Important information
Key documents
Below are the current versions of Meriti Capital's general terms and conditions and current price list. If you are looking for the terms and conditions of any of our services that are not listed below, please contact us.
Responsible investment
The Board of Directors of Meriti Capital AB has adopted a Responsible Investment Policy - Sustainability Risk Integration.
Meriti Capital shall always act with the aim of achieving the best possible return for the funds' unit holders/investors, taking into account the funds'/portfolios' objectives and investment restrictions.
The work on responsible investment and corporate governance aims to contribute to this goal and, over time, to sustainable value creation based on financial, environmental and social values - for the benefit of customers, society and the environment.
Read our policy here.
Supervision and licensing
Meriti Capital AB, org nr 556064-5151, är ett svenskt värdepappersbolag som står under Finansinspektionens tillsyn. Mer information om våra tillstånd från Finansinspektionen hittar du här.
- 2025-10-03 Diskretionär portföljförvaltning betr fin instr
Diskretionär portföljförvaltning beträffande finansiella instrument, enligt 2 kap. 1 § 4 p. lagen [2007:528] om värdepappersmarknaden - 2025-10-03 Investeringsrådgivning till kund betr fin instr
Investeringsrådgivning till kund beträffande finansiella instrument, enligt 2 kap. 1 § 5 p. lagen [2007:528] om värdepappersmarknaden - 2016-09-22 Annan sidoverksamhet
Annan sidoverksamhet, enligt 2 kap. 3 § första stycket lagen [2007:528] om värdepappersmarknaden - 2007-11-01 Annan sidoverksamhet
Annan sidoverksamhet, enligt 2 kap. 3 § första stycket lagen [2007:528] om värdepappersmarknaden - 2007-11-01 Mottagande o vidarebefordran order betr fin instr
Mottagande och vidarebefordran av order beträffande finansiella instrument, enligt 2 kap. 1 § 1 p. lagen [2007:528] om värdepappersmarknaden - 2007-11-01 Utförande order betr fin instr på kunders uppdrag
Utförande av order beträffande finansiella instrument på kunders uppdrag, enligt 2 kap. 1 § 2 p. lagen [2007:528] om värdepappersmarknaden - 2007-11-01 Förvara fin instr o ta emot medel m redovisnskyld
Förvara finansiella instrument och ta emot medel med redovisningsskyldighet, enligt 2 kap. 2 § 1 p. lagen [2007:528] om värdepappersmarknaden
If you would like more information about our licenses and how Finansinspektionen works with supervision, please visit Finansinspektionen's website, contact them on telephone number 08-408 980 00 or write to Finansinspektionen, Box 7821, 103 97 Stockholm.
If you would like more information about our licenses and how Finansinspektionen works with supervision, please visit Finansinspektionen's website, contact them on telephone number 08-408 980 00 or write to Finansinspektionen, Box 7821, 103 97 Stockholm.
Organization and governance
Meriti Capital AB, (hereinafter referred to as the "Company" or "Meriti Capital"), is a Swedish investment firm under the supervision of the Swedish Financial Supervisory Authority.
The company applies an internal regulatory framework that is decided at various levels. The framework clarifies the division of responsibilities, assignments for functions and employees and provides guidance on how employees should act in accordance with Meriti Capital's fundamental values. The internal regulatory framework consists of policies decided by the Board of Directors and instructions decided by the CEO.
The purpose of having documented governance documents is to achieve good internal governance and control, i.e. a process through which the board and management can obtain reasonable assurance that the company's objectives can be achieved.
The Board of Directors is ultimately responsible for the organization and management of the Company's affairs. The Board sets the strategies and objectives for the business and monitors their achievement, including ultimate responsibility for ensuring that the Company has a well-functioning risk mitigation system and an appropriate organization to manage the risks to which the business is exposed.
The CEO, in turn, is responsible for the day-to-day management of the company's affairs in accordance with the Board's guidelines and instructions.
Risk scale
Fund/portfolio risks are graded on a seven-point scale, with 1 being the lowest risk and 7 the highest risk. Category 1 does not mean that the fund/portfolio is risk-free.
