Conflicts of Interest

Sissener AS guidelines for identification and handling of conflicts of interest

Sissener AS is a management company for mutual funds and manages Sissener Canopus and Sissener Corporate Bond Fund. This means that Sissener AS makes investment decisions and implements these on behalf of the mutual funds. The company must be organized in such a way that the risk of a conflict of interest between the company and its customers, between two customers, between a customer and a mutual fund or between two mutual funds is limited to a minimum.

Sissener AS will always act in the best interests of customers and mutual funds. However, situations where conflicts of interest arise are conceivable. Conflict of interest means a situation that arises due to different interests or priorities.

The objective of Sissener AS's guidelines for handling conflicts of interest is to identify the potential conflicts of interest that may arise in connection with Sissener AS's activities and describe what measures have been established to handle such conflicts of interest. The framework for Sissener AS 'instructions is regulated in the Securities Funds Act § 2-11 (3) and the Mutual Fund Regulations §§ 2-20 to 2-24.

The company has identified conflicts of interest in the following way:

Conflicts of interest between mutual funds

The company has prepared instructions related to the management of mutual funds which are intended to remedy potential conflicts of interest, including routines for registration and logging of orders and transactions and routines for internal trading between the mutual funds.

Conflicts of interest between the Company and the Company's mutual funds

The company shall not normally trade in financial instruments, but may exceptionally make certain strategic investments. In such situations, the CEO must prove that the investment is not in conflict with the Company's obligations in the mutual fund or in any other way is in conflict with the mutual funds' interests.

Conflicts of interest between employees of the Company and the Company's mutual fund

As a general rule, employees in the Company shall not trade financial instruments for their own account (so-called proprietary trading), partly because employees' proprietary trading may conflict with the interests of the mutual funds. If employees exceptionally trade, the Company has an internal instruction for employees 'personal transactions that is intended to prevent employees from trading in financial instruments in conflict with the mutual funds' interests. The internal rules contain requirements for pre-clearance from the CEO when trading in financial instruments, restrictions on which instruments can be traded and the lock-in period for trading.

Employees of the Company will from time to time be offered gifts or other benefits from the Company's customers, suppliers or others who provide services to the Company or the mutual funds. The company has an internal instruction for employees' access to receive gifts to prevent conflicts of interest between the employees and the mutual funds as a result.

Other conflicts of interest

The company has a number of other instructions to prevent conflicts of interest:

Ethical guidelines for the company and employees

Rules for handling inside information

Guidelines for subscription and redemption of units in the mutual funds

Instructions on the role of the Compliance function

If the above measures are not sufficient to secure the customer's interests in a reassuring manner, the Company shall inform the customer of the possible conflict of interest. The company may not conduct business at the customer's expense until the customer has received such information

If relevant conflicts of interest are identified in connection with the Company's activities, the Company's CEO and CCO shall jointly clarify which measures are to be implemented. The CEO shall approve the measures to be carried out, including whether it is sufficient to remedy a possible / current conflict of interest, and shall in that case approve information provided to customers about conflicts of interest. Documentation of implemented measures must be secured and stored.

The guidelines on handling conflicts of interest shall be reviewed at least once per year.