SERVICES

MUFG Lux Management Company SA (“MUFGLM”)

MUFG Lux Management Company SA (“MUFGLM”) provides valuable and efficient management services to funds domiciled in Luxembourg, Cayman and Bermuda. MUFGLM offers simple, flexible, scalable and fast solutions – taking responsibility for proper fund governance. Being one of the biggest Alternative Investment Fund Managers in Luxembourg, MUFGLM can provide you with high quality services in all Alternative Investment Fund Managers Directive (“AIFMD”) related duties and in all UCITS V related duties.

      • MUFGLM is fully authorized to handle a wide range of investment funds, covering all legal structures (SICAV, FCP) and fund types (UCITS, AIF, SIF, RAIF) and investment strategies starting with long traditional funds and equity strategy but including also Hedge Funds, Real Estate and Private Equity Funds. MUFGLM started its activities in 1995 and and is currently acting as a UCITS Management Company in accordance with Chapter 15 of the 2010 Undertakings for Collective Investment Law, and as an Authorized Alternative Investment Fund Manager (‘AIFM’) in accordance with the 2013 Alternative Investment Fund Managers Law.

         

        Our company offers a one-stop shop model (i.e. appointing various entities of MUFG group as key service providers for the fund), which is the best solution to accelerate the set up of your fund, to mitigate various operational risk and achieve cost efficiency. Through this model solution, our company presents a competitive advantage compared to the other management companies in Luxembourg.

         

         

        In the case a manager cannot or does not want to act as an AIFM or is seeking for a solution to market its fund(s) to investors in Europe, MUFG offers an alternative to the internal AIFM route by utilizing its Luxembourg based AIFM, MUFG Lux Management Company S.A.
        The role of MUFGLM, in scope of the AIFMD and UCITS V, is to provide the following services:

        • Portfolio Management (usually delegated to the sponsor of the fund)
        • Risk Management
        • Central Administration
        • Distribution (usually further delegated to the sub-distributor)
        • Compliance

         

        MUFGLM will act as a link between the fund, the depository, the central administration, the portfolio manager and the distributor and other possible entities involved in successfully marketing the fund within the EU. MUFGLM will of course also provide the connection to any prospective investors.

         

        We propose our services for several investment classes bundled with different possible fund structures according to Luxembourg, Cayman and Bermuda law. Our bespoke and efficient investment fund solutions enable banks, asset managers, insurance companies, pension funds and other institutional investors to concentrate on their core functions and benefit from our extensive know-how, optimized processes in a one stop solutions. MUFGLM works with a limited number of best-in-class selected Central Administrators while you will have only one point of contact.

         

        Policies

        Best Execution
        Proxy Voting and Engagement
        Complaint Handling
        Remuneration Policy
        Conflicts of Interest Policy
        Inducements Policy

        Privacy Notices

        We value your privacy.

         

        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

        Investor Privacy Notice


        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

        Client Privacy Notice


        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

        Third Party Privacy Notice


        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: dataprotection_mufglm@lu.tr.mufg.jp

         

        ESG Disclosures

         

        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 Sustainability Impacts [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 investment manager’s website (see table included in the pdf-file 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); and
        • 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 Sustainability Impacts [Article 4 SFDR 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 is able to offer 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 relevant information described above can be found in the prospectus of the relevant fund or on the website of the investment manager of the relevant fund or sub-fund. The table included in the pdf-file in point VI. at the end of the “ESG Disclosures” lists:

        • the relevant fund or sub-fund classification as defined in SFDR; or
        • the link to the investment manager’s website listing the disclosures described above or an indication that these disclosures are available in the prospectus of the relevant fund or sub-fund.

         

         

        VI. Overview of Article 8 and Article 9 SFDR funds or sub-funds

        The table in the attached pdf provides an overview of the Article 8 and Article 9 SFDR funds or sub-funds under the supervision of the Company, the related investment manager’s name, and the link to the related investment manager’s website detailing the following disclosures (where relevant) or an indication that these disclosures (where relevant) are available in the prospectus of the relevant fund:

        • Article 4 SFDR disclosures (Consideration of Adverse Sustainability Impacts or No Consideration of Adverse Sustainability Impacts);
        • Article 10 SFDR disclosures (Sustainability Related Disclosures).

         

        OVERVIEW FUNDS AND IM WEBSITE
      • MUFG Lux Management Company S.A.
        287-289, route d’Arlon L-1150
        Luxembourg,
        Grand Duchy of Luxembourg
        Phone number: +352 445180 907