1. General

This Investor Information Package of Signum Varainhoito Oy compiles information that must be provided to the Client pursuant to the regulations concerning investment services. More detailed service- and product-specific information is provided in connection with the provision of the service or financial instrument in their respective terms or agreements. Signum Varainhoito Oy updates this information as necessary. Changes and updates to this information package will be published at www.signumvarainhoito.fi and shall enter into force on the date of publication. If there is a conflict between the information package and the service- and product-specific terms or agreements, the agreement or terms shall prevail.

2. Information about Signum Varainhoito Oy 

Signum Varainhoito Oy is a Finnish investment services company, licensed by the Finnish Financial Supervisory Authority in accordance with the Investment Services Act to provide the following services:

1. asset management
2. receiving and forwarding assignments
3. investment advice
4. currency services related to investment services

The company is registered in the Trade Register maintained by the Finnish Patent and Registration Office with the Business ID 3240103-6. The company's registered office is in Helsinki, and Finnish law applies to the contracts it concludes.

3. Contact Information

The headquarters of Signum Varainhoito Oy is located at: Fabianinkatu 14 B 203, 00100 Helsinki. Telephone +358 40 745 9407, email: firstname.lastname@signumvarainhoito.fi. More information: www.signumvarainhoito.fi.

4. Regulatory authority

The authority supervising Signum's investment services operations in accordance with the Act on Investment Services is the Financial Supervisory Authority, Snellmanninkatu 6, PO Box 103, 00101 Helsinki, telephone +358 9 831 51 (switchboard), for more information: www.finanssivalvonta.fi.

5. Use and storage of data

Signum Varainhoito Oy records telephone conversations, electronic communications, and other discussions with clients that may lead to transactions. Signum Varainhoito Oy uses the recordings to verify assignments, develop its customer service, for risk management purposes, and as evidence in resolving potential disputes. Competent authorities, such as the Finnish Financial Supervisory Authority, have the right to obtain copies of the recordings upon request. The client has the right to request copies of call and other recordings.

The customer due diligence questions presented to the customer are based on regulations concerning the prevention, detection, and investigation of money laundering and terrorist financing. Customer due diligence information and other personal data may be used for the prevention, detection, and investigation of money laundering and terrorist financing, as well as for bringing about the investigation of money laundering, terrorist financing, and the crime through which the property or proceeds subject to money laundering or terrorist financing were obtained.

6. Right of access to information and duty of care of the company

The customer is aware of the Company's obligation to obtain sufficient information for the reliable identification and know-your-customer processes of the customer, as well as for the prevention of money laundering and terrorist financing. The Company must also identify the customer's beneficial owner and the person acting on behalf of the customer.

If the Company, after fulfilling its duty of care or otherwise, has reason to suspect the legal origin of the property, its use for the financing of terrorism, or the misuse of inside information or other market abuse, it has a statutory duty to investigate and report, as well as any other potential ensuing duty to act. In such a case, the Company shall not be liable for any financial damage caused to the Customer as a result of these measures, provided that the Company has exercised the care that can reasonably be required of it taking the circumstances into account. The Company is bound by the confidentiality obligations set forth in Chapter 12 of the Investment Services Act.

7. Customer classification, appropriateness assessment and statement

Signum Varainhoito Oy classifies its clients as non-professional clients, professional clients, or eligible counterparties. The client classification affects the scope of investor protection as described below. 

With an acceptable counterparty refers to an entity operating in the financial markets that is authorized, regulated, or under official supervision, a state or a state-equivalent entity, or an international organization, as well as a large enterprise that gives its consent to be classified as an eligible counterparty. Entities operating in the financial markets include, for example, credit institutions, insurance companies, investment firms, management companies, as well as pension insurance companies, pension funds, and foundations. State-equivalent entities include, for example, central banks, the State Treasury, federal states and other entities managing government debt, and organizations operating in international money markets. A large enterprise refers to an enterprise that meets at least two of the following three criteria:
• Balance sheet total of at least 20 million euros
• Net sales of at least 40 million euros
• Own assets of at least 2 million euros
For a large enterprise to be classified as an eligible counterparty, its business operations and the origin of the assets to be invested must
sufficient information is available.

