Legal Information

Privacy Policy

Simplicity is committed to protecting your individual rights and keeping your personal data safe. In this Privacy Policy we describe the collection, usage, storage and sharing practices of personal data.

1. Data controller

Simplicity AB, corporate identity number 556611-4723, is the data controller of all your personal data within the Simplicity group.

You can contact us in the following ways:
– via e-mail contact@simplicity.se
– via mail to Simplicity AB, Södra Hamnvägen 12, 432 44 Varberg, Sweden.

2. What personal data we collect

Personal data is in most cases collected directly from you or generated as part of the use of our services and products. Additional information which might be required to keep information up to date or to verify information we collect may also be collected.

The personal data we collect can be grouped into the following categories:
– Contact information: Addresses, phone numbers, e-mail addresses and in some cases additional information such as home country if foreign address.
– Identification information: Name and national identification number.
– Financial information: Type of agreement and transactional data.
– Information related to legal requirements: country of taxation or foreign tax payer reference, customer due diligence with respect to anti-money laundering- and anti-terrorism requirements.

Personal data we may collect from you
We collect information you provide directly to us. New customers are required to state personal data such as personal identification number, name and contact information. We also collect information which you give us through interaction when you, for example, wish to update personal data or execute transactions.

Personal data we collect from third parties
To verify that our information is correct and up to date we collect information from third parties.

Example of sources we use to collect such data is: registers held by governmental agencies such as population registers held by tax authorities, company registration offices, enforcement authorities, EU sanction lists, and registers of individuals in politically exposed positions.

3. Why we use your personal data and the lawful basis for doing so

We collect and use personal data to comply with legal and contractual obligations as well as to provide you with offers and services.

Performance of a contract
The main purpose of our personal data processing is to collect, verify and process personal data prior to entering into a contract with you as well as documenting, administering and completing tasks for the performance of the contract.

Legal obligation
Processing personal data also takes place for us to fulfil our obligations under law, other regulations or authority decisions. Examples of processing due to legal obligations:
– Know Your Customer requirements
– Preventing, detecting and investigating money laundering, terrorist financing and fraud
– Bookkeeping regulations
– Reporting to authorities

Legitimate interest

Personal data is also processed in the context of marketing, product- and customer analyses. The purpose of this processing is marketing and optimization of our customer offerings.

Consent

There are situations when we will ask for your consent to process your personal data. These types of consensual agreements may for example be regarding certain types of personal data. You can at any time withdraw such consents.

4. To whom we forward your personal data and geographical location for processing

Your personal data may be forwarded to and processed by others. We forward your personal data to companies that we cooperate with and to companies that process personal data on our behalf, so called personal data agents. We have agreements with our personal data agents that ensure that your personal data is treated in accordance with this privacy policy and our instructions.

We also disclose personal data to authorities to the extent we are under statutory obligation to do so. Such authorities include tax authorities, police authorities, enforcement authorities and supervisory authorities in relevant countries.

Under normal circumstances your personal data is only processed within the EEA. In some cases, we may transfer personal data to organizations in countries outside the EEA. Such transfers can be made if any of the following conditions apply:
– The EU Commission has decided that there is as an adequate level of protection in the country in question, or
– Other appropriate safeguards have been taken, or
– That there are exceptions in special situations, such as to fulfill a contract with you or your consent to the specific transfer.

5. How we protect your personal data

Keeping your personal data safe and secure is very important to us. We have therefore taken appropriate measures to safeguard the data we hold from loss, misuse, unauthorized access, disclosure, alteration and destruction.

6. Your privacy rights

You have the right to, free of charge, request in writing that we disclose which personal data we hold on you and have a copy of the data sent to you. You can request correction of incorrect or incomplete data at any time. You may also have the right to request erasure of data, given there are no legal obligations for us to store the data. Due to the financial sector legislation we are in many cases obliged to retain personal data on you during your customer relationship, and even some time after that to comply with statutory obligations or where processing is carried out to manage legal claims.

In such cases when erasure is not legally possible you have the right to limit the data usage to storage alone.

