact standards and the Climate invested in by the funds are monitored for violations of UN Change Principles, and they are engaged with or excluded if Global Compact standards and the Climate Change Principles, violations are detected. The fund’s ESG indicators are reported and they are engaged with or excluded if violations are de- in a fund-specific ESG report which is updated four times a tected. The ESG indicators of the funds are reported in fund- year. The fund does not have a benchmark index. specific ESG reports, which are updated four times a year. The funds’ benchmark indexes are market-based indexes that do Evli Corporate Bond, Evli European Investment Grade, not consider sustainability risks or sustainability factors. The Evli Nordic 2025 Target Maturity, Evli Nordic Corporate benchmark index used by each fund can be found in the rel- Bond evant fund-specific key investor information document. SFDR classification: article 8, light green Fixed income funds The funds promote sustainability factors as part of invest- ment operations by integrating responsibility factors into Evli Emerging Markets Credit, Evli Euro Liquidity, investment analyses and by engaging with and excluding Evli European High Yield, Evli Short Corporate Bond companies. Before an investment decision, the ESG analysis focuses on matters that are quantifiable through the quality SFDR classification: article 8, light green of a corporate bond. Especially in company analysis, the funds The funds promote sustainability factors as part of invest- focus on the main ESG risks of each company. If a company ment operations by integrating responsibility factors into has significant and unresolved ESG issues, the company be- investment analyses and by engaging with and excluding comes ineligible for investment. The analysis of ESG factors companies. Before an investment decision, the ESG analysis is based on portfolio managers’ holistic view of the company, focuses on matters that are quantifiable through the quality which is based on information provided by the company, the of a corporate bond. Especially in company analysis, the funds portfolio managers’ own analysis and MSCI’s ESG data. The funds favor companies with better ESG scores in their invest- focus on the main ESG risks of each company. If a company ments; i.e. the funds use positive selection. In addition to has significant and unresolved ESG issues, the company be- Evli’s general exclusion practices, the funds exclude alcohol comes ineligible for investment. The analysis of ESG factors and weapons manufacturers, gambling companies and fossil is based on portfolio managers’ holistic view of the company, fuel mining, extracting, drilling and refining companies from which is based on information provided by the company, the their investments. The companies invested in by the funds are portfolio managers’ own analysis and MSCI’s ESG data. The monitored for violations of UN Global Compact standards and funds follow Evli’s general exclusion practices. The companies the Climate Change Principles, and they are engaged with or invested in by the funds are monitored for violations of UN excluded if violations are detected. The ESG indicators of the Global Compact standards and the Climate Change Principles, funds are reported in fund-specific ESG reports, which are and they are engaged with or excluded if violations are de- updated four times a year. The funds’ benchmark indexes are tected. The ESG indicators of the funds are reported in fund- market-based indexes that do not consider sustainability risks specific ESG reports, which are updated four times a year. The or sustainability factors. The benchmark index used by each funds’ benchmark indexes are market-based indexes that do fund can be found in the relevant fund-specific key inves- not consider sustainability risks or sustainability factors. The tor information document. Evli Nordic 2025 Target Maturity, benchmark index used by each fund can be found in the rel- which does not have a benchmark index, is an exception. evant fund-specific key investor information document. 13
Evli Green Corporate Bond nies. The funds are asset allocation funds that largely invest in Evli’s equity and fixed income funds which are primarily SFDR classification: article 9, dark green classified as light green funds; i.e. they promote sustainability The objective of the fund is to make sustainable investments. factors as part of investment operations. To the extent that The fund invests in assets that, based on a sustainability analy- the funds have investments in index funds and exchange- sis, are expected to have a positive impact on the environment traded funds, the aim is to select index funds and exchange- or society or on the achievement of the UN Sustainable Devel- traded funds that promote sustainability factors in addition to opment Goals. These assets include green bonds. In addition other features (i.e. light green products). At least 75% of the to Evli’s general exclusion practices, the fund excludes alcohol active, index and exchange-traded funds in the funds are clas- and