Swisscanto Asset Management International S.A. has issued instructions which set out the criteria for determining, and the principles for dealing with, conflicts of interest.

These instructions apply to all Swisscanto Asset Management International S.A. employees who could become directly or indirectly involved in one of the following conflicts of interest when rendering services and performing their work:

If Swisscanto Asset Management International S.A. as an individual enterprise, or as part of the reciprocal relationships with other Swisscanto Group companies and Zürcher Kantonalbank and their employees

• makes a financial gain or avoids a financial loss which is to the detriment of investors.
• has an interest in the outcome of a service rendered for the fund or investor, or in a transaction executed for the fund or investor, which is contrary to the interests of the fund/investor in this outcome.
• has a financial or other incentive to place the interests of one or more investors before the interests of one or more other investors or before those of the fund. (Equal treatment)
• pursues the same commercial activities as the investor.
• receives a benefit, in addition to the customary commission or fee, in the form of money, goods or services, now or in future, from a person other than the investor, in relation to a service rendered for the investor/fund. 

In special instructions Swisscanto Asset Management International S.A. has in particular regulated employees' trading for their own account and issued a market code of conduct regarding handling of and action to be taken in connection with conflicts of interest.