Policy on handling conflicts of interest

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However, instances could arise where the interests of the funds or the client are in conflict, or where a conflict of interest occurs between SKAGEN employees and the funds. The aim of this policy is to identify possible conflicts of interest which could arise in SKAGEN's activities and to describe the measures instigated to prevent or handle these in accordance with relevant laws and regulations. The policy shall contribute to:

The way SKAGEN organises and manages all business activities is done in a way to reduce potential conflicts of interest
Establishment of sufficient internal control measures to identify and manage potential conflicts of interest
Managing conflicts of interest in the best interests of clients

This policy is based on the guideline on handling conflicts of interests in the Storebrand Group and the Securities Fund Regulations §§ 2-20 - 2-23.

Conflicts of interests may arise between SKAGEN, SKAGEN's funds, external funds, clients/unit holders, between different roles/functions in the Storebrand Group, Board members and employees. Consideration must also be given to conflicts of interest that may arise as a result of the integration of sustainability risks in SKAGEN's business activities, including conflicts of interest that may arise from a client's sustainability preferences.

In addition to legal requirements, it is important to ensure all employees have the competence to identify potential conflicts of interest in order for them to be managed according to this policy.

Conflicts of interest

Identification and measures for handling conflicts of interest

A description of specific potential conflicts of interest which could arise in connection with SKAGEN's activities and SKAGEN's procedures and actions for dealing with them are set out below.

Potential conflicts of interest arising from the management of the funds

SKAGEN manages clients' assets and the company's existence is predicated on delivering the best risk-adjusted returns to clients together with the best service and communication. SKAGEN is a long-term manager and has no incentive to prioritise short-term profits over patient long-term operations. However, a potential conflict of interest lies at the heart of the company, as persons connected with the management company or the Storebrand Group may prioritise the company's earnings over the long-term interests of the funds and their unit holders. To avoid such conflicts of interest becoming a reality, it is important to ensure the independence of a number of functions, and SKAGEN has instigated general measures to achieve this:

Procedures for determining the fund price (NAV), in which dedicated employees set the fund prices independently of the portfolio managers. Price-setting is thus subject to checks by the company's Compliance function.
Each fund must have a custodian. A custodian is a financial institution with licence to act as a custodian. The custodian's duties include safekeeping the funds’ assets or maintaining accounts of them in a securities register. The custodian must also perform several checks. These relate partly to whether movements in the funds have been performed in accordance with the law, regulations or rules and whether the unit value has been calculated in accordance with the law, regulations or fund rules.
Procedures for preventing insider trading and market manipulation in the performance of fund management or personal transactions.
Policy and procedure for best execution to ensure SKAGEN will take all reasonable steps to obtain the best possible result for the unit holders.
Ethical guidelines for preventing SKAGEN employees from obtaining benefits at the expense of SKAGEN's business.

Potential conflicts of interest between SKAGEN AS and SKAGEN's funds

SKAGEN AS will normally not deal in financial instruments but may exceptionally make individual strategic investments in companies. Before SKAGEN AS makes such investments, the Managing Director must certify that the investments do not conflict with SKAGEN's obligations under the Norwegian Act on Securities Funds or with the interests of SKAGEN’s funds. In the case of significant business decisions, safeguarding the client perspective will be documented.

Potential conflicts of interest between the owner of SKAGEN AS and funds managed by SKAGEN AS

The interests of the owner of SKAGEN AS could potentially differ from those of the funds. The owner could influence the operation of SKAGEN through their representation on the Board. This conflict of interest is handled by ensuring that unit holders represent at least one third of the Board members. The Board members elected by the unit holders are there to uphold the unit holders' interests.

Potential conflicts of interest between SKAGEN employees and SKAGEN's funds

SKAGEN employees are able to trade financial instruments on their own account. This may conflict with the interests of the funds, for instance if the fund and the employee attempt to buy the same security or the employee attempts to exploit knowledge that the fund is about to sell a security by buying it at a reduced price. To avoid employees trading in securities in a way judged to conflict with the interests of the funds, or exploiting information received for their own benefit, or exploiting their position to obtain special advantages, SKAGEN has drawn up internal rules for personal account trading by employees. The rules include pre-trade clearance of buying and selling financial instruments, a ban on trading in funds, a tied period and restriction on permitted intermediaries.

From time to time, SKAGEN employees may be offered gifts or other benefits by SKAGEN unit holders, suppliers, or other service providers to SKAGEN or SKAGEN’s funds. To avoid a conflict arising between the interests of the employee and those of SKAGEN’s funds, the company has established internal rules governing the acceptance of gifts and/or other benefits by employees.

Potential conflicts of interest between SKAGEN's funds

To avoid conflicts of interest arising between the various funds managed by SKAGEN, the company has established comprehensive procedures for the management of securities.

For example, the procedures include:

Registration and logging of all orders placed, and transactions executed.
If several funds intend to buy or sell the same security, the trades must be placed with the broker at the same time. If financial instruments are purchased for several portfolios and the order is partially filled, the shortfall must be allocated pro rata between the funds.
SKAGEN may only in exceptional cases trade between funds.

Potential conflicts when distributing SKAGEN's funds, funds managed by the Storebrand Group or other external funds

To avoid conflicts of interest arising when distributing funds managed by SKAGEN, funds managed by the Storebrand group or other external funds, the company has established detailed procedures for investment advice and execution on digital solutions:

For example, the procedures include:

Procedures for how and when SKAGEN funds, Storebrand funds or other external funds are to be offered to clients
Information of potential conflicts of interests, for example being both producer and distributor
Information on how SKAGEN’s incentive structure is not solely based on sales volumes or profitability

Potential conflicts of interest between different roles/functions in the Storebrand Group

The legal company structure and functional organisational structure within the Storebrand Group may represent potential conflicts of interest. If such a situation is identified, it is documented with mitigating actions. All employees have specific role descriptions with reporting lines. In addition, intragroup agreements govern the services provided by roles/functions to different companies within the Storebrand Group.

Handling of conflicts of interest

SKAGEN must ensure that the interests of the clients and the integrity of the market are safeguarded in the best possible way.

In areas where conflicts of interest have been identified between clients, between clients and SKAGEN, between different companies and/or business areas in the Group or between different roles/functions, measures must be taken to handle the most significant conflicts of interest in order to secure the clients' interests in the best possible way.

The compliance function in SKAGEN must ensure that management confirms that conflicts of interest are identified, assessed, documented and handled adequately. Objective and documented criteria must be used insofar as possible when handling conflicts of interest.

The company must regularly assess whether any conflicts of interest that have been identified have been adequately handled. The assessment from management will be submitted to the Board at least annually.

Anyone associated with SKAGEN is covered by these guidelines.

Last updated May 2023.