Lysa is an investment firm under the supervision of the Swedish Financial Supervisory Authority. Lysa’s system developers have solid experience from the banking, telecom sector and payment systems. All of these areas have high demands on customer safety. Lysa’s Board of Directors consists of people with many years of experience from the banking world.

The security architecture has been developed and tested together with Sweden’s leading consulting companies within IT security and all system development applies the industry standard body’s OWASP guidelines.

Lysa uses two-factor authentication signing in on our website. When you visit Lysa.se, the communication is encrypted through a so-called https connection. All pages that you visit are encrypted, and all information that you enter on our web pages is sent encrypted. We use the most powerful encryption protocols that modern browsers support.

Lysa is obliged to keep your securities separate from its own assets. The same applies to the money associated with the requirements of record keeping that Lysa receives in connection with the portfolio management. Since your securities and money must be separate from Lysa's assets, you are entitled to them if Lysa enters into bankruptcy. More information on the management of securities and customers’ money can be found under Investor protection and deposit guarantee. 

Your safety is our highest priority.

Security

Latest updated on 2020-12-04.

When you use Lysa’s services, we will process certain personal data about you. Lysa AB is the personal data controller for all such processing. When visiting our website, we may also process certain personal data by using cookies after your consent (read more our work with cookies here). In this privacy policy you can read about (i) what data about you we collect, (ii) why we process your data, (iii) how we use automated decision making, (iv) which other companies and authorities we share your data with, (v) how long we store your data and (vi) your rights in relation to your data.

Lyse takes great care to protect your personal privacy and will only use your data as specified in this privacy note. We also want to emphasise that Lysa’s customer register and other information which Lysa has about you as a customer is protected by confidentiality in accordance with Chapter 1, Section 11 of the Securities Market Act (2007:528). This means that Lysa may not unauthorised reveal this information.

What personal data do we collect?


Information you provide to us
When you become a customer or when you register your interest to become a customer of ours, you (or where applicable, your representative) submit personal data to us so that we can administer your request. The personal data we collect include e.g. name, social security number, where applicable, a picture of your ID, e-mail address, address, bank account number, financial position, bank statements and information regarding know your customer as required by law with the purpose to restrain money laundering. In connection with certain transactions we may also need to collect additional information from and about you, such as receipts, invoices or other documents proving that a transaction is legal. When using the service, we will also process data about your monthly savings, the frequency and size of deposits and withdrawals, investment guidelines and risk levels, and your balance over time. We also record communication with our customers, such as e-mails and telephone calls when you contact our customer service.

Information we receive from sources other than you
We may supplement your personal data by obtaining data from private and public registers, and information about account numbers from your bank.

Why do we process your personal data?
We use your personal data only for the purposes and under the lawful bases for processing set out below, or in accordance with specific information about a certain processing for a specified purpose to which you can consent. The duration of the processing is specified under the heading “Duration of the processing” (note, however, that we are required by law to keep certain data for longer periods, see more under “Legal requirements”).

Acceptance of customer

Purpose of the processing

If you register your interest to become a customer of ours, we will process your personal data to verify your identity and your information. The processing is done to decide whether we can approve you as a customer. The decision is a so-called “automated decision”. If we do not get a hit against sanction lists that we are required by law to apply, you will be able to become a customer of ours. You can always contact our customer service if you wish to contest such a decision or otherwise if you wish to discuss the decision with us.

Lawful basis for the processing
The processing is necessary for Lysa to comply with legal obligations.

Duration of the processing
We will process the data as long as required by applicable legislation (such as the Swedish Money Laundering and Terrorism Financing (Prevention) Act).

The service

Purpose of the processing
When you are a customer of ours, we will process your personal data to provide you the services in accordance with the customer agreement.

We use profiling when we make an investment proposal for you. The profiling is based on the information you provide to us in connection with the preparation of an investment proposal: your financial situation, risk tolerance, knowledge and experience and investment horizon.

Lawful basis for the processing
The processing is necessary for the performance of the customer agreement with you.

Duration of the processing
We will process the data during the time you are a customer. 

Contact person (corporate customers)

Purpose of the processing
If you are the contact person of a corporate customer, we will process your personal data in order to provide the service to the corporate customer.

Lawful basis for the processing
The processing is necessary for our legitimate interest in providing the service to the corporate customer.

Duration of the processing
We will process your data as long as you are registered as a contact person of the corporate customer. 
Beneficial owner (corporate customers)

Purpose of the processing
If you are the beneficial owner of a corporate customer, we will process your personal data in order to comply with applicable law. 

