Policy documents and guidelines

Risk management instructions

The instruction summarizes Slättö Förvaltning AB and funds managed by Slättö Förvaltning AB's instructions, procedures and processes in relation to risk management, liquidity management, financial leverage, operational risk and sustainability risks. Risk management enables the company to effectively manage uncertainty and related risks and opportunities. Slättö Förvaltning AB's Board of Directors has adopted the principle of "the three lines of defense" based on the AIF Manager and functions that own and manage risks, the risk and compliance function and the internal audit function.

Investment committee policy

The Board of Directors of Slättö Förvaltning AB has appointed an Investment Committee to make portfolio management decisions on behalf of the funds. To this end, the Board has adopted this policy, which aims to describe the composition of the Investment Committee and the regulations and frameworks that will govern the work of the Investment Committee. The policy also describes the procedures in place for the various decision-making stages in both decision-making and execution of portfolio management decisions.

Portfolio management decisions shall be made on a well-informed basis, including market analysis, SWOT, sustainability risks and aspects and the results of due diligence. Investments must comply with the investment strategy and fund compliance. The policy also considers management in the event of a conflict of interest.  

Instruction on measures against money laundering and terrorist financing

This instruction is based, among other things, on Swedish laws and regulations regarding money laundering and terrorist financing. The instruction aims to ensure that the company at all times has well-functioning and effective procedures to prevent the business from being used for money laundering and terrorist financing. The company must draw up instructions and implement procedures against money laundering and terrorist financing based on the company's activities.

Instructions for managing conflicts of interest

Conflicts of interest may arise and are a natural part of many business activities. As an AIFM, all reasonable steps should be taken to avoid conflicts of interest. This instruction is intended to establish procedures to ensure that the Company meets the requirements for identifying, managing and reporting conflicts of interest that may arise in the business.

Conflicts of interest arising from the remuneration of employees of the Company are documented and managed within the remuneration policy of the AIFM.  

Instruction for Compliance

This instruction clarifies the responsibility of the Board of Directors to establish, apply and maintain appropriate policies and procedures to detect risks that the company cannot fulfill its obligations under laws and regulations. The company's board of directors is ultimately responsible for ensuring that the company's operations are conducted in accordance with applicable rules, including laws and regulations as well as government regulations, general advice, internal policies, instructions and similar industry and market practices.

The company's CEO is responsible for the daily operations and for ensuring that the internal rules established in the company are implemented and applied in the business. To support the management in these matters, the Board of Directors has appointed a Compliance Officer who shall work independently of the business operations in accordance with this instruction.

Remuneration policy

The Company's remuneration policy is compatible with and promotes sound and effective risk management and counteracts risk-taking that is incompatible with the alternative investment funds' risk profile, fund rules, articles of association or equivalent regulations. The Company also follows the guidelines for sound remuneration policy published by the European Securities and Markets Authority (ESMA) and other employment laws and regulations applicable in Sweden.

The Company shall analyze the risks, including sustainability risks, associated with the AIFM's remuneration policy and remuneration system. Based on the analysis, the Company shall identify specifically regulated staff of the AIFM.

Code of Conduct

Slatless Code of Conduct describes our way of working and guides us in our business relationships. It is based on the UN Global Compact's ten principles on human rights, labor, environment and anti-corruption. The Code of Conduct covers all company employees, including consultants.

Code of conduct for suppliers

The company's suppliers are an important part of our sustainability delivery and impact. Code of Conduct for Suppliers aims to clarify requirements and guidelines for the company's suppliers and covers all the company's suppliers, including subcontractors and partners. The code is based on the UN Global Compact's ten principles. Serious breaches of the code are always considered a material breach of contract.  

Code of conduct for suppliers is complemented by a due diligence Q&A for the contractors used by the company.  

Sustainability policy

In Plain Island Sustainability policy clarifies guidelines for how the company's sustainability work should be conducted. It covers all employees and all parts of the company's operations. The sustainability work shall be conducted through the daily work and contribute to a sustainable development of the company as well as society.