Market risk is measured as annualized volatility, calculated as VaR with a 97.5% confidence interval over a 5-year period. The calculation of the risk indicator is common to all EU Member States.
|
MRM class |
VaR equivalent volatility |
|
1 |
< 0,5% |
|
2 |
≥ 0,5% och < 5,0% |
|
3 |
≥ 5,0% och < 12% |
|
4 |
≥ 12% och < 20% |
|
5 |
≥ 20% och < 30% |
|
6 |
≥ 30% och < 80% |
|
7 |
≥ 80% |
The (annualized) VaR equivalent volatility determines the MRM class of the fund and is calculated on daily logarithmic returns with 5 years of history. If no history is available, a relevant market index can be used, for example.
If 5 years of data are not available, a shorter period can be used (but at least 2 years)
Klagomål
Meriti Capital AB, (nedan kallat ”Bolaget” eller ”Meriti Capital”), är ett svenskt värdepappersbolag som står under Finansinspektionens tillsyn
If you have a specific complaint about the way we have handled a financial service, you can make a complaint. We want the complaint handling process to be efficient and effective, but also in line with the applicable rules.
Complaints will be dealt with in the first instance by the Complaints Officer. If a complaint is received by someone other than the Complaints Officer, the latter shall be informed promptly.
The Complaints Officer will investigate the complaint, for example by seeking the views of advisers or other relevant staff and by asking the customer any additional questions.
The complaint handler informs the customer of the outcome of the investigation. The customer is given an explanation of the outcome and information about help that can be obtained from, for example, consumer organizations.
If no reply can be given within fourteen (14) days, the complainant shall be informed within this time of the progress of the procedure.
Download a complaint form (PDF) here
Either send the form to klagomal@meriticapital.se or describe your case directly in an email.
This is the address if you prefer to post the form:
Meriti Capital AB
Box 5390
402 28 Göteborg
Whistleblowing
Investment firms must provide reporting systems for anyone wishing to report suspected breaches of provisions applicable to their activities. The same applies to measures against money laundering and terrorist financing.
The aim is to enable whistleblowers to report serious incidents without fear of reprisals.
Employees, associated agents, contractors and clients can report wrongdoing and breaches of rules.
Reporting system
Employees have the right to report violations of internal and external rules or suspicions of such violations without retaliation.
Reporting is done to the Chairman of the Board by email: visselblasare@meriticapital.se
The identity of the reporter or suspect or any information contained in a report must not be disclosed without authorization. The fact that the person appointed to investigate the report has access to the information does not constitute unauthorized disclosure.
Principles of shareholder engagement
for Meriti Capital AB, (hereinafter referred to as the "Company" or "Meriti Capital"), is a Swedish investment firm under the supervision of the Swedish Financial Supervisory Authority. The guidelines below, regarding the Company's principles for shareholder engagement, shall be updated and adopted at least annually by the Company and published on the Company's website.
1 Introduction
The Company is obliged to adopt shareholder engagement principles for shares included in the Company's portfolio management and issued by an EEA-based company listed on a regulated market ("investee companies").1 Shares listed on other marketplaces are not covered. The principles must show how the investment firm integrates shareholder engagement into its investment strategy. The company must also report annually on its shareholder engagement.
Portfolio management means that a client enters into an agreement for the management of financial instruments where the management is designed on the basis of a suitability assessment carried out by the Company's advisors. The Company handles the day-to-day investment decisions without the client's involvement in accordance with established frameworks and represents the client in the management of instruments included in the portfolio. The client owns the custody account covered by the management but cannot dispose of the capital without the Company's involvement.
The Company mainly provides portfolio management services in respect of investment funds where the Company has limited ability to influence the underlying investments. The principles for shareholder engagement are therefore applicable to the part of the management that relates to individual shares. Equity portfolio management is mainly provided through standardized mandates but also through tailor-made mandates with a higher degree of customization according to a client's needs and preferences. Portfolio management can be provided to clients with their own principles of ownership engagement and in those cases the management is adapted in accordance with those principles.
