MAKING THE MOST OF UCITS IV

Key Investor Information Document

Key features

5 - Charges The charges and fees payable are shown in an overview table and are broken down into three categories (entry and exit charges, ongoing charges and per- formance fee). The charges must be presented as clearly as possible to enable investors to take account of their combined impact. “Ongoing charges” are the annual charges and other payments levied on the assets of the UCITS during the previous accounting year. A new UCITS that cannot calculate its ongoing charges may provide an estimate based on the anticipated total amount of charges. 6 - Past performance The past performance of the UCITS is illustrated in the form of a bar chart co- vering the last 10 years, or a five-year period if past performance is available for fewer than five years; This takes up no more than half a side of A4. For each year for which no figure is available, the chart is blank with no informa-

tion other than the date. Only UCITS that make a clear reference to their benchmark may incorporate a diagram alongside each bar showing the fund’s past performance. In relation to mergers, only the performance of the absorbing UCITS will be retained. The following information will be provided: Whether the performance is cal- culated inclusive or exclusive of charges, the date on which the UCITS was created, the calculation currency of the UCITS, and a warning that past per- formance is not a guide to future performance. Past performance data must be updated within 35 working days of 31 December of each year. 7 - Practical information This is strictly defined by Commission Regulation 583/2010 (for example, name of the depository, address at which practical information may be requested).

Points of attention

Main questions that clients should address

• There are specific KIID formats for five categories of UCITS (UCITS with sub-funds, different share/unit classes, feeder UCITS, structured UCITS and funds of funds);

• The KIID will need to be translated into the native language of all Mem- ber States in which the UCITS is marketed;

Is the move to the KIID subject to the local supervisory authority?

• Special attention must be paid to the drafting of the KIID: The Mana- gement Company will be liable for any information that is incorrect or inconsistent with the information provided in the full prospectus, al- though it will not be liable for incomplete information;

What strategy should be adopted in order to make the switch to KIID in the case of UCITS from the same Management Company (big bang? by UCITS range?)? How can assistance be obtained when converting simplified prospectuses into KIID? Have specific problems with implementation of the KIID been identified and analysed (necessary technical resources, financial and human resources, translation requirements, terminology to be used, outsourcing of calculation, control and monitoring of the SRRI, etc.)? Are there any specific actions and/or procedures to be implemented for UCITS that are marketed internationally and more particularly in light of local requirements in some countries (e.g. Switzerland, Hong Kong, Singapore)?

• The Management Company is responsible for producing, reviewing and/or revising the KIID on an annual basis and as often as necessary;

• The Management Company must ensure that the various documents published on the same UCITS (for example sales documents, full pros- pectus, KIID) are consistent in order to avoid any conflict of interest and/ or misinterpretation by the investor; • Some Member States could take additional transposition measures in relation to the Directive, extending the KIID’s scope of application to UCIs other than coordinated UCITS (OPCIs, for example).