Legal information

Proxy P Management AB (“Proxy” or “AIFM”) is an authorized AIF-Manager and is legally obligated to disclose certain important information and documents. Below is a list of such information that are relevant to both fund investors as well as other stakeholders. Some of the documents are only available in Swedish. Proxy currently manages the AIF: ProxyP SICAV-SIF – Proxy Renewable L/S Energy (the ”Fund”). The Fund is an open-ended investment company, qualifying as a specialised investment fund “société d’investissement à capital variable”, with multiple Sub-Funds governed by Part II of the SIF Law (for more information: ProxyP_SICAV_prospectus).

Returns

There are no guarantees that an investment in the Fund will be profitable. The funds invested in the Fund can both increase and decrease in value and it is not certain that the person who invests in the Fund will get the entire invested capital in return. An investment in the Fund should be considered long-term. Past performance is no guarantee of future returns.

Publicly disclosed documents:

Remuneration Policy 

The company's remuneration rules are designed in accordance with the Swedish Financial Supervisory Authority's regulations and general guidelines (FFFS 2013:10). The remuneration rules are designed to encourage good performance and attract new employees, while at the same time being consistent with the company's business strategy and long-term interests. The remuneration rules shall counteract excessive risk-taking, conflicts of interest and promote sound and effective risk management. At present, all of the company's employees are deemed to be included in the category of specially regulated personnel.

Article 5 of SFDR requires financial market participants to include in their remuneration policies information on how those policies are consistent with the integration of sustainability risks and to publish this information on their websites. The Company has integrated sustainability risks into its assessments and believes that it is consistent with the integration of sustainability risks in the business. In short, both fixed and variable salary components are determined taking into account common, long-term goals within the Company, including the Company's performance and risks. Proxy’s results are based on risk-adjusted profit measures in a multi-year perspective and the employee's individual performance. When considering the employee's performance, both financial and non-financial criteria shall be taken into account and both qualitative and quantitative measures shall be considered. The qualitative targets include Proxy’s overall sustainability targets. When determining variable components, their impact on current and future risks in Proxy shall be taken into account, including sustainability risks.

Further information or a copy of Proxy’s remuneration policy is available free of charge for investors upon request. If so, please send an email to info@proxypm.se.

Incitement 

Proxy manages the Fund. Proxy receives remuneration from the Fund, partly in the form of a fixed management fee and partly in the form of a performance-based fee in accordance with the fund rules. The Company may enter into agreements with distributors who mediate the Fund and with institutional investors. In the event of such agreements, Proxy may pay compensation in the form of a percentage of the management fee Proxy receives on the capital brokered by the distributors and the institutional investor invested. The Company does not receive any remuneration from third parties in connection with transactions on behalf of the Fund.

Further information can be found in the prospectus and is provided free of charge upon request to investors. If so, please send an email to info@proxypm.se.

Sustainability policy and disclosures

The Fund has sustainable investment as its objective and thus, is categorised as a “Sustainable Objective” approach sub-fund, falling into the scope of article 9 of the SFDR. We refer to the following page for more detailed information: Sustainability - Proxy P Management AB.

Information on sustainability criteria for the Fund can also be found in the fund prospectus; for more information: ProxyP_SICAV_prospectus. Information on sustainability risk can be found below.

Sustainability risk

Sustainability risk refers to “an environmental, social or governance event or condition that, if it occurs, could cause an actual or a potential material negative impact on the value of the investment”, in accordance with article 2 (22) of the SFDR. Unmanaged or unmitigated sustainability risks can impact the returns of financial products. For instance, should an environmental,social or governance event or condition occur, it could cause an actual or a potential material negative impact on the value of an investment.

Proxy considers sustainability risk as risks that are likely to materially negatively impact the financial condition or performance of a company or an issuer, and therefore the value of that investment. The scope of the analyzed sustainability risks is environmental, social and employee matters, respect for human rights, anti‐corruption and anti‐bribery matters. Proxy integrates the sustainability risks in the Funds’ investment process: (i) in the due diligence when making an investment decision and (ii) assessing the sustainability risks on a continuous basis through the Fund’s risk monitoring process, in conjunction with all investments, by identifying what sustainability risks are relevant for each investment and how they might have a negative impact on the financial return of such investments. Sustainability risks are integrated into the decision making and risk monitoring processes to the extent that they represent a potential or actual material risk and/or opportunities to maximize the long term returns. The result of Proxy’s assessment of the likely impacts of sustainability risks on the returns of the Sub-Fund is further described in the prospectus ProxyP_SICAV_prospectus and here: .

https://www.proxypm.se/sustainability-disclosure.

Policy for Best Execution 

Proxy executes transactions on behalf of the Fund. In order to achieve the best possible result, Proxy takes into account price and associated costs, speed and probability of execution and settlement, the size and nature of the transaction, as well as other conditions that are essential for the execution.