With a professional customer it refers to a large enterprise that is not classified as an eligible counterparty, an entity whose main business activity is investment, and another client who has the capacity to make independent investment decisions, who understands the risks associated with them, and who fulfills
at least two of the three requirements:
• Regularly execute large transactions in financial instruments
• The value of investment assets exceeds 500,000 euros
• Works or has worked in the financial sector

As a non-professional customer let us classify all those clients who are not classified as an eligible counterparty or a professional client. When providing investment advice, Signum Varainhoito must obtain from a non-professional client, for the purpose of carrying out a suitability assessment, sufficient information regarding the client's or its representative's investment experience and knowledge, as well as sufficient information regarding the client's financial situation and investment objectives, so that the Company can recommend financial instruments and services suitable for the client. The purpose of the suitability assessment is to enable Signum Varainhoito Oy to act in the best interests of the client. Therefore, it is important that the client provides up-to-date and accurate information on the form, and the Company has the right to rely on the information provided by the client. The client undertakes to notify of any material changes in their information. An order concerning each product or service is required from a non-professional client in writing or as an approved electronic confirmation before the execution of the order.

The impact of customer classification

Protection of the Investors' Compensation Fund: An eligible counterparty and a professional client are not covered by the Investor Compensation Fund. A retail client may be eligible for compensation from the Investor Compensation Fund if Signum is unable to fulfill its obligations as agreed.

Suitability assessment and target market: Signum does not assess the appropriateness of a financial instrument or investment service for an eligible counterparty, nor does it assess whether an eligible counterparty belongs to the target market of a financial instrument.

Statement on investment advice and appropriatenessSignum shall not provide a statement on the investment advice it has provided or the appropriateness of financial instruments to an eligible counterparty or professional client.

8. Investment advice

The investment advice provided by Signum Varainhoito Oy to its customers is non-independent as defined in the Investment Services Act. In practice, this means that the investment advice offered by Signum Varainhoito Oy is not based on a broad and fair analysis of various financial instruments, but is primarily limited to Signum's own products, namely two special investment funds whose portfolio management is outsourced to Signum Varainhoito Oy, and Signum has a cooperation agreement regarding the funds with GRIT Rahastoyhtiö Oy. Thus, the comparison of financial instruments offered by Signum is extremely limited, as the offering is restricted to only two funds.

Signum Varainhoito Oy collects from clients all the information it needs to understand the essential facts related to the client and on the basis of which it can reasonably ensure, taking into proper account the nature and scope of the service provided, that the recommended or executed transaction is suitable for the client.

Investment advice refers to the provision of a personalized recommendation to a client, upon the client's request or at the initiative of a representative of Signum Varainhoito Oy, regarding a financial instrument brokered by Signum, where the provision of investment advice has been preceded by an assessment of the client's individual circumstances and a suitability assessment.

Similarly, when Signum Varainhoito Oy provides a client with a personal recommendation, all necessary information is collected and a suitability assessment is conducted to ensure that the personal recommendation corresponds to the client's investment objectives and personal circumstances regarding the investment and savings period, and specifically the client's investment objectives, including the person's risk tolerance, the client's financial situation, including the person's ability to bear losses, the client's knowledge and experience, and the client's sustainability preferences. Investment advice and the provision of a personal recommendation do not include the provision of general recommendations, such as recommendations on asset class weightings or buy, sell, or hold recommendations in investment research. Furthermore, marketing does not constitute investment advice or a personal recommendation.

9. Assignment brokerage

Signum transmits subscription and redemption orders for Signum special investment funds to GRIT Fund Management Company. The client submits the subscription forms for Signum special investment funds to the company by email, mail, or as a paper version for further transmission to GRIT Fund Management Company. No separate agreement is made regarding fund investments. The client also submits the redemption order forms in writing to Signum Varainhoito Oy for further transmission to GRIT Fund Management Company. GRIT Fund Management Company Oy sends the subscription and redemption confirmations to the client. Before making the subscription decision, the client receives the fund's prospectus and key investor information document. The fund's monthly report is sent to the client by email or made available for information/reading on the company's website. In addition, the fund's annual report is sent to the client.

10. Principles of order routing

The customer can submit orders for Signum funds electronically or as a paper version to be forwarded to GRIT Rahastoyhtiö Oy. Orders can be placed once a month. The subscription date is the last Finnish banking day of each month. The subscription amount and the order must be submitted five (5) banking days before the subscription date by 23:59.

The redemption order is five (5) banking days before the redemption date at 23.59. The redemption date is the last Finnish banking day of each month. The payment for the redemption is within five (5) Finnish banking days from the publication of the value.

11. Incentives

Inducements refer to any fee, commission, or other benefit that the Company may pay or receive from a party other than the client in connection with the provision of investment and ancillary services. Examples of these include retrocessions. Fees or charges normally charged for the investment service are not considered inducements.

Signum Varainhoito Oy does not accept inducements from third parties nor pay them to third parties in connection with the provision of investment or ancillary services. However, Signum or its staff may accept minor, non-monetary benefits if they enhance the quality of the service provided to clients and their receipt does not create a conflict of interest between Signum and the client. Such benefits may include, for example, participation in seminars or training courses and materials relating to financial instruments or investment services.

