Possible conflicts of interest

Blackfort AG (hereinafter referred to as Blackfort) is a company specializing in the provision of highly professional financial services. The constant respect for and the interests of the clients, as well as their fair treatment, have the highest priority. Blackfort seeks to permanently protect and reconcile the interests of its clients, shareholders, and employees. Nevertheless, conflicts of interest in a company providing different financial services cannot always be completely ruled out. In accordance with the statutory provisions, Blackfort therefore informs about its precautions for dealing with potential conflicts of interest.

Conflicts of interest may arise between the companies, the management, the owner, the employees, or other persons associated with Blackfort and their customers or between their clients.

The consistent client orientation in the corporate culture is the central instrument to avoid influencing non-judgmental interests in asset and portfolio management or other services. Great care in selecting employees, commitment to the highest standards and respect for international market opportunities help Blackfort to put clients interests at the centre of its actions.

Organizational measures to avoid conflicts of interest

Blackfort has taken the following measures to prevent potential conflicts of interest:

• Create a compliance function that is responsible for identifying, avoiding and managing potential conflicts of interest and taking appropriate measures where necessary;
• Establishing and maintaining a client and risk-oriented organization that ensures the financial and regulatory integrity of the company at all times;
• Organizational measures to safeguard client interests in asset management;
• Arrangements for the acceptance and granting of benefits and their disclosure;
• The delineation of business areas and functions from each other and simultaneous control of the flow of information among each other (as far as this makes organizational sense);
• Arrangements concerning the treatment and disclosure of proprietary transactions in financial instruments of employees and institutions;
• Rules governing the acceptance of gifts and other benefits by employees and organs;
• Compensation arrangements for employees that do not automatically result in higher wages for the benefit of the company or the assumption of greater risk by the customer;
• The Company does not exercise any shareholder rights within the meaning of Article 367h para. 1 fig. 1 and 4 PGR;
• Ongoing training of the employees.

Disclosure of potential or actual conflicts of interest

• Conflicts of interest that can not be avoided and which may arise will be disclosed to the clients concerned prior to a general contract or specific transaction.
• There are no retrocession agreements or other agreements between Blackfort and banks or other third parties regarding partial reimbursement on custody fees, stock exchange and trustee commissions, brokerage fees or other fees. For the customer, the (special) conditions agreed with the respective bank are used.
• For efficient portfolio management, Blackfort also uses investment funds that are launched and managed by Blackfort. When using such products, no double charge of the clients is applied.
• The selection of funds or other products – be it directly in the client portfolio or indirectly via investment funds managed by Blackfort – is carried out exclusively on the basis of customary, qualitative and quantitative selection criteria (best-in-class approach). All purchases of funds and other products are always made in the best interests of the client, whenever possible at net interest rates or against reimbursement of inventory commissions or closing commissions in favor of the client or fund.
• Blackfort receives from other service providers, e.g. Brokers, gratuitous or discounted payments in connection with securities transactions, such as financial analysis or other informational material, training and, in part, technical services and equipment for accessing third-party information systems. The receipt of such donations is not directly related to the services rendered to the customer. Blackfort uses these grants to provide its services in the high quality claimed by the customer and to continuously improve them.
• Partly, Blackfort pays success-based commissions and fixed fees to tied or independent intermediaries who supply Blackfort with or without reference to a specific business to customers or individual transactions. In addition, tied agents may also receive direct payments from third parties, in particular, fund companies and securities issuing houses, in addition to the agency fees paid by Blackfort.
• Financial analyses prepared or disseminated by Blackfort also inform about relevant potential conflicts of interest.