East Capital Financial Services AB

East Capital Financial Services AB (the "Company") is a fully owned subsidiary of East Capital Holding AB and is part of the East Capital Group. East Capital Group conducts investment activities with a focus on active management and responsible ownership and offers a number of strategies and specialities within active management of equities, fixed income and real estate. The managers work according to a clear ESG framework and also benefit from the scale and collective strengths of the Group.

Management

The role of the Board is to manage the affairs of the company on behalf of the shareholders. The members of the Board of Directors are elected by the shareholders for the period from the Annual General Meeting up to and including the next Annual General Meeting. The work of the Board is primarily governed by the Board's Rules of Procedure, which describe in detail the Board's duties, the allocation of responsibilities within the Board and the format of Board meetings. The Board of Directors consists of the members listed below.

The CEO manages the day-to-day administration of the company in accordance with the Board's guidelines.

The Board of Directors

Peter Elam Håkansson
Ordförande och styrelseledamot

Per Elcar
CEO and Board Member

Fredrik Boheman
External Board Member

The corporate governance of East Capital Financial Services aims to create a sound and effective corporate culture that promotes the trust of customers and society. Through good organisation and corporate governance, the business should be managed as responsibly and efficiently as possible.

The governance, management and control of East Capital Financial Services is divided between the owner, the Board of Directors and the CEO. In addition, the company has internal control functions in the form of independent risk control, compliance and internal audit functions.

The Board of Directors has ultimate responsibility for internal control, financial development and reporting, risk management and ensuring that the organisation complies with applicable laws and regulations. The Board's work is governed by the Board's rules of procedure. The Chairman of the Board of Directors leads the work of the Board and has ongoing contact with the CEO to monitor the company's operations.

The CEO is responsible for the day-to-day management of the company in accordance with the instructions of the Board of Directors and other policies and governing documents. In addition, the CEO ensures that the Board is kept informed of the development of the company and its environment in order to make informed decisions.

East Capital Financial Services' operations comply with applicable laws and regulations such as the Swedish Companies Act, the Swedish Annual Accounts Act and the Swedish Securities Market Act. In addition, East Capital Financial Services is governed by an internal regulatory framework consisting of various governing documents such as the Board's Rules of Procedure, instructions to the CEO and a large number of policy documents and instructions on risk management, conflicts of interest, money laundering, remuneration, etc. All governing documents are reviewed on a regular basis.

The company has guidelines that set out how it manages the conflicts of interest that it has identified. The guidelines have been adopted by the Board of Directors of East Capital Financial Services AB and are appropriate in view of the size and organisation of the investment firm and the nature, scope and complexity of its operations.

Conflict of interest policy

1. Identifies the circumstances that constitute or may give rise to a conflict of interest entailing a material risk that the interests of one or more clients are adversely affected in relation to the investment services, activities and ancillary services performed by or on behalf of the investment firm; and
2. Specifies the procedures to be applied and the measures to be taken to manage such conflicts.

East Capital Financial Services AB works continuously to identify potential conflicts of interest and to update the procedures for managing them. The Board of Directors adopts an annual policy for managing conflicts of interest.

How to file a complaint:

As our customer, it is important to us that you are satisfied. If for any reason you are not satisfied with any product or service, we are grateful that you take the time to contact us, so that we have the opportunity to find out what happened. Complaints are of course free of charge.

1. Contact your advisor or the distributor who provided the product to you.

2. If you are still not satisfied after receiving a response from your first contact, you can contact our Complaints Officer. Please write to us, describing what happened, what you are dissatisfied with, and who you have previously contacted, as clearly and comprehensively as possible.

Write to us via email, klagomal@eastcapital.com,or via mail to:

East Capital Financial Services AB
Att: Complaints Officer
Box 1364
111 93 Stockholm

We strive to respond to your complaint without unnecessary delay and no later than 14 days after we receive it. If the response requires a longer processing time, you will be informed of this.

3. If you are still not satisfied after receiving a response from the Complaints Officer, you can contact one of the following bodies:

For advise

Consumer Guidance
Consumer advisor in your municipality

Konsumenternas 
Box 24215, 104 51 Stockholm, Sweden
Phone 0200-22 58 00 (from abroadt: +46 8 22 58 00)
www.konsumenternas.se

Consumer Agency (KO) / Hallå konsument
Consumer Agency, Box 48, 651 02 Karlstad. Telefon 0771-42 33 00. www.konsumentverket.se
Hallå konsument, Box 48, 651 02 Karlstad. Telefon 0771-525 525. www.hallakonsument.se

For dispute resolution

The National Board for Consumer Disputes (ARN)
Kungsholmstorg 5, Box 174, 101 23 Stockholm
Telefon 08-508 860 00
www.arn.se

Also via the EU's online platform
http://ec.europa.eu/odr

 General court, Judicial Agency
https://www.domstol.se/hitta-domstol/allmanna-domstolar/

East Capital Financial Services AB (the "Company") has established guidelines for the best execution of trades and orders. 