12. Principles for avoiding and managing conflicts of interest

A conflict of interest situation may arise when Signum, its personnel, or another client has an interest or benefit related to the financial instrument or investment service provided that differs from the client's interest. Signum provides its clients with, among others, the following services in which conflict of interest situations may potentially arise:

• Assignment brokerage
• Investment advice
• Portfolio management

Signum has implemented measures it considers reasonable to identify and prevent conflicts of interest. Signum primarily aims to actively identify and prevent potential conflicts of interest through internal training, guidelines, and access rights, among other means. To prevent and monitor conflicts of interest, Signum's personnel are subject to internal guidelines regulating personal and related-party trading, as well as a conflict of interest policy that details the procedures to be followed in situations involving conflicts of interest. If a conflict of interest arises despite the aforementioned measures, the client will be provided with sufficient information regarding its nature and causes before the transaction is executed. The client will independently consider whether they want the transaction to be carried out despite the conflict of interest. The transaction in question may also be left unexecuted to avoid a conflict of interest, at the initiative of either Signum or the client.

13. General information on financial instruments and investment services and their related risks, customer's liability

The acquisition of financial instruments and investment services and investment activities always involve financial risk. Risks are also always associated with asset classes and financial instruments generally considered to be low-risk investments. The risk of investment activity consists of several different risks, some of which are common to all financial instruments and some of which are associated only with certain financial instruments. The risks associated with investments vary, among other things, by asset class, financial instrument, industry, and geography. The realization of the risk means that invested capital may be lost in whole or in part and the targeted return may not be achieved or may be lower than the return obtained from other financial instruments or investment services over a corresponding period.

Before making an investment decision, the customer must familiarize themselves with the terms and conditions of the financial instrument, characteristics, and the obligations arising therefrom so that they can understand the risks associated with the financial instruments and their potential impact on their financial position. The client must carefully consider the suitability of the financial instrument for its intended purpose, even under changing circumstances. When making decisions, the client must always base their decisions on their own assessment of Signum Varainhoito Oy, the investment service, the investment targets, and the risks associated with the investment decision. The investor is always solely responsible for the financial consequences of their investment decisions, actions, and orders regarding financial instruments, and is not entitled to compensation from Signum for any damages or losses, even if Signum has assessed the suitability of the investment service or financial instrument for the client. The historical volatility of an individual financial instrument—that is, fluctuations in its value—is one way to gauge risk, but it only reflects the historical fluctuations in the financial instrument’s value and does not take into account other risks associated with financial instruments that affect or may affect the instrument’s future performance. The risk of a financial instrument cannot be measured by any single metric; rather, it is always an assessment of the combined effect of various risks. The most important risks associated with asset classes, financial instruments, and investment activities in general are described below. This list is not exhaustive; other risks not specified here may be associated with investment activities or may arise in the future. The ownership and trading of foreign financial instruments may involve financial, legal, tax, political, and other unforeseeable risks—that differ from those associated with investing in Finnish financial instruments, and these risks are the sole responsibility of the client. If these risks materialize, the investor may lose all or part of the invested capital. 

Force majeure risk

Force majeure risk refers to factors independent of contracts, unforeseeable, and causing insurmountable consequences, which pose a risk to the continuity of operations and for which the contracting parties are not responsible. Examples of force majeure risks include severe natural disasters, rebellions, strikes, and states of war, and the damages resulting from them. The materialization of force majeure risks may significantly affect the prices of securities or the possibilities to trade in securities, and the investor may incur losses. As a result, the materialization of force majeure risks may also affect the execution schedule of trades.

Market risk

Market risk refers to the risk caused by fluctuations in market prices, which can lead to receiving a lower price for an investment when selling it on the market than its purchase price. In this case, capital losses may be realized for the investor. Market risk is generally measured by volatility. Volatility refers to the fluctuation in the value of a financial instrument. As the volatility of an investment increases, the possibility of a loss or a profit also increases, because there can be a significant difference between the purchase and selling prices.

Return risk

Return risk refers to the possibility that the return on an investment will be lower than the return on other investments or lower than what the investor expected.

Korkoriski

Interest rate risk is caused by changes in interest rates. Interest rate risk typically affects the value of bonds more directly than the value of other financial instruments. Interest rate risk means that the relative value of a financial instrument decreases as a result of rising interest rates. When interest rates rise, bond prices fall, and vice versa. This is based on the fact that when interest rates rise, the opportunity cost associated with owning bonds increases, as investors can realize higher returns by moving to other products that reflect the rise in interest rates. Floating-rate and fixed-rate financial instruments involve other interest-rate-related risks as well. The interest income of floating-rate financial instruments cannot be predicted with certainty.