weapons manufacturers, gambling companies and fos- sified as light green funds. The funds’ benchmark indexes are sil fuels (mining, extracting and drilling) manufacturers from market-based indexes that do not consider sustainability risks its investments. The companies invested in by the fund are or sustainability factors. The benchmark index used by each monitored for violations of UN Global Compact standards and fund can be found in the relevant fund-specific key investor the Climate Change Principles, and they are engaged with or information document. excluded if violations are detected. The fund’s ESG indicators are reported in a fund-specific ESG report which is updated Evli Euro Government Bond, Evli Factor Premia, Evli Q7 four times a year. In addition, the fund publishes a regular (at SFDR classification: article 6, mainstream least once a year) report on the use of assets and the expected impact of the projects it has funded. The fund’s benchmark The funds do not take sustainability factors into account in index is the Bloomberg Barclays MSCI Euro Corporate Green their investments. It is not possible to calculate ESG scores Bond 5% Capped Index. In order to be accepted in the index, for the instruments these funds use, in the same way as it is the bond must pass an assessment by MSCI, on the basis of for equities and corporate bonds. To the extent that the funds which it can be classified as a green bond. This requires that invest in Evli’s equity and fixed income funds, they comply the bond meets the criteria set by MSCI regarding asset use, with Evli’s Principles for Responsible Investment. project evaluation and selection, management of assets and reporting. With respect to asset use, the requirement is that Evli Wealth Manager the assets collected with the bond are used for projects that SFDR classification: article 6, mainstream promote sustainability goals related to the climate or to the environment (e.g. sustainable water use, pollution prevention The fund does not take sustainability factors into account in and control, green building). This index is different from a its investments. The fund follows Evli’s general exclusion prac- general market index because only green bonds are selected tices. The companies invested in by the fund are monitored for into it. violations of UN Global Compact standards and the Climate Change Principles, and they are engaged with or excluded if Evli Leveraged Loan violations are detected. SFDR classification: article 6, mainstream Evli Wealth Management’s principles for responsible The fund takes account of sustainability factors as part of investment investment operations by integrating responsibility factors into investment analyses and by engaging with and exclud- We at Evli want to achieve the best possible return for our ing companies. Before making an investment, as part of the clients’ investments. We believe that investors and companies due diligence process and the investment decision, the target that take responsibility issues into consideration will benefit company is analyzed from an ESG perspective taking into ac- in the long term. We also want to promote openness and count the company- and industry-specific ESG factors and transparency through responsible investment. We have there- risks. If substantial ESG risks or deficiencies are identified in fore integrated factors that affect the environment, society a company’s operations, the company in question will not be and governance into Evli Wealth Management’s investment invested in. If ESG problems arise after the investment, the operations in accordance with our principles of responsible problems identified will be discussed with the major share- investment. holders or the company management. Therefore, ESG matters are integrated throughout the investment process. The fund The purpose of the Responsible Investment Principles is to follows Evli’s general exclusion practices and Evli’s general define Evli Wealth Management’s approach to responsible and the fund’s own Principles for Responsible Investment. The investment and communicate its methods. The principles of fund does not have a benchmark index. responsible investment and practical procedures are decided on by the Responsible Investment Executive Group, which Other funds consists of the Chief Executive Officer, the Chief Investment Officer, and the heads of the following groups: Legal, Risk Evli Global Multi Manager 30, Evli Global Multi Manager 50 Management and Compliance, Institutional Clients, Private Clients, Equities or Fixed Income, Discretionary Mandates and SFDR classification: article 8, light green Sustainability. The Responsible Investment Executive Group The funds promote sustainability factors as part of investment reports to the Executive Group of Evli Bank. Evli’s Responsible operations by integrating responsibility factors into invest- Investment team operates under the Responsible Investment ment analyses and by engaging with and excluding compa- Executive Group and handles any norm violations and possible 14
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