Proxy currently uses the following counterparties:

-SEB

-Morgan Stanley

-JP Morgan

Further information or a copy of Proxy’s best execution policy and counterparties is available free of charge for investors upon request. If so, please send an email to info@proxypm.se.

Policy for shareholder engagement 

An AIFM shall develop adequate and effective strategies for determining when and how any voting rights held in the AIF portfolios it manages are to be exercised, to the exclusive benefit of the AIF concerned and its investors. To comply with this, Proxy has adopted and implemented internal guidelines for exercising voting rights. According to our ownership policy, we shall always vote with the common interest of the investors of the Fund. Voting can only be exercised in accordance with the Fund’s investment policy and/or strategy at hand. Generally, Proxy does not exercise active ownership and will not participate in shareholders' meetings due to the fact that Proxy's management model is not focused on pursuing ownership interests and that Proxy mainly invests in larger, liquid companies. In the event that the Fund in any case would nevertheless invest funds in a share and thereby belong to the major shareholders and Proxy for other reasons deems it to be material for the Fund's return, Proxy will exercise its ownership/voting rights. However, Proxy continuously monitors the development of the funds’ portfolio companies. When voting rights are exercised, Proxy shall always act in accordance with relevant laws and regulations and otherwise according to good practice in the stock market.

Under Article 4 of SFDR, Proxy also strives to be a driving force in sustainability, and believes that shareholder engagement is a lever to achieving this aim. The UN PRI defines stewardship as ‘the use of influence by institutional investors to maximise overall long-term value including the value of common economic, social and environmental assets, on which returns and clients' and beneficiaries' interests depend’. In keeping with this definition, Proxy enactse its stewardship by engaging with broader stakeholders as part of the investment process in order to discuss certain factors and their potential significance. These stakeholders include:

▪ Current or potential investees/issuers

▪ Policy makers and standard setters

The identification of such factors enables Proxy to evaluate the impact to the financial condition or operating performance of an investment, as well as to potentially influence corporate practice. In assessing the sustainability risk associated with underlying investments, Proxy P is assessing the risk that the value of such underlying investments could be materially negatively impacted by an ESG event or condition. The assessment may result in adjustments to financial forecasting and modelling.

As the Fund is not an activist fund, it does not engage in other elements of stewardship such as filing shareholder resolutions and proposals, or fulfilling direct roles on investee boards and board committees. We engage in voting selectively rather than systematically and consistently discuss ways of improving our voting process.

Measures against money laundering and terrorist financing

The board of directors has appointed Martin Rudling as responsible for the anti-money laundering work and he will act as the officer for controlling and reporting obligations for the AIFM(CFA).

For further information on Proxy’s work against money laundering and terrorist financing, please send an email to info@proxypm.se with you request.

The AMLO of the Fund is Martin Rudling martin.rudling@proxypm.se

Market Soundings (MAR)

Proxy does not participate in market soundings. If AIFM wishes to participate in future market soundings, this will be disclosed.

Conflicts of interest

In order to comply with the regulation and to maintain the public’s confidence in the financial market and for the group, Proxy has established, implemented, and applied an internal policy for preventing, identifying, managing, and monitoring conflicts of interest. The internal policy is evaluated and re-approved at least once per year by the board of directors.

Depositary

Proxy uses the following provider as depositary for the Fund:

Skandinaviska Enskilda Banken AB, Luxembourg Branch 4, rue Peternelchen L-2370 Howald

Complaints

If you are not satisfied with our services, it is important that you get in contact with us as soon as possible. We follow FSA’s General guidelines regarding complaints management concerning financial services for consumers (FFFS 2002:23).

If you have a complaint, you should first and foremost contact Proxy’s Complaint Manager in writing. When making a complaint in writing, attach copies of relevant documents. It is preferred if you indicate which employees you have had contact with in the case, as well as when these contacts happened.

If the complaint is to be regarded as a simple mistake or misunderstanding, this will be rectified as soon as possible. If we are unable to respond to your case within 14 days of receiving the complaint, you will receive written information on this as well as information on the further processing of your case.

Complaints decisions are normally made by our compliance officer, in consultation with relevant managers. If you are not satisfied after the first decision, a final answer will be provided by the compliance officer together with a board member. On this occasion, you are also informed that this is our final decision. If this is also not to your satisfaction, you can contact an external body: General Complaints Board or General Court. If you would like to contact these bodies, we will help you.

If you want guidance on your complaint, you can get help from the municipal consumer guide (see your municipality’s website) and at the Consumer Banking and Finance Bureau (www.konsumentbankbyran.se).

Att: Complaints manager: info@proxypm.se

Returns

Historical returns are no guarantee of future returns. The money that is invested in the Fund can both decrease and increase in value and it is not certain that the investor will get back all the deposited capital. The Fund can both shrink and increase significantly in value, due to its composition and the management methods used. We recommend that you take careful note of the fund’s prospectus and fund regulations before investing. We only accept professional investors.