Commodity risk

Commodity risk means the risk arising from fluctuations in commodity prices. Commodity prices can vary significantly if natural disasters or accidents affect the supply or production of commodities. The price of a commodity can also be affected by a state of war or conflict, which weakens the supply and production of the commodity. If the interest and/or redemption price payable on a product is determined based on the price of a commodity, a change in the commodity price may reduce the interest and/or redemption price payable on the product.

Cost risk

Cost risk refers to the risk arising from the costs of a financial instrument reducing the accumulated return. The complex structure of a financial instrument can mean higher costs, as the investor always has to pay for the features included in the product. Fees and charges are usually built into the product structures and therefore may not be easily noticeable. All costs reduce the return on the financial instrument.

Regulatory risk

All investments may be subject to regulatory risks due to changes in legislation or its interpretation. Such a risk may arise from political, economic, and other factors and cannot be foreseen. Therefore, the risk is greater in emerging markets, but it always exists regardless of the market.

Issuer risk

Issuer risk refers to the risk that the party responsible for repaying the capital and/or paying the return on an investment, having issued the financial instrument, is unable to meet its obligations due to, for example, bankruptcy. Issuer risk is closely related to credit risk. If issuer risk materializes, the investor may lose all or part of the invested capital. The magnitude of issuer risk is measured using credit ratings, among other things. The better the credit rating, the lower the issuer risk can generally be considered to be at the time of evaluation.

Liquidity or secondary market risk

Liquidity risk means that buying or selling a financial instrument may be difficult at a given time due to a lack of buyers or sellers in the market. The liquidity of a financial instrument is directly affected by its supply and demand, and indirectly by other factors such as market disruptions (for example, a trading outage) or infrastructure problems, such as shortcomings or disruptions in the settlement process for financial instrument transactions.

Credit or counterparty risk

Credit risk is the risk of loss arising from a financial market participant being unable to meet its obligations. Obligations may include, for example, the obligation to return deposit funds to a depositor, pay a debt, honor a guarantee, perform in accordance with an agreement, or fulfill another contractual obligation.

Insolvency risk

Insolvency risk refers to the risk of insolvency or default by a trading counterparty or securities broker, which may lead to the liquidation or closing of financial instrument positions without the client's consent, or to the failure to return the value of the investment to the client.

Legal risk

Legal risk means that the counterparty may not comply with laws or regulations, or there may be deficiencies in the information or agreements between the parties.

Operational risk

In the investment market, service providers offering financial instruments are exposed to operational risks that may arise, for example, from external factors (such as fire, terrorism), technology, and deficiencies in the functioning of personnel, the organization, or internal processes, which lead to damage or losses or affect the investor's operating environment by making operations more difficult. Operational risks may also include potential personnel and organizational changes.

Solvency risk

Settlement risk refers to a situation where a counterparty in a securities transaction is unable to fulfill its obligations, even though the other party has met its own contractual obligations. This may cause losses to the investor. Settlement risk can be involved particularly in the trading of financial instruments in emerging markets, where payment and the delivery of the financial instrument take place separately from each other.

Systemic risk

Systemic risk refers to the risk associated with the entire financial market and its structures. Examples of these include the knock-on effects caused by the insolvency of a single operator on the entire financial sector, the exposure of all or most financial sector operators to the same risk, the general risk caused by the compounding of risks, and the collapse of a specific market or the entire financial system.

Industry and geographical risk

Industry risk means that an unexpected event affecting an industry impacts the performance of the entire industry and the financial instrument related to it. Geographical risk, on the other hand, refers to the risk where the aforementioned unexpected event concerns a specific geographical area.

Currency risk

From the perspective of an investor making investments in euros, currency risk is inherent in all financial instruments whose value depends on a currency other than the euro. In this case, the value of the financial instrument is affected not only by the value of the financial instrument itself, but also by the value of the instrument's currency relative to the euro.

Tax risk

Taxation is national in scope and generally involves political and economic objectives. Tax rules and their implementation change from time to time, and changes may lead to an immediately or indirectly unfavorable outcome for the investor. Changes to taxation may also be made without prior notice. Investments may also involve complex investor-specific tax consequences.

Leverage risk

The leverage effect risk refers to the risk caused by the multiplication of fluctuations in the value of a financial instrument due to the use of leverage. The concept of leverage is used to describe methods or strategies that multiply potential gains or losses. Examples of these include borrowing funds or using products such as derivatives. Leverage is typically used in financial instruments to pursue higher returns, but leverage can also easily multiply losses.