Compliance Review of Investors

Signet Asset Management Latvia IPS, in order to comply with the requirements of the regulatory enactments on prevention of the risks of money laundering, financing of terrorism and proliferation and sanctions violations, invites investors who own shares of the mutual funds managed by Signet Asset Management Latvia IPS — Integrum Multi-Asset Total Return USD Fund, Integrum Global EUR Stock Index Fund, as well as shares of the mutual fund’s Integrum Global Bond Fund sub-funds Integrum Global USD Bond Fund and Integrum Global EUR Bond Fund (hereinafter – investors), to contact Signet Asset Management Latvia IPS and submit information and documents for the compliance review of investor in person.

To contact Signet Asset Management Latvia IPS, please call during business hours +371 67002775 or send an email to [email protected]

Investors whose shares of the mutual funds are safekept in ABLV Bank Luxembourg, S.A. in judicial liquidation, have to contact ABLV Bank Luxembourg S.A. in judicial liquidation in judicial liquidation  and provide their consent to the transfer of information and documents necessary for the compliance review  to Signet Asset Management Latvia IPS. Upon receipt of the investor’s consent, the ABLV Bank Luxembourg, S.A in liquidation will ensure the transfer of the information and documents required for compliance review of the investor to Signet Asset Management Latvia IPS.

Investor review process is performed by Signet Asset Management Latvia IPS and supervised by the regulator – Latvijas Banka.

Investor compliance review constitutes an essential precondition for Signet Asset Management IPS to continue cooperation with the investor including processing transactions with the shares of mutual funds. Signet Asset Management IPS will process transactions with the shares of mutual funds only after the investor’s compliance review and if there are no restrictions in accordance with the legal acts.

To initiate the compliance review, the investor has to submit the following documents

• identification and representation documents;
• Filled “Individual Investor Questionnaire” or “Legal Entity Investor Questionnaire”
• “Ultimate Beneficial Owner Application” in case investor is a legal entity or natural person who in “Natural Person Investor Questionnaire” indicated that he is not the true beneficiary;
• Financial instrument account statement or equivalent document (e.g. a formal notice issued by the respective financial institution) attesting investor’s ownership of the shares of mutual funds. Requirements for the document here;
• If shares were obtained after 18/02/2018 – a document justifying the receiving of the shares of mutual funds from a third party (e.g. a purchase agreement or a gift agreement);

During the review, the investors might have to submit other documents requested by Signet Asset Managment IPS, e.g. documents confirming source of funds used to acquire shares of mutual funds, documents confirming source of wealth.

Submission procedure

Investor should submit the documents in person or by the authorized representative. Documents should be submitted at Antonijas Street 3, Riga, LV-1010, the Republic of Latvia. For arranging a meeting, please call beforehand +37167002775 during Signet Asset Management IPS business hours or send an email to [email protected]

After identification of the Investor, and its representatives, the investor will be provided with access to the Signet Asset Management IPS system Online Office for secure communication in the future.

If investor cannot meet in person, please contact Signet Asset Management IPS about a possible solution.

Decision on sufficiency and adequacy of each investor’s documents will be made individually, considering the results of the investor’s compliance review.

Questions and answers on investors verification

How do I apply for compliance review of Investor?

The investor should contact Signet Asset Management Latvia IPS during business  hours by phone +371 67002775 or by e-mail [email protected]. The investor will be registered for a face-to-face meeting with Signet Asset Management Latvia IPS, during which the investor will be identified and the necessary documents will be accepted, and the investor will be given access to Signet Asset Management Latvia IPS Online Office system for further communication during the compliance review process.

Why does the investor need to attend a face-to-face meeting?

A face-to-face meeting with Signet Asset Management Latvia IPS is necessary for the identification of the investor and its authorised representatives.

What documents do I need to submit to start the compliance review of Investor?

The section “Compliance Review of Investors” of the website lists the documents that the investor needs to submit in order to initiate compliance review.

If it is not possible for the investor to come to Latvia in person, how the face-to-face identification can be ensured?

The investor is able to submit the documents necessary for the initiation of the compliance review ofinvestor through the authorised persons. To this end, the investor needs to draw up a notarial power of attorney in his country of residence to an able-bodied person whom the investor trusts and who can attend a face-to-face meeting in Latvia. The notarial power of attorney must be presented by the authorized person at the time of the face-to-face identification.

Will investors who are creditors of ABLV Bank, AS in liquidation and who have been subject of the compliance review of  the creditor process be subject to a new compliance review of investor process?

Yes, the compliance review will apply to all investors. The compliance review is an essential precondition for Signet Asset Management Latvia IPS to continue cooperation with the investor, including processing transactions with investment certificates. Signet Asset Management Latvia IPS will process transactions with investment certificates only after the investor’s compliance review and if there are no restrictions in accordance with the legal acts.

What are requirements for the compliance review of investor?

The compliance review process will be carried out under the control of the regulator, the Bank of Latvia, in accordance with the established investor compliance review procedures aimed at the preventing of the risk of money laundering, financing of terrorism and proliferation, and sanctions violations.

Can additional documents be requested as part of the compliance review of investor?

During the review, the investors might have to submit other documents requested by Signet Asset Management Latvia IPS, such as documents confirming source of funds used to acquire investment certificates of mutual funds, documents confirming source of wealth.

Can additional documents be requested as part of the compliance review of investor?

The investor will be able to submit an application for transactions with investment certificates to Signet Asset Management Latvia IPS after completion of the investor verification process, if the verification does not result in any restrictions on the execution of the transaction set out in the NILLTPF and other regulatory enactments. Information on the completion of the verification process will be provided to the investor in the Online Office system. If the investor has not been contacted by the Company’s staff, it means that the verification of the investor concerned has not yet been completed. The investor will receive a request for the required information or documents in the Signet Asset Management Latvia IPS Online Office system. The investor will be able to provide the requested information or documents via the Online Office system.

When will the investor be able to submit an application for transactions with investment certificates?

The investor will be able to submit an application for transactions with investment certificates to Signet Asset Management Latvia IPS after completion of the investor compliance review process, if the review does not result in any restrictions on the execution of the transaction set out in the the applicable normative acts . Information on the completion of the compliance review process will be provided to the investor in the Online Office system. If the investor has not been contacted by the Company’s staff, it means that the compliance review of the investor has not yet been completed.