Investment firms have a duty to seek the best possible result when placing orders with another person on behalf of the firm. This refers to the firm's obligation to take all reasonable steps to obtain the best possible result, taking into account a number of factors such as price, cost, speed, likelihood of execution and settlement, size and nature, and other factors relevant to execution. These factors should be set against a number of transaction-specific criteria, including objectives, investment focus, risk profile and the nature of the portfolio transaction.

The Company has developed internal rules on how to maximise the performance of Espiria's asset management activities, including portfolio management, and how to monitor and evaluate intermediaries. The internal rules also stipulate that the best execution result should normally be assessed taking into account transaction costs and probability of execution and settlement. The price of the financial instruments may also be taken into account.

Processing of customer orders

East Capital Financial Services AB shall act in the best interests of its clients when providing investment or ancillary services and shall act honestly, fairly and professionally and in a manner that maintains public confidence in the securities market. Once East Capital Financial Services has made a decision to trade in a financial instrument, East Capital Financial Services shall place the order with a counterparty for execution. When placing orders, East Capital Financial Services shall take all reasonable steps to obtain the best possible result for the client.

The group remuneration policy governs the management of variable remuneration for employees. The remuneration system contributes to sound and effective risk management by discouraging excessive risk-taking and conflicts of interest with clients.

Group remuneration policy

Market soundings are conducted, among other things, to assess the interest of potential investors in a potential transaction and its pricing, size and structuring. Market soundings are important for the proper functioning of capital markets. They may include an initial public offering or subsequent offers of securities and do not constitute trading. The new Market Abuse Regulation (MAR) regulates the procedure and handling of information and inside information in the context of market soundings.

East Capital Financial Services has appointed the following fund managers as contact persons for market soundings. 

East Capital Financial Services has appointed the following fund managers as contact persons for market soundings. 

Adrigo
Staffan Östlin

East Capital
Peter Elam Håkansson
Jacob Grapengiesser

Espiria
Peter van Berlekom (aktiemarknaden)
Stefan Pari (räntemarknaden)

Internal control and risk management
East Capital Financial Services AB (the "Company") shall be characterised by good governance, risk management and control. The Company shall be managed in an ethically responsible and professional manner with clear roles and responsibilities. The risk management processes shall be effective and appropriate and shall be managed by the independent risk management function, which is responsible for managing, monitoring and reporting on the overall risks of the Company. There is no separate risk committee within the company.

Three lines of defence principle
The Company's risk management and control is based on the principle of three lines of defence. The first line of defence is the business operations. The second line of defence consists of the Risk Management function and the Compliance function. These are independent of each other and separate from other activities. The third line of defence is Internal Audit, which reports directly to the Board of Directors.

1. First line of defence: Risk management in business operations
Risk management takes place primarily in the first line of defence, which is made up of the business and support functions, with clear responsibility for each department. Within the Company's regulatory framework, there are specific risk management frameworks with policies, guidelines, instructions, risk appetite and limits for each risk type.

2. Second line of defence

2.1 The risk management function
An important part of risk management is to promote a long-term sustainable risk culture and risk-taking that must never jeopardise the company's survival. This culture is based on the governance and decision-making of the Board and management. Within the framework of the Group's financial capacity, the Board has formulated its risk appetite. To ensure that risk-taking remains within the risk appetite and limit structure, there are risk management and risk control processes that cover risk identification, assessment, management, reporting and monitoring for all types of risk to which the company is exposed. The monitoring and control of risks includes mitigation and measurement of financial risks, self-assessment of non-financial risks, incident reporting and follow-up, as well as risk analysis and approval from the control functions for major changes. The risk management function reports an overall picture of the Company's risk exposure on a monthly basis to management and on a quarterly basis to the Board of Directors. In addition, it reports directly to the CEO and the Chairman of the Board as required. The Head of the Risk Management function reports directly to the CEO.

2.2 Compliance function
The Compliance function verifies that the licensable activities are conducted in accordance with laws, regulations, internal rules and good practice. The Compliance function regularly checks and assesses whether the measures and procedures implemented by the Company are appropriate and effective. Furthermore, the Compliance function proposes internal rules, procedures and measures that need to be implemented to minimise the risks of non-compliance and to enable the Financial Supervisory Authority to exercise effective supervision. The compliance function is also responsible for keeping the Company's employees informed and trained on the rules in force at any given time for the operations subject to authorisation that the Company conducts. The Compliance function reports directly to the CEO and reports to the Board of Directors on a quarterly basis and regularly to Group Management, and also reports directly to the CEO and the Chairman of the Board on an ongoing basis as required.

3. Third line of defence - Internal audit
Internal Audit is an internal independent review function appointed by and reporting directly to the Board of Directors of the Company. The work of the internal audit function is based on a risk-based audit plan established by the Board. The plan is based on a thorough risk analysis and the audit work includes reviewing and evaluating the governance and internal control, reviewing and evaluating that the company's organisation, governance processes, IT systems, models and procedures are appropriate and effective, and reviewing and regularly evaluating the reliability and quality of the work performed by other control functions. Internal Audit issues recommendations after each audit and then regularly follows up on the implementation of the recommendations.

