MUFG Lux Management Company S.A.
MUFG Lux Management Company S.A. (hereinafter “MUFGLM”) is authorized to handle a wide range of investment funds, covering all legal structures (SICAV, FCP, Trust) and fund types (UCITS, AIF, SIF, RAIF). These include investment strategies with long traditional funds and equity strategy, as well as hedge funds, real estate and private equity funds.
Serving clients since 1995, our entity offers a “one-stop shop” model as our teams provide a wide range of services to accelerate the establishment of funds and provide cost-effective management solutions that minimize operational risk. We believe this model provides our clients a significant competitive advantage when compared to the other alternative investment fund managers and management companies based in Luxembourg.
MUFGLM offers distinct services under two licenses: we act as a UCITS Management Company for retail investors in accordance with Chapter 15 of the 2010 Undertakings for Collective Investment Law, and we serve as an Authorized Alternative Investment Fund Manager for institutional investors in accordance with the 2013 Alternative Investment Fund Managers Law.
We primarily focus on the supervision of delegates and service providers, like portfolio managers (usually delegated to the sponsor of the fund), UCI administrators and distributors, and we perform risk management and compliance activities. In addition, we coordinate with supervisory authorities (e.g. CSSF) and auditors.
Through MUFGLM, clients can receive a wide range of services, including UCI administration (e.g. transfer agency, fund administration and domiciliation), as well as investment management, distribution (usually delegated to a sub-distributor) and international registration.
MUFGLM acts as a link between funds, depositaries, central administrators, portfolio managers, distributors and other entities involved in successfully marketing funds within the European Union through the European Passport, Europe in general, Asia and Latin America. In addition, we provide connections to prospective investors.
Our services are designed to serve several investment classes bundled with different fund structures governed by Luxembourg, Cayman or Bermuda law. Our bespoke and efficient investment fund solutions enable banks, asset managers, insurance companies, pension funds and institutional investors to concentrate on their core functions and benefit from our extensive experience and optimized processes for comprehensive solutions. We provide clients with a single point of contact as we work with a limited number of best-in-class selected UCI administrators.
- Best Execution
- Proxy Voting and Engagement
- Complaint Handling
- Remuneration Policy
- Conflicts of Interest Policy
- Inducements Policy
- Summary of Investor Rights
- Whistle Blowing
Within the framework of its activities, MUFG Lux Management Company S.A. (the “Company”) and its affiliates and service providers, as data processors on behalf of the Company (“we”, “us”), will collect, store, use, disclose or otherwise process personal data of individuals (“you”) with whom we correspond, communicate and entertain a professional relationship.
We will process your personal data in accordance with Regulation (EU) 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (the “General Data Protection Regulation”, “GDPR”), as amended or replaced from time to time, as well as any other applicable law or regulation relating to the protection of personal data.
The Company’s privacy notices below set out to explain the details of the Company’s role as data controller and how your personal data is processed.
If you are an investor or connected to an investor in a fund for which the Company is a service provider (e.g., as management company or alternative investment fund manager), please refer to our Investor Privacy Notice here attached.
If you are connected to a client of the Company (e.g. you are an employee, a signatory, a director, a beneficial owner, etc. of a client of the Company), please refer to our here attached.
In any other case (e.g., you are a service provider to the Company or connected to such service provider or you are in touch with the Company in general) or if in doubt, please refer to our here attached.
For any further information related to the processing of your personal data by the Company, you can contact us via post mail to the attention of the “data protection team” at 287-289, route d’Arlon, L-1150 Luxembourg, Grand-Duchy of Luxembourg, or via email at: [email protected]
Key Information Documents (KIDs)
The Company’s disclosures below set out to explain the details of how the Company complies with the disclosure requirements in accordance with Regulation (EU) 2019/2088 of 27 November 2019 on sustainability-related disclosures in the financial services sector (“SFDR”).
I. Integration of Sustainability Risks [Article 3 SFDR disclosure]
The Company as a third-party management company is fully committed to having a sustainable investment approach for its investments when required by the initiator or investment manager of its fund. The manner and extent in which this sustainable investment approach is applied varies by fund and sub-fund.
The Company is able to offer tailor made solutions for specific funds by making sure that any policies or general approach of the initiator or investment manager of the fund on the integration of sustainability risks are duly taken into consideration and embedded in the delegated investment manager’s investment process and in particular where the investment policy is promoting environmental or social characteristics (Article 8 SFDR funds) or having sustainable investment as an objective (Article 9 SFDR funds). The Company itself, however, decided not to have its own policy on the integration of sustainability risks (as defined in SFDR) in order to be able to adapt to the policies and procedures of the delegated investment managers.
The Company’s own risk policy takes into account sustainability risks in certain circumstances.
