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Ampega

BVI Code of Conduct

The BVI (Bundesverband Investment und Asset Management e.V.) Code of Conduct sets out voluntary standards that go beyond the statutory obligations of capital management companies to protect investors and the markets. These standards take account of the fiduciary relationship between the capital management company and the investor, which places particularly high demands on conduct towards investors.
In addition to the statutory requirements and regulations, Ampega Investment GmbH, as a member of the BVI, undertakes to comply with the BVI Code of Conduct, which was established in 2003, on its own responsibility and in an appropriate manner. The current BVI Code of Conduct is available on the BVI website or via the following link(2019_07_BVI_Wohlverhaltensregeln.pdf).

Notes on the remuneration policy

The remuneration system of Ampega Investment GmbH

Pursuant to Section 37 KAGB, Ampega Investment GmbH (hereinafter referred to as Ampega) is obliged to set up a remuneration system that complies with the statutory requirements. The document with the full details

Derivatives - OTC derivative transactions

Here you will find an overview of the contractual partners, as stated in the sales prospectus in the section "Derivatives - OTC derivative transactions": OTC derivative transactions - contractual partners

Top 5 Execution Venue Report as at 31.12.2024

All data on the Top 5 Execution Venue Report can be found here.

Information on the depositaries

Order information and cut-off times
Here you will find up-to-date information on the sub-custodians appointed by the respective custodian, as indicated in the "Custodian - additional information" section of the prospectus:

Guideline on the best possible execution of trading orders (Best Execution Policy)

As an investment company, Ampega Investment is primarily committed to the interests of investors. This Best Execution Policy sets out principles and procedures aimed at achieving the best possible result for the client portfolio in the context of transactions.
Read the entire Best Execution Policy.

Investor information - Turnover rate and associated transaction costs in Ampega mutual funds

Ampega has established suitable procedures for the mutual funds it manages in order to avoid undue detriment to investors' interests through transaction costs, particularly in the context of excessive turnover rates.
The primary objective of index-tracking funds is to replicate an index. The frequency and scope of transactions in the respective fund is therefore determined by the index to be replicated.
For the actively managed investment funds, the company regularly determines the turnover rate of each investment fund. When a defined limit is reached, an escalation and consultation with the fund manager takes place. Continuous monitoring is ensured by the company's Investment Controlling department.

Information on the UCITS and AIF investment assets

Institutional investors such as banks and insurance companies are also frequently invested in investment funds. In order to fulfill their regulatory obligations, these investors require information that goes beyond the minimum information required by law.
This includes various reports and comprehensive portfolio information. Institutional investors request this type of information from the investment fund management companies.
As all investors in UCITS and AIF investment funds should be treated equally, we would also like to provide you with this information to the same extent if requested. To make this possible, however, we need some information from you as an investor and ask you to contact us with the following personal data and an e-mail address registered for you if you would like to receive further information documents on the fund you have purchased and hold.

Customer status: private or institutional
First name and surname
Address (street, zip code, town)
Telephone number
E-mail address

After receiving your e-mail via fonds@ampega.com, we will contact you and check whether you have a legitimate interest in this further information, i.e. whether you are an investor in the fund. We will then send you an overview of any further information available on the fund, which you are welcome to receive from us once you have made your selection."

Suspension of the redemption of target funds

ComfortInvest Substanz & Ampega Real Estate Plus

Complaint management for investors

If you are not satisfied with us, you have the opportunity to complain at any time. We see feedback as an opportunity for improvement. We would therefore be delighted if you would contact us.Contact us
Notes on the complaints procedure:

  • We will process your complaint without delay. Upon receipt, you will promptly receive an acknowledgement of receipt and information on the processing of your complaint.
  • Your complaint will also be recorded by our internal quality management.
  • Processing is of course free of charge.
  • We store and use the personal data transmitted in connection with a complaint exclusively for the processing of your complaint and to fulfill statutory retention obligations and to comply with our possible disclosure obligations.

Ampega Investment has joined the ombudsman's office for investment funds of the BVI.
Private investors/clients have the option of contacting the ombudsman's office for investment funds to resolve disputes with the company.
Disputes in connection with the Investment Act can be settled here by an independent and neutral arbitrator.
Further details are set out in the "Rules of Procedure of the BVI Ombudsman's Office for Investment Funds". Requests for arbitration must be submitted in writing to the BVI Ombudsman's Office, Unter den Linden 42, 10117 Berlin. Further information on the ombudsman's office for investment funds and its procedures can be found at www.ombudsstelle-investmentfonds.de/start/.
If you have a problem, please contact us or your advisor first before initiating proceedings with the ombudsman's office for investment funds. Many issues can be resolved in this way.