2 The principles of investment
2.1 Investment strategy
The Company's equity portfolio management is carried out through investments in a number of model portfolios. The Company's holding does not normally exceed 1% of the market value of the investee. The purpose of portfolio management and what thus governs the choice of shares is to create a long-term, good risk-adjusted return.
The selection of stocks is based on a screening process of a large number of companies. The process consists of a fundamental and a technical analysis. The analysis is based on information from representatives of the investment objects, publicly published information, internal analytical work and analyses from external parties. When selecting investment objects, the Company focuses in particular on whether the investment objects have a proven and sustainable business model, a credible strategy, clear growth/profitability potential and a strong or growing market position. The company also takes into account the nature of the investee's sustainability work and the responsibility the investee takes in social and environmental issues related to the investee's operations. The company has adopted guidelines for sustainability and responsible investment.
2.2 Monitoring and involvement in investment projects
The Company continuously monitors the investees to obtain information regarding the investees' financial position, potential performance and risks. Information regarding investees is obtained through public reports, internal and external analysis and through contact with investees. Contact with investees may be made directly with their representatives or through seminars organized by the investees.
In the context of portfolio management, the Company does not exercise voting rights or other rights attached to the shares. Nor does the Company cooperate with other shareholders of the investee companies or engage in any other form of communication with stakeholders of the investee companies other than to obtain information about the investee companies. Any decision to participate in share issues, takeover bids and the like is taken by the Company without the client's involvement, as are other management measures relating to the capital.
2.3 Conflicts of interest
The Company has established and implemented a policy for the identification and management of conflicts of interest.
3 Annual report on shareholder engagement
Pursuant to Chapter 8, Section 20 b of the Act, the Company shall report its voting behavior in the portfolio companies, an explanation of the most important votes, information on the matters on which the Company has used the advice or voting recommendations of a proxy advisor and an account of how the Company has voted.
In light of the fact that the Company never participates in voting, the Company chooses not to publish a statement of its shareholder engagement, which is in accordance with the exemption in Chapter 8, Section 20 c of the Swedish Companies Act.
Conflicts of interest
Meriti Capital AB, ("the Company" or "Meriti Capital"), is a Swedish investment firm under the supervision of the Swedish Financial Supervisory Authority.
We have a duty to conduct our business in the best interests of our clients. One obstacle to achieving this is conflicts of interest, whereby decisions and actions are influenced by interests other than the best interests of our clients. This is why we work to identify and manage conflicts of interest.
Responsibility for management
The CEO is responsible for the implementation of internal rules and reviews any situation that may constitute a conflict of interest and ensures that no party is unduly favored.
Employees must inform their manager of situations where potential conflicts of interest have been identified.
The Company's Board of Directors manages at each Board meeting any material conflicts of interest that may arise, both in the business and as a result of contractual agreements.
Process for managing conflicts of interest
The Company has an administrative process for managing conflicts of interest:
- All employees and relevant persons have a responsibility to identify potential conflicts of interest in the context of their work and field of activity.
- The Company maintains a register of identified potential conflicts of interest. Changes to the register are presented to the Board at least once a year.
Reported conflict of interest situations are investigated and must be addressed:
- How the conflict of interest can be appropriately prevented or managed (or if no management is needed) so that customers are not adversely affected.
- If the conflict of interest has resulted in damage to the customer.
The board should assess whether the CEO's management and decisions are sufficient to ensure that the potential conflict of interest does not cause damage.
Conflict of interest training
Staff are trained on our policies and on the potential conflicts of interest that have been identified and how to mitigate them.
One part consists of clarifying the importance of identifying the conflicts and that each employee is obliged to report the occurrence to the management and the compliance function for management.
Customer information
If you are a customer, or if you are considering becoming a customer, please contact us and we will review the register of potential conflicts of interest and how we manage them to reduce any negative impact on you.