II. Consideration of adverse impacts of investment decisions on sustainability factors [Article 4 SFDR disclosure]
The Company has a number of funds under management, being a combination of own funds and third-party funds (together the “Funds”). Investment decisions made for those Funds may or may not currently take into account the adverse impacts on sustainability factors (as defined in SFDR) as this is actually defined at the level of each sub-fund.
The Company is committed to ensuring that its Funds and its delegates’ investment decisions are fully aligned with the strategy, policies and objectives of the Funds that it manages.
Where a Fund promotes environmental characteristics, promotes social characteristics or has sustainable investment as an objective, the Company will ensure that sustainability risks in relation to the Fund are considered and sustainability risk management is delegated to the relevant investment manager of the Funds that the Company manages.
In the case where the Fund’s investment manager considers principal adverse impacts of investment decisions on sustainability factors, a statement on due diligence policies with respect to those impacts is available on the Company’s website or on the investment manager’s website (see table included in the file “OVERVIEW SFDR ART 8 AND 9 FUNDS” in point VI. at the end of the “ESG Disclosures”) and will include:
- information about their policies on the identification and prioritisation of principal adverse impacts sustainability impacts and indicators;
- a description of the principal adverse sustainability impacts and of any actions in relation thereto taken or, where relevant, planned; brief summaries of shareholder/unitholder engagement policies (where applicable);
- a reference to their adherence to responsible business conduct codes and internationally recognised standards for due diligence and reporting and,
- where relevant, the degree of their alignment with the objectives of the agreement within the United Nations Framework Convention on Climate Change, signed in Paris on April 22nd, 2016 (the “Paris Agreement”).
III. No consideration of adverse impacts of investment decisions on sustainability factors [Article 12 SFDR Level 2 disclosure]
Where a Fund does not promote environmental or social characteristics or have sustainable investment as an objective, the Company does not consider principal adverse impacts of investment decisions on sustainability factors as it considers that the best interests of the Funds’ investors are served by following the investment objectives and policies of the Funds.
For all its Funds the Company takes into account the sustainability risks to the extent that such risks form an intrinsic part of other risks, such as market risk and operational risk. However, the Company does not consider this to amount to considering the adverse impacts on sustainability factors of investment decisions as set out under SFDR.
IV. Integration of Sustainability Risks on Remuneration Policies [Article 5 SFDR disclosure]
The Company’s remuneration policy is consistent with, and promotes, sound and effective risk management. It does not promote risk taking which is inconsistent with the risk profile of the funds that the Company manages. The remuneration policy does not explicitly take into account sustainability risks. However, the policy applies the principle of effective risk management to sustainability risk in the same way that it does to other forms of risk.
V. Sustainability Related Disclosures [Article 10 SFDR disclosure]
As a third-party management company, the Company is fully committed to having a sustainable investment approach for its investments when required by the initiator or the investment manager. The manner and extent in which this sustainable investment approach is applied varies by fund and sub-fund.
The Company offers tailor made solutions for specific funds or sub-funds where their investment policy involves the promotion of environmental and/or social characteristics or which have sustainable investment as their objective by making sure that for each financial product referred to in Article 8(1) and Article 9(1), (2), and (3) of SFDR the following information is published and maintained:
(a) a description of the environmental and/or social characteristics or the sustainable investment objective of the relevant fund or sub-fund;
(b) information on the methodologies used to assess, measure and monitor the environmental and/or social characteristics or the impact of the sustainable investments selected for the relevant fund or sub-fund, including its data sources, screening criteria for the underlying assets and the relevant sustainability indicators used to measure the environmental and/or social characteristics or the overall sustainable impact of the relevant fund or sub-fund;
(c) the information required to be included in the relevant pre-contractual disclosures as required under Article 8 or Article 9 of SFDR; and
(d) the periodic report information as required under Article 11 of SFDR, where such information is required.
The table included in the file under “OVERVIEW SFDR ART 8 AND 9 FUNDS” in point VI. below will indicate the disclosures or the link to the website listing the disclosures described above.
VI. Overview of funds or sub-funds which qualify as financial products under Article 8 and Article 9 of SFDR
The table in the attached file lists:
- the funds or sub-funds which qualify as financial products under article 8 or article 9 of SFDR;
- the name of the investment manager of the relevant fund or sub-fund;
- the relevant fund or sub-fund classification as defined in SFDR;
- an indication whether adverse sustainability impacts are being considered by MUFGLM in accordance with article 4 of SFDR;
- an indication whether adverse sustainability impacts are being considered by the relevant fund or sub-fund in accordance with article 7 of SFDR;
- the disclosures or the link to the website listing the disclosures described under V. above; and
- if any, additional information of the relevant investment manager’s ESG policies.
MUFG Lux Management Company S.A.
287-289, route d’Arlon L-1150
Grand Duchy of Luxembourg
Phone number: +352 445180 907