You can always object to the processing of personal data about you for direct marketing. If you do not wish that your personal data is used for such activities we kindly ask you to notify us. We will in such cases cease to process the personal data for such activities and erase the data, given there are no legal obligations or other purposes for the data processing according to this privacy policy.

If you have consented to processing of personal data you can at any time, fully or partially, revoke your consent by contacting us. If you revoke your consent we kindly ask you to note that this does not affect the legality of the processing prior to the consent being revoked.

7. Cookies

We use cookies to analyze data regarding the use of our websites in order to offer visitors of our websites a more relevant and user-friendly experience. You can choose to disable cookies in your browser. If you choose to disable cookies in your browser you will still be able to use the majority of our website, with some functionalities disabled or altered.

8. How long we process your personal data

We will keep your data for as long as they are needed for the purposes for which your data was collected and processed or required by laws and regulations.

Examples of situations that require us to store personal data:
– Preventing, detecting and investigating money laundering, terrorist financing and fraud: minimum five years after termination of the business connection or the performance of the individual transaction.
– Bookkeeping regulations: up to ten years.
– Details on performance of an agreement: up to ten years after end of customer relationship to defend against possible claims.

9. Questions or concerns

If you are displeased with our personal data processing we kindly ask you to contact us. Please see section 1 for contact information. You can also lodge a complaint or contact the data protection authority in any of the countries where we provide services or products to you.

Risk Information

Past performance is no guarantee of future returns. The money invested in a fund can both increase and decrease in value and there is no guarantee that you will get back the full amount invested. Value growth depends, among other things, on the future development of the stock markets, interest rates and currencies. Investments in funds that invest in emerging markets may entail additional risks. Information brochures, fund rules and further information is available at Simplicity’s website, or can be received free of charge upon request. Please contact Simplicity on phone +46 (0)340 – 21 95 00 or via e-mail contact@simplicity.se

About the website

Regarding the material published at Simplicity AB´s website, the following applies:

No information published on the website should be perceived as a recommendation to sell or buy fund units. Simplicity does not provide advice investments. Making investments decisions always involves risk taking, and each such decision is taken independently by the customer on his own responsibility. The information on the website is not intended to be used instead of the professional advice that the individual customer may need.

Although Simplicity makes utmost efforts to obtain information from sources that Simplicity perceive as reliable, Simplicity cannot guarantee that the information available on the website is accurate, reliable nor complete.

All information, services and offers on the website is intended solely for individuals and companies with legal residence in Sweden, Norway and Luxembourg. No material on this website is thus directed towards individuals or companies with legal residency in USA, Canada, Japan, Australia or any other country where the publishing or accessibility of the material found on the website is prohibited or the permissibility is limited in any way.

Swedish law applies to information provided on this website and on agreements reached online at simplicity.se, and any disputes relating thereto shall ultimately be settled in Swedish court.

Regarding investment advice
Simplicity AB does not provide such financial advisory services as described in the Swedish Financial Advice to Consumers Act (2003:862), nor does Simplicity AB provide such investment advice as described in the Swedish Investment Funds Act (2004:46). Simplicitys primary business is active fund management.

The information on this website and in Simplicity’s information material is not intended to be advisable. The information is general information about investments via Simplicity AB. Financial advising is not within the scope of Simplicity’s business operations.

In order to determine what is appropriate for you, an individual counseling is required which includes an analysis of your financial circumstances and your preferences. In these cases reference is made to expertise in financial advisory services.

Complaints

The company board has established internal guidelines for the handling of complaints. The guidelines will be sent free of charge to customers upon request.

A complaint is defined as a customer who is dissatisfied with a financial service or product and the company is unable to meet the customers’ requests. In this context, general discontent is not considered a complaint. Complaints should be submitted in writing to the company’s Complaints Manager. Complaints are submitted free of charge to Simplicity.

The processing time for complaints is normally 14 days. Should the complaint require further investigation or processing Simplicity will notify the customer within 14 days. If you as a customer are not satisfied with Simplicitys handling of your complaint then you should contact, in the first instance, the Consumers’ Bank & Finance Bureau (Konsumenternas Bank- och finansbyrå) for guidance. You can also contact the municipality (Kommunens) consumer adviser for guidance, or contact the Consumer Complaints (ARN) or civil courts to ask to have your case reviewed.

