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Important information

The Robeco Capital Growth Funds have not been registered under the United States Investment Company Act of 1940, as amended, nor or the United States Securities Act of 1933, as amended. None of the shares may be offered or sold, directly or indirectly in the United States or to any U.S. Person (within the meaning of Regulation S promulgated under the Securities Act of 1933, as amended (the “Securities Act”)). Furthermore, Robeco Institutional Asset Management B.V. (Robeco) does not provide investment advisory services, or hold itself out as providing investment advisory services, in the United States or to any U.S. Person (within the meaning of Regulation S promulgated under the Securities Act).

This website is intended for use only by non-U.S. Persons outside of the United States (within the meaning of Regulation S promulgated under the Securities Act who are professional investors, or professional fiduciaries representing such non-U.S. Person investors. By clicking “I Agree” on our website disclaimer and accessing the information on this website, including any subdomain thereof, you are certifying and agreeing to the following: (i) you have read, understood and agree to this disclaimer, (ii) you have informed yourself of any applicable legal restrictions and represent that by accessing the information contained on this website, you are not in violation of, and will not be causing Robeco or any of its affiliated entities or issuers to violate, any applicable laws and, as a result, you are legally authorized to access such information on behalf of yourself and any underlying investment advisory client, (iii) you understand and acknowledge that certain information presented herein relates to securities that have not been registered under the Securities Act, and may be offered or sold only outside the United States and only to, or for the account or benefit of, non-U.S. Persons (within the meaning of Regulation S under the Securities Act), (iv) you are, or are a discretionary investment adviser representing, a non-U.S. Person (within the meaning of Regulation S under the Securities Act) located outside of the United States and (v) you are, or are a discretionary investment adviser representing, a professional non-retail investor. Access to this website has been limited so that it shall not constitute directed selling efforts (as defined in Regulation S under the Securities Act) in the United States and so that it shall not be deemed to constitute Robeco holding itself out generally to the public in the U.S. as an investment adviser. Nothing contained herein constitutes an offer to sell securities or solicitation of an offer to purchase any securities in any jurisdiction. We reserve the right to deny access to any visitor, including, but not limited to, those visitors with IP addresses residing in the United States.

This website has been carefully prepared by Robeco. The information contained in this publication is based upon sources of information believed to be reliable. Robeco is not answerable for the accuracy or completeness of the facts, opinions, expectations and results referred to therein. Whilst every care has been taken in the preparation of this website, we do not accept any responsibility for damage of any kind resulting from incorrect or incomplete information. This website is subject to change without notice. The value of the investments may fluctuate. Past performance is no guarantee of future results. If the currency in which the past performance is displayed differs from the currency of the country in which you reside, then you should be aware that due to exchange rate fluctuations the performance shown may increase or decrease if converted into your local currency. For investment professional use only. Not for use by the general public.

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Managing conflicts of interest

1.1 Introduction

The provision of indices is inherently subject to certain types of conflicts of interest, which implies the existence of opportunities and incentives to manipulate indices. Such risk factors are common to all indices and should be made subject to adequate governance and control requirements.Avoiding and managing conflicts of interest at Robeco Indices B.V. is an important element in ensuring that the interest of clients, the financial markets and the integrity and reputation of Robeco Indices B.V. is protected. Conflicts of interest can arise between Robeco Indices B.V., and its directors, employees, clients, users and suppliers. Conflicts of interest (or perceived conflicts of interest) may also arise from the ownership and control of Robeco Indices B.V., as it is part of the Robeco organization, which focuses on active asset management.

1.2 Objective

Robeco Indices B.V. has a Conflicts of Interest Policy in place that ensures that (potential) conflicts of interest are adequately identified, disclosed, managed and avoided. The policy describes the key conflicts of interest that may arise at Robeco Indices B.V., as well as the measures that have been implemented by Robeco Indices B.V. to manage these conflicts of interest adequately. This document is an outline of the Conflicts of Interest Policy.

1.3 Identification of (potential) conflicts of interest

Robeco Indices B.V. maintains an overview of identified (key) conflicts of interest relating to its activities and its ownership and control structure. If a new conflict of interest is identified on an ad hoc basis, it is ensured that it is included in the overview of identified conflicts of interest. In addition, an annual analysis is conducted to determine whether new conflicts of interest can be identified.