Lawful basis for the processing
The processing is necessary for Lysa to comply with legal obligations.

Duration of the processing
We will process your data as long as required by applicable legislation (such as the Swedish Money Laundering and Terrorism Financing (Prevention) Act).

Insurance distribution (corporate customers)

Purpose of the processing
In order to provide insurance distribution of company-owned endowment insurance, Lysa processes personal data, for example in order to assess whether a certain solution fits the corporation as a customer. Lysa will also process personal data about the beneficiary of the insured.

Lawful basis for the processing
The processing is necessary for the performance of the customer agreement with the corporate customer and for Lysa to comply with legal obligations.

Duration of the processing
We will process your data as long as required by applicable legislation (such as the Swedish Money Laundering and Terrorism Financing (Prevention) Act).

Potential customer

Purpose of the processing
If you are not a customer of ours, but have received an investment proposal on the website or register an interest in becoming a customer, we will process your data in order to nurture our potential relationship with you.

Lawful basis for the processing
The processing is necessary for our legitimate interest to nurture potential customer relationships.

Duration of the processing
If you have not become a customer or contacted us within three months from the date you registered your interest in becoming a customer, or from the date of the investment proposal, in such a way that there is reason for us to assume that your interest in becoming a customer of ours remains, we will delete your data.

Support

Purpose of the processing
If you contact us through our customer service or otherwise, we will process your information in order to assist you with the relevant question. In connection with this, we may for example save e-mail correspondence and record telephone calls. If we record a telephone you will always be informed.

Lawful basis for the processing
The processing is necessary for the performance of the customer agreement with you and for Lysa to comply with legal obligations.

Duration of the processing
We will delete your personal data within 12 months after the case has been handled.

Marketing
Purpose of the processing
If you sign up to receive newsletters or other information from us, we will process your personal data in order to provide you with the requested information.

Lawful basis for the processing
The processing is necessary for our legitimate interest in maintaining good customer relationships.

Duration of processing
We will cease the processing of personal data if you decline marketing (you can decline marketing in logged-in mode on Lysas website or through a link in each marketing mail). We will then delete your data, unless you are a customer of ours and the data therefore is necessary for other processing.

Requirements by law
Purpose of the processing
If you are a customer of ours or if you have received an investment proposal from us, we must process your data in order to fulfill applicable legislation, such as rules and regulation relating to money laundering and terrorism financing (including requirements of risk assessments, know your customer, risk classifications, monitoring of transactions, review and reporting of suspicious transactions), suitability assessments, checks against santion lists, capital adequacy requirements, as well accounting and tax rules.

Lawful basis for the processing
The processing is necessary for Lysa to comply with legal obligations.

Duration of processing
We will process your data as long as required by applicable legislation (such as the Swedish Accounting Act, the Swedish Money Laundering and Terrorism Financing (Prevention) Act, the Swedish Financial Supervisory Authority’s regulations on securities business, the Swedish Tax Procedure Act).

Abuse of the service

Purpose of the processing
If you register an interest in becoming a customer or if you are a customer of ours, we will process your personal data in order to prevent and detect abuse of the service (including measures for risk management, traceability and evidence and fraud detection).

Lawful basis for the processing
The processing is necessary for our legitimate interest in preventing and detecting abuse of the service.

Duration of processing
We will process the data during the time you are a customer of ours.

Anonymization

Purpose of the processing
We will anonymize certain of your personal data in order to compile anonymous and aggregated statistics (among other things regarding the behaviour of website visitors, website traffic, page views, searches, customer analysis, business follow-up and service development).

Lawful basis for the processing
The processing is necessary for our legitimate interest in creating anonymous statistics.

Duration of processing
We will anonymize your personal data every day. When your personal data has been anonymized, it is no longer considered as personal data under applicable data protection legislation.

Recipients of your personal data (including third country-transfers)

Suppliers/processors
We use the services of suppliers providing storage- and communication services. The suppliers will, as part of their services provided to us, process certain of your personal data on behalf of us. Certain of these suppliers are located within the EU/EEA, but the majority of the suppliers are located in the US. The transfers to the US are subject to appropriate security measures, such as standard contractual clauses approved by the EU Commission. 

When providing insurance distribution, in order to provide customers with company-owned endowment insurance, Lysa cooperates with an external insurance company which, when applicable, will process certain personal data on behalf of Lysa.