Complaints manager

Ulf Ingemarson is responsible for complaints and claims at Simplicity AB.

Simplicity AB
Ulf Ingemarson
Södra Hamnvägen 12
432 44 Varberg

Ownership Policy

For share owners and the funds alike, Simplicity AB exercises ownership rights in the companies in which the fund company have chosen to invest. The role of owner shall be exercised in the share owners common interest. This means that other interests from the fund company or other affiliated companies always must be set aside.

Simplicitys role of owner has the purpose to promote the long-term risk adjusted returns for each individual funds assets.

The board of Simplicity has established guidelines for how the fund company shall exercise ownership rights in the companies where the funds invest. The funds investment strategies does, normally, not motivate the participation from Simplicity on Annual General Meetings, election commitees or company boards since the funds holdings in individual companies normally constitutes a smaller quota of the shares outstanding, which is in line with the funds investment strategies. For Simplicity to be represented in a company board in which a fund invests could lead to situtations where the board representative becomes an insider, which would limit Simplicitys possibilities to trade financial instruments issued by the company.

Simplicity seeks to invest in well-governed companies, and according to us a sustainable company is a well-governed company. We have adopted a Responsible Investment Policy that govern how we will act in these matters. If a company in any of the funds portfolios would violate international norms regarding environment, human rights or corruption, Simplicity will engage in dialogue with the company to steer the company in a more sustainable direction. In cases where the dialogue does not lead to a positive change or cases where it is deemed unlikely that dialogue would affect the company, Simplicity could divest the holding. More information regarding our work as responsible asset managers can be found in Simplicitys policies for responsible investments.

Should a situation arise where it is deemed favourable for the funds share owners that Simplicity takes a more proactive stance regarding participation and voting at Annual Genereal Meetings, the CEO of Simplicity shall address and seek approval from the board of Simplicity before the company represents a fund at such events. The board shall take into consideration possible conflict of interests before reaching a decision in such matters, which shall be in accordance with Simplicitys internal rules regarding the handling of conflict of interests.

The fund companys contact person regarding ownership issues is CEO Ulf Ingemarson.

Remuneration Policy

The Board of Simplicity AB has established a remuneration policy that covers all employees of the fund company. The remuneration policy is designed according to the Swedish Financial Supervisory Authority’s regulations.

The remuneration system should promote sound business, effective risk management and counteract excessive risk. The remuneration system shall encourage long-term stability in Simplicitys operations.

The employees at Simplicity AB will be paid a fixed salary. In addition, variable compensation may be payable. The company shall base a performance-based remuneration on employee performance as well as the overall profit and loss account of the affected unit and company. All employees entitled to variable remuneration have a fixed remuneration at a level that makes it possible to set the variable part to zero. Thus, the variable remuneration can be zero for a single individual at low profitability or deficiencies in goal achievement.

For an employee who exercise or could exercise a non-immaterial influence at the overall risk level for the company, a so called specially regulated individual, at least 40% of the variable renumeration payment shall be postponed for at least three years. For specially regulated individuals whose variable remuneration is considerably high, at least 60% of the payment shall be postoned for at least three years. The company may disburse or transfer the postponed remuneration once a year, evenly distributed over the time the remuneration has been postponed.

In such cases where the company board intend to grant and pay variable remunerations the company shall always take into account how these variable remunerations payments could affect the companys long-term performance. When the company agrees on the basis for remunerations, the company shall take into account that the overall results could be affected by both current and future risks. In its performance measurement the company shall take into account the acutal costs associated with holding capital and liquidity that follows concerning the operations that the performance measurement pertains to.

More information regarding remunerations is available in the funds annual reports and Simplicitys annual report. The fund companys remuneration policy can be obtained free of charge upon request by the funds share owners.

