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Credit Suisse Asset Management

Regulatory information

Financial markets are closely regulated to ensure they function efficiently and effectively. Governments and regulatory authorities around the globe have proposed and enacted numerous reforms to help create a more robust financial system.

Shareholder rights: transparency statement, engagement policy and voting rights

Credit Suisse Asset Management ensures that investee companies follow good governance practices engaging with companies and by exercising voting rights.

Further information:

Summary of Investor Rights for EEA domiciled funds

This statement is a summary of investor rights prepared in relation to Regulation (EU) 2019/1156 of the European Parliament and of the Council of June 20, 2019 on facilitating cross-border distribution of collective investment undertakings and amending Regulations (EU) No 345/2013, (EU) No 346/2013 and (EU) No 1286/2014 (the "Regulation").  One of the goals of the Regulation is to ensure that investors are provided with a summary of investor rights resulting from their investment in an undertaking for collective investment in transferable securities in the meaning of Directive 2009/65/EC or, under certain circumstances, in an alternative investment fund in the meaning of Directive 2011/61/EU (hereinafter referred to as "Fund" or jointly as "Funds"). 

It is not the intention of this summary to give an exhaustive list of rights Investors may have. Further information may also be obtained in the respective Fund's prospectus, offering document or other pre-contractual disclosure document as well as by contacting the management company or alternative investment fund manager ("AIFM"), respectively.

Conflict of Interest Policy of Credit Suisse Asset Management (Switzerland) Ltd.

The below summary of the Conflicts Policy applicable to Credit Suisse Asset Management (Switzerland) Ltd outlines how we will manage actual and potential conflicts of interest that may arise through the provision of services to you.

Management of conflicts of interest of Credit Suisse Fund Management S.A. (hereinafter referred to as “CSFM”)

In accordance with the Luxembourg Law of 17 December 2010 relating to Undertakings for Collective Investment, as well as in accordance with Chapter III of the CSSF Regulation Nr. 10-4, implementing Directive 2009/65/EC, and Circular CSSF 18/698, as well as the Luxembourg Law of 12 July 2013 on Alternative Investment Fund Managers and Commission Delegated Regulation (EU) No 231/2013 of 19 December 2012 supplementing Directive 2011/61/EU, as may be amended from time to time, CSFM is under the legal obligation to establish, implement, and maintain an effective conflict of interest policy.

In the conduct of its business, CSFM’s policy is to identify, manage, and, where necessary, avoid any action or transaction that may pose a conflict of interest between: 

  • CSFM, including its managers, employees or any person directly or indirectly linked to CSFM by control, and the funds managed by CSFM or the investors in these funds; or
  • a fund or the investors in that fund, and another fund or the investors in that fund; or
  • a fund or the investors in that fund and another CSFM client; or
  • two CSFM clients.

CSFM strives to manage any conflicts of interest in a manner consistent with the highest standards of integrity and fair treatment. For this purpose, it has implemented procedures to ensure that any business activities potentially involving a conflict are conducted with an appropriate level of independence and that any conflicts are resolved fairly. 

In the unlikely event that a conflict of interest could not be managed by CSFM, any such non-neutralized conflicts as well as the decisions made will be disclosed appropriately.

Statement on Best Execution Principles of Credit Suisse Asset Management (Switzerland) Ltd.

This Statement on Best Execution Principles (hereafter as “Statement”) describes the approach of Credit Suisse Asset Management (Switzerland) Ltd. (hereafter as “CSAM”) when seeking to achieve Best Execution of order placements on behalf of its client portfolios, which may be either collective investment schemes or discretionary portfolio management mandates for institutional and private clients.

This Statement, including the appendices which should be read in conjunction, summarizes the standards applied by CSAM with respect to Best Execution which are regulated in the internal CSAM Best Execution Policy and guidelines (hereafter as “Policy”). It thereby provides all relevant information on CSAM order execution and order transmission as required by applicable law and by following the standards of the Markets in Financial Instruments Directive 2014/65/EU (hereafter as “MiFID II”).

For clients serviced by Credit Suisse legal entities other than CSAM, please note that there might be separate statements in place which describe the Best Execution principles of those legal entities. Please contact your local Relationship Manager for further information.