The register contains information similar to that in the table below but also includes measures that we take to reduce any negative impact on you.
| Parties | Example of a potential conflict of interest |
| A customer has conflicting interests with the Company |
A customer wants good service and low fees while the Company wants to offer low service and charge high fees to maximize profits The customer can only communicate in Swedish but the Company has outsourced customer service via telephone to a supplier who only speaks English because this supplier gave the lowest quote |
| A customer has conflicting interests compared to a Relevant Person | A client wants access to emergency investment advice in the event of a stock market crash, even though the investment advisor is on weekend leave |
| A client has conflicting interests with a related person of the Company or a related person of a Relevant Person | A customer operates in a different industry in the same market as an owner of the Company and the owner uses the dividends from the Company to subsidize the other business |
| One customer has conflicting interests compared to other customers | A block order placed on behalf of several customers does not give full allocation |
Managing conflicts of interest
Conflicts identified should be addressed with reasonable measures to eliminate the harm they may cause. We do not need to take measures that would make it impossible to carry out the activity or that would be financially too burdensome to take, as such measures are unreasonable.
Where the reasonable steps taken are not sufficient to eliminate the potential conflict of interest completely, the client who may be prejudiced by the conflict of interest shall be informed of the existence of the potential conflict of interest and the steps taken to manage it. The purpose is to enable the client to make an informed decision as to whether the client wishes to remain a client of the Company or whether there are other investment service providers that better suit the client's needs, requirements and preferences.
The information on the remaining potential conflicts of interest that have not been fully eliminated shall be set out in an annex to the engagement letter concluded by the client.
Remuneration policy
Meriti Capital AB, (hereinafter referred to as the "Company" or "Meriti Capital"), is a Swedish investment firm under the supervision of the Swedish Financial Supervisory Authority.
Investment firms should measure, manage, report and control the risks that remuneration systems may entail. Meriti Capital's remuneration policy applies to all remuneration from the Company and applies to all employees. Remuneration refers to salary, other remuneration such as variable remuneration or other compensation paid to a person within the employment relationship. The Company shall comply with the policy, which is summarized below, even when previous employment contracts are terminated.
The Company's remuneration system shall promote effective risk management and discourage excessive risk-taking. The remuneration system shall encourage a long-term perspective and stability in the Company's operations. The Company shall always maintain a balance between fixed and variable remuneration. The variable remuneration shall therefore be reasonable in relation to the Company's paid fixed remuneration and shall never be so large that it risks eroding the Company's capital base or its ability to generate a positive result in the long term.
The remuneration system and the possibility of receiving variable remuneration must be adapted to the risks inherent in the business. This is done by
- the assessment of employee performance and achievements is also linked to non-financial factors, such as employee accountability, safeguarding customer interests, customer satisfaction, risk-taking, consideration of sustainability criteria and compliance with external and internal rules,
- results on which compensation is based are risk-adjusted where possible
The company has three different forms of employee benefits.
- Fixed remuneration,
- Variable remuneration based on performance against set criteria,
- Gratuity (awarded by the Company in arrears without any commitment to the employee)
Decisions on fixed salaries shall be based on an assessment of the tasks performed in terms of difficulty and results, interest in development, independence and initiative, ability to take responsibility, ability to cooperate and ability to contribute to a good working environment.
The setting of salaries shall take into account the influence of the market on salary levels. There shall be no discriminatory or other unjustified differences in pay between employees. Salary reviews shall normally take place at the regular review date set by the CEO.
The outcome of variable remuneration shall be based on the employee's performance in relation to pre-communicated criteria, except for bonuses. Assessment of performance is based on criteria such as quality and quantity of delivery under the employee's area of responsibility, accountability, consideration of sustainability criteria, compliance and teamwork. The assessment shall also be made in relation to the company's performance and include an assessment of the achievement of business and other objectives for the whole business.
The criteria aim to promote conduct that is in line with the interests of customers as well as the Company, sound and effective risk management, good regulatory compliance and counteract excessive risk-taking. When assessing performance, account should be taken of the fact that the performance is sustainable in the long term, i.e. over the last three-year period. In cases where an employee has been employed for a shorter period, this should be taken into account in the evaluation, i.e. some caution should be taken into account in the assessment.
The same criteria for variable remuneration apply regardless of the type. The types of variable remuneration that are relevant for the Company are:
- General variable remuneration
- gratuity
- Severance payments
All employees who are eligible to receive variable remuneration shall be informed of the criteria governing such remuneration and of how their performance is assessed. The remuneration policy and description of the remuneration scheme shall be available to all employees.