1.4 Measures to avoid or manage (potential) conflicts of interest

Subsequent to the identification of (potential) conflicts of interest, it is assessed whether adequate measures are in place to avoid or manage these. If such analysis shows that a potential conflict of interest is not being managed effectively, additional (or other) measures will be taken.
If an employee working for Robeco Indices B.V. identifies a conflict of interest that has not been or appears not to be appropriately managed, the employee must report this conflict of interest to his/her superior and to Compliance.
Employees working for Robeco Indices B.V. are subject to several policies and measures addressing potential conflicts of interest, such as:

  • Code of Conduct

  • Segregation of functions and duties

  • Handling confidential and inside information

  • Chinese Walls

  • Private investment transactions policy

  • Ancillary functions, gifts and other inappropriate stimuli

  • Equal treatment of clients

  • Remuneration policy

  • Oversight and governance

Code of Conduct

Employees working for Robeco Indices B.V. are trained on the Code of Conduct and other compliance polices upon joining and periodically thereafter. All employees certify that they will comply with the Code and the related Compliance policies.

Segregation of functions and duties

Conflicts of interest may arise within Robeco Indices B.V. and between Robeco Indices B.V. and other entities of the Robeco organization as a result of combining different tasks and responsibilities. Robeco Indices B.V.’s clear organizational structure with well-defined, transparent and consistent roles and responsibilities for all persons involved in the provision of an index aims to prevent such conflicts of interest.
Robeco Indices B.V. has taken appropriate measures to operationally separate the design and calculation of the indices from each other and other parts of business that may create an actual or potential conflict of interest. The calculation of the indices has been outsourced to a third party service provider.

Handling confidential information and inside information

Employees working for Robeco Indices B.V. must exercise due care in dealing with confidential information. Such information may only be used for the specific purpose for which it was obtained. Such information may only be disseminated amongst a very restricted group of insiders on a ‘need-to-know’ basis. Employees are bound by a non-disclosure requirement based on their employment contract.

Chinese Walls

To prevent inside and/or confidential information from being disseminated, Chinese Walls have been established between Robeco Indices B.V. and other entities of the Robeco organization. These Chinese Walls restricts access to potentially price sensitive information related to the indices provided by Robeco Indices B.V. and index changes to staff who have a need to know such information to perform their duties in order to protect such data.

Private investment transactions policy

To avoid any semblance that employees make use of inside information, a private investment transactions policy applies. Employees engaged in the index design and maintenance are generally prohibited from purchasing or selling financial instruments (other than open-end investment funds).

Ancillary functions, gifts and other inappropriate stimuli

Taking on ancillary functions and/or accepting gifts, invitations and other favors in whatever form, can cause an employee to act in their own private interests rather than on behalf of Robeco Indices B.V. and/or the users of its indices. Robeco Indices B.V. does not tolerate this. Rules and procedures on taking on and reporting of ancillary functions and regarding accepting and offering gifts and invitations have been set. These rules are contained in the Regulations on Ancillary Functions, the Gifts, Entertainment & Anti-bribery Policy and the general Code of Conduct.

Equal treatment of clients

Robeco Indices B.V. applies the principle that clients are given equal treatment in equivalent situations. An example of this is that announcements with respect to changes in an index or index methodology are communicated to all clients at the same time. This ensures that one client does not have an information advantage over another.

Remuneration and performance evaluation

The remuneration policy applicable to employees working for Robeco Indices B.V. stimulates a healthy corporate culture, focused on achieving sustainable results in accordance with the long-term objectives of Robeco Indices B.V. and its stakeholders. A link between the remuneration of an employee involved in the provision of an index and the value or performance of that index could offer incentives to manipulation. The risk that this occurs in Robeco Indices B.V. is mitigated by strict risk control measures as laid down in the remuneration policy.

Oversight and governance

Robeco Indices B.V. has established independent functions including Risk Management, Compliance and Internal Audit to monitor and review the index determination and the relevant methodology conducted periodically. Also a permanent Oversight Committee has been established to ensure independent oversight of all aspects of the provision of indices. These independent functions and the Oversight Committee are staffed with members who are not involved in the design, calculation or maintenance of the indices of Robeco Indices B.V.. A member of the Oversight Committee who is also performing activities for Robeco Institutional Asset Management B.V., does not have access to any price-sensitive information resulting from the index rebalancing process, which he can pass on within the Robeco organization for the benefit of actively managed portfolios. In addition, the independence of the Oversight Committee as a whole is ensured through voting rights and the appointment of nondependent members.Where any judgement or discretion in the index determination process is required, Robeco Indices B.V. ensures that it is independently and honestly exercised. Given the methodologies used for the determination of the indices of Robeco Indices, any exercise of judgement or discretion in the determination of a benchmark, the disregard of any input data or other changes in or deviations from standard procedures and methodologies will rarely occur. Should such an event nevertheless occur, then the event will be carefully reviewed by the management and the Oversight Committee of Robeco Indices B.V.

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