Information Processing, Possible Conflicts of Interest and Customer Assets.

(2015-10-29)

Smedvig Asset Allocation AS acts as the asset management company for several companies within the Smedvig Group. Our biggest customer is Smedvig Funds plc, a Qualifying Investor Alternative Investment Fund, established in Ireland, and has been authorised by the Financial Regulator (the Central Bank of Ireland) under Part XIII of the Companies Act 2014.

The company has internal guidelines for handling potential conflicts of interest, cf. §9-24 of the Norwegian Securities Services Act. Briefly, it is worth mentioning that the guidelines include limitation on the information that may be shared with other companies in the Smedvig Group. All decisions are made by the company without interference from other companies in the Smedvig Group. A more detailed description of the guidelines regarding conflicts of interest is available from the company upon request.

Assets managed on behalf of Smedvig Funds plc are safeguarded by the fund’s depository bank in Ireland under the continuous supervision of the fund’s trustee. Smedvig Asset Allocation AS has no access to the assets under management and is not in control of any of the assets.

For active management customers (other than Smedvig Funds plc) assets are allocated to various sub-funds of Smedvig Funds plc. Bank accounts are controlled by the customers themselves. Smedvig Asset Allocation AS has no access to the assets under management and is not in control of any of the assets.