Proxy Voting Policy Statement (Jul 2017)Complaints handling
Any complaints about the operation of the SICAV or any of its sub-funds or services received as an investor should be submitted to the Management Company - Eastspring Investments (Luxembourg) SA - to the attention of the Complaints Officer.
Tel: +352 22 99 99 5764
Email: compliance.lu@eastspring.com
A complaint includes all grievances and criticism of the Management Company, its products and/or its agents, employees and representatives, irrespective of to whom the complaint is addressed and whether it is expressed in writing or orally, while it may also include all material concerns channelled through distributors or other service providers. For clarification, feedback of an inquiry nature would not be considered a complaint.
The process for handling a complaint is confidential. Once received, the complaint will be subject to a formal acknowledgement of receipt, which will be sent to you within 10 business days at your address (which should have been provided), unless the matter was resolved in the meantime. Management Company shall come back to you with a final response in relation with your complaint, including the course of action that has been undertaken in order to address the issue.
The Management Company has implemented and is subject to the requirements of the Luxembourg Commission de Surveillance du Secteur Financier (“the CSSF”) Regulation 16-07 relating to the out-of-court resolution of complaints.
This means in particular that if as complainant,
you are not satisfied with the resolution of the
issue as proposed by the Management Company,
you then have the possibility to escalate the
matter to CSSF, within one year as from the date
of your initial complaint, in view of the out-of-court
resolution of such complaint by CSSF, i.e. your
case shall be investigated by CSSF in view of a fair
and amiable resolution. Click the link for more information.
Whistleblowing policy
Eastspring Investments (Luxembourg) S.A. is committed to provide an internal reporting channel and procedure to give the opportunity to report misconduct and breaches of international or national law in a simplified way. Any report or request for advice addressed to the “Investigating Officer/RC” is free of charge.
Investigating/Whistleblowing Officer
Eastspring Investments (Luxembourg) S.A.
26, Boulevard Royal
L-2449 Luxembourg
Tel: +352 22 99 99 5764
Email: Whistleblowing.lu@eastspring.com
Eastspring Investments (Luxembourg) S.A. (the “Company”) is committed to provide an internal reporting channel and procedure to give the opportunity to report misconduct and breaches (“the Report”) of international or national law (the “Misconduct”) in a simplified way. This report can be done by any legal person or natural person that is aware of any Misconduct (the “Whistleblower”), for instance: employees, including those whose employment contract has not started or has ended, volunteers and trainees, subcontractors, suppliers, self-employed persons, shareholders and members of the administrative, management or supervisory body. This includes all affected individuals and other parties for the Eastspring SIVAC and SIF funds, as well.
The Group and the Company is also obliged to have in place enhanced protection measures for “Whistleblowers”, in the East spring Group called “Reporter”. This includes to keep the identity confidentially and protect the “Whistleblower” from any retaliation.
Whistleblowers are requested to consider to first use this internal channel described below before using any external or public channels. In case it is not possible for Whistleblowers to use OFM’s internal channel, they can also contact the CSSF and send a written statement to the CSSF (Whistleblowing@cssf.lu) as described in the CSSF’s Whistleblowing Questions and Answers (as applicable): https://www.cssf.lu/de/document/whistleblowing-questions-answers/
The Whistleblower can file the Report in writing by addressing it to Whistleblowing.lu@eastspring.com or verbal by using the phone number +352 2299995764 or in a physical meeting. Please describe the facts as precisely and detailed as possible. The written message will only be received by the employee in charge of whistleblowing within the Company (the “Investigating Officer”) which is the local MLRO-RC and will be handled confidentially.
In case of a written Report, the Investigating Officer will confirm the receipt of your report within 7 days and will also inform and support the “Whistleblower/Reporter” during the process. The final feedback to the “Whistleblower/Reporter” will in principle be provided within three months from the date of the initial notification. In case this is not possible and the appropriate follow-up is still being determined, the “Whistleblower/Reporter” will be informed about this and about any further feedback to expect.
Your personal date is optional for the report but may help to clarify the case of Misconduct. If the processing of your personal data should be necessary to clarify the case, you will be asked to confirm the disclosure beforehand.
Any Report or request for advice addressed to the “Investigating Officer/RC” is free of charge.
