Policies

Compliance

Bellevue Asset Management AG is a FINMA-regulated manager of collective assets pursuant to Art. 24 FinIA. Bellevue strives to comply with all regulatory requirements at all times and to implement them accordingly. Bellevue Asset Management AG lives an exemplary control and compliance culture, with individual employees setting a good example and complying with all applicable laws, regulations and directives at all times. New or existing practices are critically scrutinized, and in the event of non-compliance with standards, action is taken and the matter is reported to the responsible supervisor or the Compliance Office. In addition, the Three Lines of Defence model is consistently adhered to.

Compliance Policy

Code of Conduct

Bellevue Asset Management AG is a FINMA-regulated manager of collective assets pursuant to Art. 24 FinIA. Bellevue strives to comply with all regulatory requirements at all times and to implement them accordingly. The Portfolio Manager of Bellevue Asset Management AG adhere to the principles of the industry association Asset Management Association Switzerland (“AMAS”).

Code of Conduct

Best Execution & Dealing with conflict of interests

Best Execution

Bellevue Asset Management AG, as manager of collective assets, ensures portfolio management and risk management for the entrusted assets. As part of its obligation to safeguard the interests of investors, Bellevue Asset Management AG has taken precautions to ensure the best possible result for investors when executing buy and sell orders. Bellevue Asset Management AG processes all buy and sell orders for financial instruments through brokers. An annual review ensures that approved brokers provide a high quality of service and efficient arrangements to consistently achieve the best possible execution of orders.

Best Execution Policy

CONFLICT OF INTEREST

Bellevue Asset Management AG takes the necessary precautions to identify and avoid conflicts of interest in its business activities and to protect investors from disadvantages. The aim is to protect its reputation as a manager of collective assets with integrity and fairness, to comply with regulatory requirements and to maintain the trust of clients and business partners.

Bellevue Asset Management AG's actions are geared towards aligning its own interests, those of its employees and shareholders with the interests of its clients. To this end, the employees are committed to the highest ethical standards.

In order to prevent Bellevue Asset Management AG's services from being influenced by extraneous interests, the operational and organisational structure is multi-level and takes into account an appropriate separation of functions. An effective internal control system aims in particular to identify potential conflicts of interest and to avoid them by taking appropriate measures. If a conflict of interest cannot be avoided, such a conflict is disclosed to the clients.

In addition, Bellevue Asset Management AG complies at all times with the Swiss Banking Guidelines " Directives on the Independence of Financial Research" of January 2008 (updated January 2018).

Conflict of Interest policy

Voting policy

As a responsible and long-term investor, Bellevue Asset Management AG supports all measures and initiatives that increase the long-term value of the company in the interests of shareholders and investors. Proposals for resolutions by the management at the Annual General Meetings are assessed with regard to the long-term interests of the shareholders as well as to environmental and social aspects. Proposals that Bellevue Asset Management AG considers to be contrary to these interests may be rejected in the interests of investors.

Proxy Voting Policy

Automatic Exchange of Information (AIA)

The Automatic Exchange of Information (AEOI) is an international standard of the OECD, which aims to increase tax transparency. With AEOI, the tax authorities of participating countries exchange data on bank accounts and securities accounts of taxable customers. Switzerland also participates in the AEOI. Like all financial institutions in the participating countries, Bellevue Group AG is obliged to consistently implement the AEOI requirements.

List of Switzerland’s partner countries

Information on the exchange of tax-related information

Official Homepage of the Federal department of Finance (SIF)

EU Regulation 2019/2088 on sustainabily-related disclosurs

Bellevue Asset Management AG and its subsidiaries take sustainability risks into consideration and integrate ESG factors into their investment processes. The information required under Regulation (EU) 2019/2088 of the European Parliament and of the Council of November 27, 2019 on sustainability-related disclosures in the financial services sector can be found here.

ESG policy

Whistleblowing

Bellevue strives to comply with all regulatory requirements at all times and to implement them accordingly. To support this purpose, Bellevue expects its employees to speak up when they know of or suspect conduct or incidents that violate laws, regulations or internal directives.

«Whistleblowing» policy

Human Rights

As a responsible corporate citizen, Bellevue respects internationally recognized human rights and aims to not infringe on human rights, be complicit or contribute to human rights abuses. Bellevue is responsible towards its employees, its investment, clients and society at large.

«Human Rights» policy