34-38, Avenue de la Liberté
Grand Duchy of Luxembourg
T : +352 26 12 15 20
/ F : +352 26 12 15 99
Email: [email protected]
Tishman Speyer Europe S.à r.l. (Tishman Speyer)
is subject to a wide range of European and Luxembourg laws or regulations, which require notably it to have in place, keep up-to-date, implement and regularly review a number of its internal policies and procedures. Tishman Speyer is also legally required to disclose some of these policies and procedures as well as certain regulatory information to its clients and to investors of the funds it manages.
The compliance function of Tishman Speyer is in charge of ensuring compliance with these internal policies.
You will find below a list of the policies and other regulatory information that Tishman Speyer must publish and make available free of charge to investors:
Tishman Speyer is only required to disclose a summary of its remuneration policy. The purpose of the remuneration policy is to outline the principles applied by Tishman Speyer in the remuneration of its staff members who can exert a material influence on the risk profile of the funds it manages to among other things promote sound and effective risk management and avoid conflicts of interest and excessive risk-taking.
Information on Conflicts of Interest
Tishman Speyer is required to disclose under article 36 of the EU Commission Delegated Regulation 231/2013 information on notably the steps taken to identify conflicts of interest that arise in managing the funds. It also provides the steps and procedures to be followed in case a conflict of interest arises.
Tishman Speyer will publish in quarterly investors’ reports the following information:
• where organisational arrangements are made by it to identify, prevent, manage and monitor conflicts of interest are insufficient to ensure, with reasonable confidence, that risks of damage to investors’ interests will be prevented, Tishman Speyer will disclose the general nature or sources of conflicts of interest to the investors before undertaking business on their behalf, and on the appropriate policies and procedures developed in such circumstances;
• where Tishman Speyer considers that its operating conditions may involve any other material conflicts of interest, it shall disclose any such other material conflicts of interest to relevant investors of the funds managed.
Tishman Speyer is required to disclose its complaints handling policy under the Commission de Surveillance du Secteur (the CSSF
) Regulation 16-07. The complaints handling policy aims at facilitating the resolution of complaints by investors against Tishman Speyer without judicial proceedings. The complaints handling policy provides relevant information on how to make a complaint to Tishman Speyer (such as contact details information and procedure) as well as on the CSSF’s out-of-court resolution procedure in case of an unsatisfied answer.
Tishman Speyer is required to disclose its voting rights policy in respect of the assets held by the funds it manages. Tishman Speyer is committed to exercise its voting rights in the best interests of the funds managed and their investors. The voting rights policy aims at providing investors with the general guidelines that Tishman Speyer will apply in exercising its voting decisions.
Tishman Speyer is required to inform investors in the funds managed by Tishman Speyer on how their personal information is collected, used, shared and protected. The privacy notice aims at providing information on the persons subject to personal data processing, the personal information processed, the means to obtain your personal information and the use of your personal information.
Tishman Speyer is required to publish on its website sustainability-related disclosures under the EU Regulation 2019/2088. This document aims at providing you with information on the integration of sustainability risks in the investment decision-making process, the consideration of adverse sustainability impacts and other sustainability-related information.