In implementing Directive 2017/828/EU, asset managers must, in accordance with Liechtenstein law (Art. 367h of the Persons and Companies Act – "PGR"), either (§1) develop an engagement policy and publish it on their website, and (§2) publicly report on its implementation, or (§3) provide a clear and reasoned explanation as to why they do not comply with one or more of these requirements.

Reuss Private Access AG (hereinafter referred to as the “Company”) qualifies as an “asset manager” within the meaning of Article 367a no. 3 of the Liechtenstein Persons and Companies Act (PGR) and is therefore required to describe its engagement policy in accordance with Article 367h PGR.

The Company does not exercise shareholder rights within the meaning of Article 367h paragraph 1 items 1 and 4 PGR that are based on active engagement in companies in which it has invested under discretionary portfolio management mandates. In particular, the Company does not exercise any rights related to the general meetings of public limited companies. The right to dividends and subscription rights is exercised in consultation with the clients.

• The monitoring of key matters relating to companies, as defined in Article 367h paragraph 1 item 2 PGR, is carried out by reviewing the legally mandated reporting of such companies in financial statements and ad hoc disclosures.
• No exchange of views takes place with the corporate bodies or stakeholders of the companies, as referred to in Article 367h paragraph 1 item 3 PGR.
• There is no collaboration with other shareholders within the meaning of Article 367h paragraph 1 items 5 and 6 PGR.
• In the event of conflicts of interest within the meaning of Article 367h paragraph 1 item 7 PGR, disclosure is made to the affected parties in accordance with legal requirements, and the further course of action is clarified with them.
• An annual publication on the implementation of the engagement policy, as required under Article 367h paragraph 2 PGR, is not provided, as no such exercise of rights takes place.
• No publication of voting behavior is made within the meaning of Article 367h paragraph 1 item 3 PGR, as no participation in voting takes place.

The Company is committed to good corporate governance and to market- and legally-compliant incentivisation of management. We are open to dialogue on these matters with interested investors, while ensuring confidentiality. We regularly review our engagement policy and update it where appropriate.

As of 01.02.2024

Disclaimer: This English version is a non-binding translation of the original German text. It is provided for convenience only. In the event of any discrepancies or legal interpretation, only the German version shall be legally binding and authoritative.