Total variable remuneration shall not exceed 100% of the annual fixed remuneration of an employee. If the employee has not met the qualitative requirements, in particular with regard to the sustainability criteria, the variable remuneration may not be paid at all.
Based on the Company's employment conditions and salary structure, there is no employee whose variable remuneration must be withheld in any part for regulatory reasons. However, the Company may, from time to time, choose to withhold variable remuneration for a certain period of time in order to encourage healthy risk-taking and long-term thinking.
Exceptions to the above restriction may be decided by the Board of Directors and shall be considered on a case-by-case basis. For staff who have a significant impact on the risk profile of the company, exceptions cannot be made. The final decision on the outcome shall be decided by the Board of Directors of the Company based on the proposal of the CEO.
The Board of Directors has delegated to the CEO to prepare proposals for the allocation of variable remuneration to the Company's employees. This shall include proposals on:
- Total variable remuneration in relation to Company performance and total fixed remuneration
- Variable remuneration allocated to each employee based on the Company's remuneration system
When assessing the amount of variable remuneration, the CEO shall take into account:
- The company's overall performance for the measurement period,
- The company's capital situation,
- The employee's business unit's performance and
- The employee's individual performance based on the criteria established for the Company's remuneration scheme
Guaranteed variable remuneration may only be paid in connection with new employment and may then only cover a single year. Decisions on guaranteed variable remuneration shall be taken by the Board of Directors.
Variable remuneration is normally paid in cash, but the Board of Directors may also decide that payment shall be made through a combination of cash and financial instruments.
Variable remuneration is not pensionable.
The Company shall have a control function, normally the compliance or internal audit function, review annually whether the Company's remuneration system complies with the remuneration policy. The function shall report the results of the review no later than three months after the publication of the Company's annual report.
The Company shall ensure that employees in the reviewing control functions are independent of the business areas they oversee and have appropriate authority and resources to monitor and control the risks associated with the Company's remuneration schemes.
A statement of the Company's remuneration shall be published in connection with the adoption of the annual report. The statement shall be published as an appendix to the annual report and on the Company's website. If the statement is not included in or appended to the annual report, the Company shall state in the annual report where the information is published. The statement shall be available for at least one year from the date of publication.
The Company shall, at least once a year, provide relevant, clear and comprehensible information on the Company's remuneration in a form that does not risk disclosing the financial circumstances of individuals. The Board of Directors is responsible for the publication of the information.
Privacy policy
Meriti Capital AB, (hereinafter referred to as the "Company" or "Meriti Capital"), is a Swedish investment firm under the supervision of the Swedish Financial Supervisory Authority.
We care about your privacy and are committed to maintaining a high level of data protection. The short version of Meriti Capital's privacy policy below describes how your personal data is collected and used. It also explains what rights you have if your personal data has been recorded. If you want to know more, please contact us.
What is personal data and processing of personal data
Personal data is any kind of information that can be directly or indirectly attributed to a living natural person. Encrypted data and various electronic identities (such as IP numbers) are personal data if they can be linked to natural persons.
Processing of personal data is anything that happens to personal data. Examples of common processing operations are collection, recording, organization, storage, processing, transfer and erasure.
The annex sets out how the Company processes personal data.
Who is responsible for the personal data collected
Meriti Capital AB, org.nr 556064-5151, Sten Sturegatan 42, 412 52 Göteborg, är personuppgiftsansvarig för företagets behandling av personuppgifter.
Where personal data is collected from
In addition to the data provided by the data subject, or collected based on the use of the Company's services, contracting and possible purchases, personal data may also be collected from other parties, such as
- Address data from public registers,
- Information required for customer due diligence under anti-money laundering rules
- Other data from public sources, such as social media, information services or rating agencies
- The company's own assessments and recommendations in connection with the performance of investment services
Sharing personal data with other parties
We are cautious about sharing personal data with other parties, but sometimes it is necessary for the efficient and correct performance of our activities.
