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. Tundra Fonder is compliant with the Swedish Code of Conduct for fund management companies.


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: Advisense AB

Advisense AB is a leading europeisk consultant within Law, Risk, Finance and Insurance. The company is present in Sweden, Norway, Denmark, Finland, Germany, Lithuania and Belgium through approximately 450 consultants.

Complaints officer:

Simon Norenius, 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.


ECIT Services AB 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.

Remuneration policy

Here you will find our remuneration policy and remuneration paid in 2023.

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.



As our client, your opinion of us and our products and services is extremely valuable. If you feel that you would like to express an opinion or dissatisfaction or would like to lodge a complaint, you are always welcome to contact us. The Company has an internal Complaints Handling Policy, which we will send to you by post, at no charge, upon request. Nicoleta Lagerqvist is the Complaints Officer at Tundra Fonder AB. He can be reached by phone on + 46 8 551 145 70, or email to


You may express your opinions or lodge a complaint with us orally or in writing. (Naturally, it will help us if you do so in writing, to avoid misunderstandings.) Please send your written opinions or complaint to:

Tundra Fonder AB
Attn: Complaints Officer
Box 5216
102 45 Stockholm, Sweden.

However, you are welcome to contact anyone at the fund company to express your opinions or your complaint. Complaints will thereafter be handled by our Complaints Officer. Matters in which you have expressed a concrete demand or claim for compensation are considered complaints.


We make every effort to respond to your complaint as quickly as possible. Occasionally, a complaint may require additional time for investigation. In such cases, we will notify you when you can expect a response and we will explain the delay.


The Complaints Officer registers and follows up all complaints and regularly reports all complaints to the CEO and the board of directors. Our goal is to listen to our clients’ opinions and use them to the fullest extent to further develop and improve our products and services.


If you feel that you would like external guidance, we refer you to the Swedish Consumers’ Banking and Finance Bureau (by phone on +46 08-24 30 85 or online at and to your municipal consumer advisor (more information: or your municipality). If we reject all or part of your claim after we have processed your complaint, you may approach the Swedish National Board for Consumer Disputes (ARN) or a Swedish court of law for review.

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