The following companies are authorised agents of East Capital Financial Services:

In Hjerta Invest's investment advisory and discretionary portfolio management, as well as East Capital's operations, all orders are forwarded to East Capital Financial Services AB.

East Capital Financial Services AB may, in turn, forward or execute the order. For portfolio management, MFEX Mutual Funds Exchange AB, registration number 556559-0634, is used to execute all orders.

East Capital Financial Services annually obtains the respective counterparty's "Best Execution Policy."

See all counterparties

Agreements & Forms – Hjerta Invest

Hjerta Invest - Avtal om Depå - Diskretionär

Hjerta Invest - Avtal om Depå

Hjerta Invest - Avtal om Depåförsäkring - Diskretionär

Hjerta Invest - Avtal om Depåförsäkring

Hjerta Invest - Avtal om ISK - Diskretionär

Hjerta Invest - Avtal om ISK

Hjerta Invest - Flyttblankett Depå och ISK

Hjerta Invest - Order - Bytesorder

Hjerta Invest - Order - Köp

Hjerta Invest - Order - Sälj och uttag

Hjerta Invest - Överföring - Bankgiro

Hjerta Invest - Överföring - Fullmakt

Authorised agents

The general terms and conditions for East Capital Financial Services' investment services are concluded between you as a client and the Company. Information on which general terms and conditions apply to the company with which you have entered into an agreement is therefore available on request from the respective company.

Knowledge of the customer

Each client is obliged, under the anti-money laundering and counter-terrorist financing regulations, to ensure that information is provided in connection with the counselling.

What is money laundering and the Money Laundering Act?

Criminal organisations try to use financial systems to make money earned from illegal activities transparent. This could be money from drug offences, smuggling, robberies, fraud, child sex trafficking, arms trafficking and more.

All financial companies in the EU are obliged to prevent money laundering. East Capital Financial Services must assess the risk of being used for money laundering. East Capital Financial Services must have a good knowledge of its customers and their business, it must also understand the purpose of the business relationship and of the customer's transactions.

We need to ask you questions

To comply with the Money Laundering Act, we need to ask you additional questions. Here we describe various circumstances or events that require us to pay more attention.

Knowledge of clients

Part of our security work is that you as a customer must always be identified when you do business with us. When you do business via the internet/app, you need to identify yourself using BankID. ID checks are also always carried out during counselling. If you want to carry out a transaction or when you request a new service, you as an existing customer may be asked to present a valid ID document and answer further questions.

If you represent a company or are self-employed, you must be able to show valid identification and prove that you are authorised to represent the company. East Capital Financial Services also needs to know who owns more than 25 per cent of the company and whether anyone has a controlling interest in the company. You must also be prepared to answer questions about the company's activities, its turnover and how the company will use East Capital Financial Services' services.

Transactions

When you want to buy a product, make a deposit or other transaction, you may have to answer questions and show ID if your adviser asks for it. If an adviser does not understand the purpose of a transaction or does not understand where the money is coming from, he or she is obliged to ask. You, the client, should also be prepared to provide receipts, invoices or other documents to support your explanation.

Politically exposed person (PEP)

We need to know if you hold a high political or governmental position, are a member of the management of an international organisation, or are a close relative(family or close associate) of someone who holds such a position. Because of this requirement, we will need to ask you a number of questions when you sign up for a product and/or service.

In some cases, East Capital Financial Services may not provide the service

If you cannot show a valid ID document or cannot identify yourself on the phone or online, East Capital Financial Services will in many cases not be able to provide the requested service. If our advisors do not comply with the Money Laundering Act, East Capital Financial Services may be subject to sanctions from the Swedish Financial Supervisory Authority. It is also important for East Capital Financial Services to do everything in our power to avoid our business and the financial system being used for criminal activities.

If East Capital Financial Services suspects money laundering, this will be reported to the Financial Police, a special unit within the Swedish Police Authority.

At East Capital Financial Services, we take your privacy seriously and a high level of data protection is always a priority. The following document explains how we collect and use your personal data. It also describes your rights and how you exercise them. It is important that you read and understand the document and feel confident about our processing of your personal data. You are always welcome to contact us if you have any questions.

How ECFS Processes Your Personal Data

RTS28 - 2020

RTS28 - 2021

RTS28 - 2022

RTS28 - 2023

RTS28 - 2024

East Capital is a member of the Swedish Investment Fund Association and complies with the "Swedish Code for Fund Management Companies". In addition, East Capital follows the association's Guidelines for fund companies' marketing and information; Guidelines for fund companies' shareholder engagement; Guidelines on the reporting of key figures for mutual funds and special funds and Guidelines on employees' and contractors' own transactions with financial instruments.

Principal Adverse Impact (PAI) statement

Disclosure of Voting Activities