Brummer Multi-Strategy

Legal information

Best possible result when executing orders

In its capacity as investment manager, Brummer Multi-Strategy AB is required to take all reasonable measures to achieve the “best possible result” when executing and, where applicable, aggregating and allocating orders. The company’s Board of Directors has adopted a policy for achieving the best possible result. Clients may obtain a copy of this policy upon request.

Incentives

Brummer Multi-Strategy AB manages special funds and provides discretionary portfolio management services. Under the current incentive rules, which are based on EU directives, the investment manager may only pay or receive a fee or commission or give or receive a benefit in kind (incentive) in connection with these services under certain conditions. If incentives are paid or given to or by a third party, the fee, commission or benefit in kind must be designed to enhance the quality of the activity concerned and not prevent the investment manager from acting honestly, fairly and professionally and thereby in the interests of the investors. Below is a summary of the incentives and closely related forms of compensation that are used in the business.

Investment analysis and minor non-monetary benefits from third parties

Brummer Multi-Strategy AB receives certain analysis/research material from a small number of selected counterparties. The cost of this is covered from the investment manager’s own funds. Minor non-monetary benefits such as brief market updates, data relating to market prices and trading volumes, general non-substantive macro analysis as well as conferences and seminars organised by third parties also occur. However, such minor non-monetary benefits do not entail any additional cost to the investors, nor do they limit the investment manager’s ability to act in the interests of the investors.

Compensation from third parties – investment in other investment managers’ funds

Brummer Multi-Strategy AB’s funds invest in funds managed by other companies in the Brummer group. The investment manager does not receive any discount or direct compensation from these companies or funds. It does, however, receive compensation from its sister company B & P Fund Services AB, primarily to cover costs for the business. The compensation does not limit the investment manager’s ability to act in the interests of the unit owners.

Compensation to third parties – distribution compensation

B & P Fund Services AB is a distributor for Brummer Multi-Strategy AB’s funds but does not receive any compensation from the investment manager for this. B & P Fund Services AB does, however, receive compensation from the Brummer group’s other investment management companies, which is based on a percentage of the investment manager’s funds’ investments in underlying funds. The compensation is received primarily to cover costs for the business. The compensation to B & P Fund Services AB is 0.3 per cent, which is the maximum compensation that a distributor can receive for brokering the investment manager’s funds. Third-party compensation does not entail any additional costs to the customer.

Further information on incentives is provided free of charge to investors upon request.

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