Best Execution

According to the Swedish Financial Supervisory Authority fund companies shall take all reasonable steps to obtain the best possible execution for the placement of orders with someone else on behalf of the funds. This is with regards to the price, cost, swiftness, probability of execution and liquidation, the seize of the transaction, the nature of the transaction and other essential conditions. To assess the relative significance of these factors, the fund company shall take into account the goal, investment focus and risk profile for the fund, the nature of the transaction, distinctive properties of the financial instrument that is included in the portfolio transaction and disctinctive properties of the market in which the transaction is made.

Simplicity AB have established internal rules and guidelines for how best possible execution shall be achieved and how counterparties should be evaluated.

The fund company has decided that the factors that carry the most weight in order to always achieve best possible execution for the funds are the price of the instrument, the cost of execution, probability of execution and liquidation as well as the speed of the transaction.

Share owners can obtain the fund companys internal rules regarding best possible execution free of charge.

Conflict of Interests

According to the Swedish Financial Supervisory authorities regulations regarding securities funds, FFFS 2013:9, fund companies shall identify and handle such circumstances which pose or may pose a risk of conflict of interests that
entails a risk for share owners or other customers interests in regards to the fund activities conducted within the company.

Simplicity have identified a number of potential conflict of interests that could occur in our business operations. On the occasion of this, Simplicity has established internal rules and guidelines to counteract and avoid conflict of interests. Should conflict of interests occur, the company has set out routines to handle such conflicts in the best way possible.

Please contact our CEO Ulf Ingemarson for questions regarding conflict of interests.

Control Functions

Simplicity has the following control functions:
– Risk Manager (Johan Rönliden)
– Compliance (Björn Wendleby, Harvest Advokatbyrå AB)
– Internal audit (Leif Lüsch, Lüsch & Co Revision AB)

External audit
Peter Nilsson at PwC is repsonsible for Simplicitys external audit.

Depositary
Skandinaviska Enskilda Banken AB (publ), company registration number 502032-9081, acts as depositary for the following mutual funds:
– Simplicity Sverige
– Simplicity Norden
– Simplicity Småbolag Global
– Simplicity Kina
– Simplicity Likviditet
– Simplicity Global Corporate Bond

Swedbank AB (publ), company registration number 502017-7753, acts as depositary for the following mutual funds:
– Simplicity Småbolag Sverige
– Simplicity Företagsobligationer

For further information regarding the depositaries, please see each funds information brochure respectively.

Market Soundings

In accordance with MAR, the rules regulating market abuse, Simplicity have designated certain contact persons for the purpose of market soundings. Should the designated contact person not be available, another appropriate fund manager with regards to funds under management may be contacted.

Simplicity are generally positive to receive market soundings. Should Simplicity not wish to receive market soundings in relation to either all potential or particular types of potential transactions, this will be communicated in due course.

 

Equities
Ulf Ingemarson
+46(0)340 – 21 95 10
ulf@simplicity.se

Fixed Income
Henrik Tingstorp
+46(0)340 – 21 95 15
henrik@simplicity.se

 

 

Addendum for Luxembourg Investors

This is supplementary information about your investment in one or more of the funds in which you have expressed an interest. This information must be read in conjunction with the relevant fund’s Prospectus, Key Investor Information Document, application form and our terms and conditions. For full details of the funds on offer, please refer to the Prospectus, which is available on request free of charge by contacting contact@simplicity.se. The prospectus (as amended from time to time) sets out the full terms and conditions of your proposed investment. The investment will be governed by the law of Sweden.

For the full addendum, please follow the link below.

Addendum for Luxembourg Investors

Translation

This is a translation of the Swedish website regarding legal information. In case of any discrepancy between the Swedish-language version and any translation thereof, the Swedish-language version shall prevail and the legal information shall be construed in accordance with the Swedish-language version. Before investing in Simplicitys funds, carefully read our fund terms, fund rules and other relevant information. For questions or comments regarding this webiste or other translated material, please contact our backoffice function via backoffice@simplicity.se.

Changes of This Information

Simplicity AB can, at any time, change the information on this webpage. This webpage shall therefore regularly be controlled when you visit Simplicitys websites.

Copyright Simplicity AB 2017