Where necessary to provide investment services, personal data is shared with companies that are 'data processors' of the Company. They process the information on our behalf and according to our instructions. The Company has data processors who perform:
- Money laundering control (obtaining customer due diligence at the start of a business relationship)
- Marketing (print and distribution, social media, media agencies or advertising agencies),
- IT services (companies that handle the necessary operation, technical support and maintenance of our IT solutions such as advisory support for investment advice), and
- SPAR and Bisnode
If we think it is useful for you, we may also share your personal data with other companies within the same group, for example to provide you with insurance advice. In this case, however, the insurance intermediary (the company) becomes the controller of your personal data once it has received the information.
All processors are checked to ensure that they can provide sufficient guarantees regarding the security and confidentiality of personal data.
Your personal data is also shared with certain companies that are independent data controllers, which means that it is not the Company that controls how the information provided to the company is to be processed and then that company's privacy policy and personal data management applies instead.
Where is the personal data processed
The company's own IT systems are located within the EU/EEA. However, for system support and maintenance, it may be necessary to transfer the information to a country outside the EU/EEA, e.g. if the personal data is shared with a data processor who, either itself or through a subcontractor, is established or stores information in a country outside the EU/EEA. In these cases, the processor may only access the information that is relevant for the purpose
Regardless of the country in which the personal data is processed, all reasonable legal, technical and organizational measures are taken to ensure that the level of protection is the same as in the EU/EEA.
How long is personal data stored
Personal data is not kept longer than necessary for the respective purpose.
What rights do you have as a data subject
Right of access (so-called register extracts).
You have the right to access your data in the form of a register extract. Upon request, we will ask for additional information to ensure effective processing and to ensure that the information is provided to you. This often means either handing over the information to you in person or sending it to your registered address.
Right to rectification
If the personal data we have registered about you is inaccurate or incomplete, you can request a correction or completion.
Right to erasure
It is possible to request deletion of your personal data if:
- the data are no longer necessary for the purposes for which they were collected or processed
- There are objections to a balancing of interests, based on an assessment of the Company's legitimate interest and the data subject's grounds for objection,
- Personal data has been used for direct marketing purposes that you do not want,
- Personal data is processed unlawfully,
- the personal data must be deleted to comply with a legal obligation, or
- Personal data has been collected on a child (under 13 years old).
The Company may refuse your request for erasure if there are legal obligations that prevent erasure. These obligations come from accounting and tax legislation, banking and money laundering legislation, but also from consumer rights legislation. It may also be the case that the processing is necessary for the purposes of, for example, a dispute or court proceedings. If it is not possible to comply with a request for erasure, the personal data will be blocked from use other than for the purpose preventing the requested erasure.
Right to restriction
You have the right to request that the processing of your personal data be restricted. This applies in particular if the personal data are indicated to be inaccurate and in such cases refers to the time needed to verify whether it is correct.
If we no longer need the personal data, but you do so in order to pursue legal proceedings or similar, you can request restricted processing of the data. The personal data will then not be deleted.
It is also possible to request restriction of processing during the period of investigation of the balancing of interests.
Right to object to certain types of processing
There is always the possibility to opt out of direct marketing and to object to any processing of personal data based on a balance of interests.
Right to data portability
If the right to process personal data is based on either consent or the performance of a contract, it is possible to request that the data you have provided to us be transferred to another controller (so-called data portability). However, the right to transfer does not apply to the data we have created ourselves or to data to which you already have access.
Management of social security numbers
Personal data are processed only when justified by the purpose, necessary for secure identification or if there is any other clear and justified reason.
Use of cookies
A cookie is a text file consisting of letters and numbers sent from web servers and stored in the browser. The following cookies may be used on the website:
- Session cookies (a temporary cookie that expires when the browser or device is turned off),
- Persistent cookies (cookies that remain on your computer until they are deleted or expire),
- First-party cookies (cookies set by visited websites),
- Third-party cookies (cookies set by a third-party website, such as Google Analytics), and
- Similar technologies (technologies that store information in the browser or device used in a way similar to cookies).
The cookies used normally improve the services offered. Some of the services also need cookies to function properly. More information on cookies can be found on the website.