Statement on best-execution principles of Credit Suisse Fund Management S.A. (hereinafter referred to as “CSFM”)

In accordance with the Luxembourg Law of 17 December 2010 relating to Undertakings for Collective Investment, as well as in accordance with Articles 28 and 29 of the CSSF Regulation Nr. 10-4 , implementing Directive 2009/65/EC, Circular CSSF 18/698, the Luxembourg Law of 12 July 2013 on Alternative Investment Fund Managers, and Commission Delegated Regulation (EU) No 231/2013 of 19 December 2012 supplementing Directive 2011/61/EU, as may be amended from time to time, CSFM is under the legal obligation to act in the best interests of the UCITS or the Alternative Investment Funds (hereinafter referred to as “funds”) it manages when executing decisions and/or when placing orders with other entities to carry out actions on behalf of the managed funds in the context of management of their portfolios. 

In general, CSFM delegates the function of portfolio management, including the placement and execution of orders on behalf of the funds it manages, to third parties that are subject to regulatory supervision in an EU member state or, if the third party is domiciled in a non-EU country, subject to regulatory supervision that is deemed equivalent to the supervision in an EU country. 

CSFM ensures that the third parties to which these activities are delegated are subject to best-execution rules and that they have implemented related policies and procedures, including a best-execution policy. The third parties shall, in particular, take all reasonable steps to obtain the best result for the funds, taking into account price, cost, speed, likelihood of execution and settlement, order size, and nature, or any other consideration relevant to the order. 

In this context, the following criteria are relevant:

  • The objectives, investment policy, and risks specific to the funds on behalf of which the order is placed
  • The characteristics of the order
  • The characteristics of the financial instrument that is the subject of the order
  • The characteristics of the execution venues to which the order can be directed

The third parties shall monitor on a regular basis the effectiveness of their arrangements and policy for the execution of orders on behalf of the funds. The third parties must be able to demonstrate that they have executed and placed the orders on behalf of CSFM in accordance with their best-execution policy. CSFM has entered into contractual arrangements with the third parties that shall ensure the application of best-execution principles and that allow CSFM to perform appropriate due diligence and controls on the third parties. In this context, CSFM has established and implemented specifically designed policies and procedures in order to make sure that any risks of non-compliance are adequately mitigated.

The aforementioned principles do not apply where there is no choice of different execution venues.

Best Execution Publications of Credit Suisse Asset Management (Switzerland) Ltd.

This Report on the Top 5 Execution Venues and Top 5 Brokers (hereafter as “Top 5 Report”) describes the approach of Credit Suisse Asset Management (Switzerland) Ltd. (hereafter as “CSAM”, “we”, or “us”) in identifying the parties to which orders have been transmitted for execution respectively identifies the Execution Venues with whom orders have been executed on behalf of client portfolios.

This Top 5 Report is linked to the Statement on Best Execution Principles of Credit Suisse Asset Management (Switzerland) Ltd (hereafter “Statement”; available on the CSAM website) and is also linked to the Report on Best Execution Quality obtained (hereafter as “Quality Report”, also available on the CSAM website). All publications follow the recent developments and disclosure requirements of relevant law by applying the standards of the Markets in Financial Instruments Directive 2014/65/EU (hereafter “MiFID II”). More specifically, this (asset class specific) Top 5 Report refers to the obligations set out in art. 27.6 of MiFID II, art. 65.6 of the Commission Delegated Regulation (EU) 2017/565 and art. 3.1 and 3.2 of Commission Delegated Regulation (EU) 2017/576 (“RTS 28”).

This Report is intended to cover the period from 01/01/2020 to 31/12/2020. As outlined in ESMA’s Q&A on MiFID II and MiFIR investor protection topics, certain aspects of the RTS 28 requirements are tied to new provisions from MiFID II or MiFIR. Given that CSAM is not a firm directly subject to MiFID II provisions, it is not directly obliged to comply with the best execution requirements, but endeavors to do so in order to provide the best service to its clients. Thus, this Report may not include some of the detail required by RTS 28 for the information obtained when MiFID II entered into force. Where this is the case, some of the arrangements described may reflect adjustments made by CSAM in preparation for and the context of MiFID II.

For clients serviced by Credit Suisse legal entities other than CSAM, please note that there might be separate Top 5 Reports which disclose the transmission and execution details obtained of those legal entities. Please contact your relationship manager for further information.

This Report on Best Execution Quality Obtained (hereafter as “Report”) describes the approach of Credit Suisse Asset Management (Switzerland) Ltd. (hereafter as “CSAM”, “we”, or “us”) in identifying and evaluating the Execution Quality obtained based on the arrangements been setup when seeking to achieve Best Execution of order execution on behalf of client portfolios.

