Download our Privacy Policy (PDF). The document explains how Always Summer processes personal data in line with the EU General Data Protection Regulation (GDPR).

Always Summer applies procedures designed to ensure that fund units are valued correctly. Any inaccuracies in the net asset value (NAV) will be handled in accordance with the guidance issued by the Swedish Investment Fund Association (Fondbolagens förening) on correction of NAV.
‍
If you are a fund unit holder and would like more information about our procedures, please contact our fund administration at operations@alwayssummer.se or +46 (0)8 701 01 00.

Fund management companies must seek the best possible result when placing orders with a third party on behalf of the funds. This obligation requires taking all reasonable steps to achieve the best possible outcome for the funds we manage, taking into account a number of factors: price, cost, speed, likelihood of execution and settlement, size and nature, and any other consideration relevant to execution.
‍
We exercise great care when selecting investments and in the ongoing monitoring of how fund assets are invested. Our portfolio managers make carefully considered and responsible decisions within the framework set by applicable law, regulations, the fund rules, our risk-control systems and the investment guidelines.

Always Summer have documented remuneration guidelines designed to (i) be consistent with and promote sound and effective risk management, and (ii) discourage excessive risk-taking.
‍
The Remuneration Policy is aligned with the Company’s business strategy, objectives, values, management of sustainability risks and long-term interests, as well as with the funds’ risk profiles and fund rules. The remuneration framework shall comply with the applicable external regulations in force at any time.
‍
The policy aims, among other things, to ensure an appropriate balance between fixed and any variable remuneration.
‍
Salaries and other terms of employment shall be set so that the Company can attract and retain competent staff. Employees shall be informed of the criteria governing their remuneration and of how their performance is assessed. The guidelines are approved by the Board of Directors and apply to all employees of the Company.

Always Summer Asset Management AB has established guidelines for the identification and management of conflicts of interest.
‍
We identify conflicts that may arise in our business — for example between the firm and its clients, or between different clients when we provide services. When assessing potential conflicts we consider circumstances such as whether the firm or its owners, beyond any agreed fees, are likely to obtain a profit or avoid a loss at a client’s expense.
‍
We have an obligation to prevent clients’ interests from being adversely affected by conflicts of interest. If the measures we put in place are not sufficient to prevent an adverse impact, we will clearly inform the client of the nature and source of the conflict before providing a service.
‍
Our guidelines are designed to prevent conflicts from arising and, where a conflict does occur, to prevent any negative effect on clients’ interests. They describe potential conflicts and the measures we take to mitigate them, including how we secure an appropriate degree of independence between different departments, units and sub-units, and how any actual conflicts are handled.
‍
On request, Always Summer will provide further information about our conflicts-of-interest guidelines.

Always Summer exercises voting rights attached to holdings solely to benefit the fund and its investors. Our proxy-voting strategy is adopted by the Board and designed in line with the AIFM rules (including the requirements of Article 37 of the EU Commission’s Delegated Regulation). The Board reviews the policy regularly, at least annually.
‍
We monitor corporate events that matter to our investors and vote only on matters relevant to the fund’s objectives and investment mandate. Typical examples include acquisitions and mergers, capital structure changes, incentive programmes, board composition and share buy-backs.
‍
Decisions on whether to exercise the fund’s vote are taken with care and documented. The Board decides on voting where appropriate; if an urgent decision is needed and the Board cannot convene, the CEO may decide and will notify the Board without delay. Our managers act within the framework of law, fund rules, risk controls and investment guidelines.
‍
We prevent and manage conflicts of interest so that the fund’s interests always come first. If measures cannot remove the risk of an adverse effect on investors, we will disclose the nature and source of the conflict before acting. All analyses, decisions and evaluations of voting outcomes are documented and retained.
‍
For a concise summary of the strategy please contact operations@alwayssummer.se.
‍
We will publish a annual record of the actions we have taken, including voting activity and related disclosures, on this page. The first report will be published in 2027.