Browsers or devices provide the possibility to change the settings for the use and scope of cookies to better suit the data subject's preferences. The website of the National Post and Telecom Agency, www.pts.se, provides more information on the different types of cookies and settings to manage them.
How personal data is protected
IT systems are used to protect the confidentiality, integrity and availability of personal data. Specific security measures have been put in place to protect your personal data against unlawful or unauthorized processing (such as unauthorized access, loss, destruction or damage). Only persons who need to process the personal data in order to fulfill the purpose for which it was collected have access to it.
What does it mean that the Privacy Shield Authority is a supervisory authority
The Swedish Data Protection Authority (formerly the Swedish Data Protection Authority) is responsible for monitoring the application of the legislation, and anyone who believes that a company is handling personal data incorrectly can lodge a complaint with the Authority. Read more at www.imy.se
Contact for personal data
Contact the Company's Data Protection Officer by e-mail at dataskydd@meriticapital.se
Annex - List of personal data processed
In the context of advice, data about the client is processed. This is to enable the adviser to provide the recommendation required by law. The personal data processed are
- Name, social security number, contact details including email address
- Family and financial situation, including information on income, assets and liabilities, and health status if required for the purpose of the advice
- Needs, requirements and wishes to be considered in the advice
- Investments made in the framework of the advice
The information on the advice is kept for ten years after the advice has been given or the business relationship with the client has ended. This is necessary in order to safeguard the legitimate interests of the adviser and the client in being able to clarify afterwards what took place during the advice. Under the legislation on money laundering and terrorist financing, there may be an obligation to retain advisory documentation and transaction history for longer than this.
Other instances of processing of personal data relating to clients are in cases where the client is invoiced for the advice. In these cases, the processing is based on the company and the client being able to fulfill their contractual obligations to each other. There are also legal requirements regarding bookkeeping and accounting that require these data to be saved for at least 7 years after the invoicing date.
- Name, organization or social security number, contact details including email address
- Payment history for invoicing
The company's customer register also contains information on potential customers. This includes
- Name, social security number, contact details including email address
- Brief summary of the contacts made
In these cases, the data is kept for as long as it is deemed important for the client that the adviser has information about previous discussions. Normally, this means that the information is kept for up to three years. The client can request that this information be deleted at any time.
Personal data is also processed regarding employees and owners. The processing is based on legal requirements such as the Companies Act, the Employment Protection Act and the Accounting Act. The information processed consists of
- Name, social security number, contact details including email address and bank account
- Financial transactions between the registrant and the company
Personal data is stored for up to ten years according to the legal requirements for each personal data.
Based on the personal data processed, the company considers all personal data to be worthy of protection and has therefore established detailed procedures for processing them.
Order management
Meriti Capital AB, (hereinafter referred to as the "Company" or "Meriti Capital"), is a Swedish investment firm under the supervision of the Swedish Financial Supervisory Authority.
Affärsverksamheten består av att erbjuda kunder portföljförvaltning och att ta emot och vidareförmedla order från kund i de fall kunden inte valt portföljförvaltningstjänsten. För de kunder som valt Bolagets portföljförvaltningstjänst, är det istället Bolaget som beslutar om att lägga en order för kundens räkning.
The Company's order handling policy, which is summarized below, aims to regulate how transactions should be executed in order to achieve the best possible result. The guidelines apply to both the Company and its tied agents.
När Bolaget genomför en order eller en portföljtransaktion ska Bolaget vidta alla de åtgärder som behövs för att uppnå bästa möjliga resultat för kunden med avseende på;
- Price,
- Cost,
- Speed,
- Probability of execution and settlement,
- Size,
- nature, and
- Other conditions essential to the customer.
Bolaget beaktar dessa faktorer vid tidpunkten för utförandet utifrån det finansiella instrumentet ifråga och rådande marknadsomständigheter.
Om en kund har gett specifika instruktioner, utför Bolaget ordern i enlighet med dessa. Under sådana omständigheter tar Bolaget inte ansvar för bästa orderutförande.
Where the choice of counterparty for primary market operations is determined by the issuer, that counterparty shall be used.
