Tundra has signed agreements with some of Sweden’s leading companies in finance, audit and fund administration in order to ensure a high service level and full compliance with relevant regulation.


SEB is a market leader in custody services for frontier market equity, offering access to 90 countries globally.

Fund administration and risk managementISEC

ISEC provides the Secura and Fonda platforms for securities administration (back office), reporting (middle office), daily valuation and client management.

Compliance function: FCG Risk & Compliance AB

FCG Risk & Compliance AB is a leading Nordic consultant within Law, Risk, Finance and Insurance. The company is present in Sweden, Norway and Denmark through approximately 200 consultants.

Complaints officer:

Antonia Gibson, Ph: + 46 8 551 145 70, e-mail:


PwC is a leader in auditing, accounting and advisory services, with offices in 100 cities and 3,600 employees in Sweden.

Internal audit: Lüsch & Co Revision AB

Auditor in charge is Mr. Leif Lüsch, authorised auditor since 1980 and licensed auditor in financial companies FAR.


Fortner is a specialist in accounting services for fund companies and asset managers.

Designated persons entitled to receive market soundings

Market soundings are interactions between a seller of financial instruments and one or more potential investors, prior to the announcement of a transaction, in order to gauge the interest of potential investors in a possible transaction and its pricing, size and structuring.

Market soundings could involve an initial or secondary offer of relevant securities, and are distinct from ordinary trading. They are a highly valuable tool to gauge the opinion of potential investors, enhance shareholder dialogue, ensure that deals run smoothly, and that the views of issuers, existing shareholders and potential new investors are aligned. They may be particularly beneficial when markets lack confidence or a relevant benchmark, or are volatile.

In general Tundra Fonder wishes to receive market soundings.

If Tundra Fonder does not wish to receive any future market soundings in relation to either all potential or particular types of potential transactions, this will be communicated in due course.

Tundra Fonder has, in accordance with applicable market abuse regulations (MAR), designated  CIO Mattias Martinsson to receive market soundings.

Remunernation policy

Please find a summary of Tundra’s remuneration policy and renumeration in 2017 here.

Owner policy

The company deals exclusively in unitholders’ common interest. The aim of fund management is to achieve the highest possible return, taking into account the Fund’s investment policy and risk. This, combined with the importance of being able to act independently to prevent insider situations, form the base for the company’s conduct in corporate governance issues.

The company’s CIO together with the CEO assesses whether the Company will exercise its voting rights at general meetings or participate in nominating committees. The Company has no intention to take a seat on the Board of directors. This is to be independent from the investment decisions which the Company may need to make in order to safeguard interests of unitholders. In exceptional cases, the Company may decide to deviate from the above principle, subject to the Company’s Board of Directors decision and that it is in the interest of the unitholders.

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