This Report is linked to the Statement on Best Execution Principles of Credit Suisse Asset Management (Switzerland) Ltd. (hereafter “Statement”; available on the CSAM website). Both, this Report and the Statement, highlight the CSAM approach to validating Best Execution Quality. Both publications follow the recent developments and disclosure requirements of relevant law by applying the standards of the Markets in Financial Instruments Directive 2014/65/EU (hereafter “MiFID II”). More specifically, this (asset class specific) Report on Execution Quality Obtained refers to the obligations set out in art. 27.6 of MiFID II and art. 3 of Commission Delegated Regulation (EU) 2017/576 (“RTS 28”).

This Report is intended to cover the period from 01/01/2020 to 31/12/2020. As outlined in ESMA’s Q&A on MiFID II and MiFIR investor protection topics, certain aspects of the RTS 28 requirements are tied to new provisions from MiFID II or MiFIR. Given that CSAM is not a firm directly subject to MiFID II provisions, it is not directly obliged to comply with the Best Execution requirements, but endeavors to do so in order to provide the best service to its clients. Thus, this Report may not include some of the details required by RTS 28 for the information obtained when MiFID II entered into force. Where this is the case, some of the arrangements described may reflect adjustments made by CSAM in preparation for and in the context of MiFID II.

For clients serviced by Credit Suisse legal entities other than CSAM, please note that there might be separate Best Execution Statements and Reports which describe the Best Execution Quality obtained of those legal entities. Please contact your relationship manager for further information.

Ombudsman of Credit Suisse Asset Management (Switzerland) Ltd.

If you are not entirely satisfied with the service of Credit Suisse Asset Management (Switzerland) Ltd., we would like to hear from you as soon as possible. We will aim to put matters right as soon as we can. The quickest way to address any concerns you might have is to contact your Credit Suisse Asset Management (Switzerland) Ltd. representative. They will strive to answer any questions and resolve any concern you might have. 

You can also write to us at:

Credit Suisse Asset Management (Switzerland) Ltd.
COO Office
Kalandergasse 4
8070 Zurich
Switzerland
Fax: +41 44 333 22 50

We constantly strive to resolve any concern you raise. However, if you are not satisfied with our final response, you can refer your case to the Finanzombudsstelle Schweiz.

Finanzombudsstelle Schweiz (FINOS)

Talstrasse 20
CH-8001 Zurich
Switzerland

Remuneration principles of Credit Suisse Fund Management S.A. (hereinafter referred to as “CSFM”)

In accordance with the Luxembourg Law of 17 December 2010 relating to Undertakings for Collective Investment, as well as in accordance with Articles 28 and 29 of the CSSF Regulation Nr. 10-4, implementing Directive 2009/65/EC, Circular CSSF 18/698, the Luxembourg Law of 12 July 2013 on Alternative Investment Fund Managers and Commission Delegated Regulation (EU) No 231/2013 of 19 December 2012 supplementing Directive 2011/61/EU, as may be amended from time to time, and the Guidelines on Sound Remuneration Policies under the AIFMD, CSFM applies the remuneration principles and policies of Credit Suisse Group AG (hereinafter referred to as the “Group”). In addition, CSFM has developed an Appendix to the Group Compensation Policy to specify the remuneration standards at CSFM level. 

The key objectives guiding CSFM’s remuneration approach as laid out in the Group Compensation Policy are:

  • Sound and effective risk management that does not encourage risk-taking activities
  • High conduct and ethical standards through a system of penalties and rewards
  • Teamwork and collaboration across the Group
  • Balanced distribution of profitability between shareholders and employees over the long term
  • Creation of sustainable value for the Group’s shareholders
  • Performance culture based on merit that differentiates and rewards excellent performance
  • Attraction and retention of employees who are motivated to achieve results with integrity and fairness
  • A proportion of variable compensation that is appropriate for the role and encourages appropriate behaviors and actions

The Group has a Compensation Committee that supervises compensation policies and practices, procures independent external compensation advice, recommends changes to the Compensation Policy or overall plans to the Board of Directors, and approves the compensation of Executive Board members and the Board of Directors, among other tasks.

In addition, CSFM has defined a group of employees identified as “Risk Takers” (e.g. managers in charge of the control functions – Risk Management, Compliance, Internal Audit). 

The main parameters for the remuneration may comprise some or all of the following:

  • Fixed component (such as annual salary)
  • Variable component (such as performance bonus)
  • Complementary pension scheme
  • Other additional benefits

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