In certain cases, such as, for example, in the event of a break in trading, when a trading venue cancels trades, in the event of disruptions in the market, in the event of a lack of availability of technical systems or otherwise, it may, in the Company's opinion, be in the best interests of the client that an order is routed in a different way than that normally used for the financial instrument in question. The Company will then take all reasonable steps to achieve the best possible result for the client or fund in the circumstances.
When business transactions are carried out simultaneously on behalf of different customers, the customers are treated according to the same allocation principle. The main rule is that the allocation principle is pro rata.
Pro rata means that the distribution of the trade volume shall be made as a percentage in relation to the portfolio size of the customers covered by the trades. However, investment limitations and restrictions on individual customers' portfolios may mean that the above general rule cannot be fully complied with. This may be the case, for example, where a particular portfolio is intended to replicate a particular base portfolio but the contract with the client does not allow for the inclusion of certain types of securities. Another example is where the client's portfolio is too small to fully replicate the base portfolio. In other cases, too, there may be reasons for minor deviations from the main rule if they are not of material importance, such as a desire to minimize the number of transactions. However, the main rule is that conflicts of interest are avoided through equal treatment of similar portfolios.
Capital base requirements
Meriti Capital AB, (hereinafter referred to as the "Company" or "Meriti Capital"), is a Swedish investment firm under the supervision of the Swedish Financial Supervisory Authority.
För att få en rimlig grund för intern kapitalstyrning, samt leva upp till gängse krav, upprättar Bolaget fortlöpande, och minst en gång per år, en intern kapital och likviditetsutvärdering (IKLU). Denna utvärdering går i korthet ut på att identifiera alla väsentliga risker samt att bedöma kapitalbehovet för täcka desamma. Utvärderingen skall utmynna i ett bedömt kapitalkrav för hela Bolaget.
Meriti Capital's evaluation of the Company's internal capital and liquidity needs leads the Board of Directors to decide that the Company has a total capital requirement of €75,000, which also constitutes the Company's minimum capital.
The capital requirement is based on the fact that the Company is included in category 3, which consists of small and unrelated investment firms. The Company is also not included in the consolidated situation as the remaining group companies do not meet the thresholds to be achieved for the consolidated situation.
The company's equity consists entirely of Common Equity Tier 1 capital. The equity amounts to SEK 1.3 million, which exceeds the minimum capital by approximately SEK 0.5 million.
According to IFR/IFD, the Company's liquidity requirement is SEK 0.4 million. However, management believes that an appropriate liquidity target is that liquidity is not allowed to fall below SEK 0.75 million. A liquidity in this order of magnitude implies a robust stress resistance for the company, and that liquidity is in parity with the total capital requirement, without being unnecessarily restrictive.
If the capital or liquidity requirement is breached during the year, the risk manager shall notify the Chief Executive Officer and the Board of Directors for the implementation of adequate measures. The Board of Directors shall report to the FIN-FSA on the measures taken by the company to restore the required capital and liquidity.
Meriti Capital has no exposure to the credit markets apart from excess liquidity in the Company's bank accounts. The Company's counterparties in this respect are SEB and Swedbank, which have a high credit rating.
The Company's credit risk is generally very low as the Company does not carry out transactions on its own books. The credit risk that does exist is the normal delay in payment of invoices for services rendered that are paid by the Company's customers.
Swedsec
Swedsec was established after the turn of the millennium to strengthen confidence in the Swedish financial industry. The association's focus is on ensuring that competent and suitable employees are active in the industry. Licensing tests, annual knowledge updates and disciplinary procedures are the cornerstones of its operations.
Meriti Capital AB is affiliated with SwedSec Licensiering AB, which is responsible for licensing employees on the Swedish securities market.
Swedsec's Examination Board determines each year which knowledge requirements shall apply to obtaining a license. The Board is also responsible for ensuring that the content of the licensing tests is in line with the established knowledge requirements. The Examination Board also sets the knowledge requirements for the annual knowledge update (ÅKU).
The purpose of licensing is to create and maintain public confidence in the industry. Read more about Swedsec here.