Authorities and other third parties
Lysa may disclose information about you to the Swedish Financial Supervisory Authority, the Police Authority, the Tax Agency, Enforcement Agency and other relevant authorities where Lysa is obliged to do so under applicable law, regulation or governmental decision. We may also share certain data with your connected bank, Lysa’s custodian or the providers of payment methods used for your deposits or withdrawals with Lysa. 

Your rights
As a registered, you are entitled to exercise the following rights in relation to our processing of your personal data:

The right of access. You have the right to have access to your personal data (including copies thereof) and certain information regarding the processing of the data.

The right to rectification. You have the right to have inaccurate data rectified and incomplete data completed. If you are a customer you can make such adjustments on your own in logged-in mode on Lysas website.

The right to erasure. Under certain circumstances, you have the right to have your personal data erased (“the right to be forgotten”). Lysa may still need to keep certain personal data in order to fulfill legal requirements (such as the Swedish Accounting Act, the Swedish Money Laundering and Terrorism Financing (Prevention) Act, the Swedish Financial Supervisory Authority’s regulations on securities business, the Swedish Tax Procedure Act).

The right to restriction of processing. Under certain circumstances, you have the right to have the processing of your personal data restricted.

The right to data portability. You have the right to receive your personal data (or under certain circumstances transmit such data to another controller) in a structured, commonly used and machine-readable format.

The right to object. Under certain circumstances, you have the right to object to certain processing. For example, you may unsubscribe for electronic marketing in logged-in mode on Lysas website.

You may also complain about Lysa's processing to the supervisory authority the Swedish Data Protection Authority. You will find contact details to the Data Protection Authority here: https://www.datainspektionen.se/om-oss/kontakta-oss/.

Contact details to Data Protection Officer
Lysa’s Data Protection Officer is Jessica Sædén. You can contact our DPO at dpo@lysa.se.

Amendments to the privacy note
Lysa may amend this privacy note as necessary. You will be informed about any changes affecting the processing of your personal data. The latest version of the privacy note can always be found on Lysas website. At the top of this privacy note you will find the date for the latest amendment.

Information about the processing of personal data when using Lysa’s services.

Privacy note

What is money laundering, terrorist financing and the Anti-Money Laundering Act?
Money-laundering is when money from criminal activities, by various transactions, is transformed to assets that can be reported and used openly. The laundering hides the criminal origins of money. Terrorist financing is to financially support terrorism. This does not only mean making direct contributions to terrorism, but also collecting, providing or receiving money or other assets that are known to finance terrorism.

All financial companies in the EU are obliged to prevent money laundering. The Swedish Anti-Money Laundering Act is based on an EU directive. The Anti-Money Laundering Act means that Lysa must make an assessment of the risk of being used for money laundering. Lysa must also have good knowledge of its customers and their business and understand the purpose of the business relationship and the customers’ transactions.

We must ask you questions
To fulfill the requirements of the Anti-Money Laundering Act, we must ask you certain questions. All information that Lysa receives is processed in accordance with applicable data protection regulation and is covered by confidentiality. Here we describe different conditions or events due to which we must pay more attention.


Know your customer (KYC)
Part of our security work is that you as a customer always must be identified when you do business with us. The identification is done with help of the verification method that Lysa applies at each time. If you request a new service, you as an existing customer may be asked to re-identify yourself and answer additional questions.

You who represent a company or are self-employed must be able to present a valid ID document and prove that you have the right to represent the company. Lysa also needs to know who owns more than 25 percent of the company and whether anyone has a controlling influence in the company. You must also be prepared to answer questions about the company’s operations, its turnover and how the company will use Lysa’s services.

Transactions 
When you want to open an account, make a payment or another transaction you may need to answer questions and identify yourself. If Lysa does not understand where the money comes from, we are obliged to ask. You as a customer must also be prepared to present receipts, invoices or other documents that prove your explanation.

Politically exposed person (PEP)
In accordance with the Anti-Money Laundering Act, we as a company must know if you have a high political position or a high position within the state, are part of the management of an international organisation, or if you are a relative (family or close employee) of someone who has such a position. Due to this requirement, we ask questions about this in connection with you becoming a customer.

In certain cases Lyas may not perform the service
If you cannot identify yourself, Lysa will in many instances not be able to perform the service you require. If we do not comply with the Anti-Money Laundering Act, Lysa may be subject to sanctions from the Swedish Financial Supervisory Authority. It is also important for Lysa to do everything in our power to avoid that our business is used for criminal activities.

If Lysa suspects money laundering, this will be reported to the Financial Police, a special unit within the Swedish Police Authority. 
To reduce money laundering and terrorist financing, we need to work together and help each other. If you have questions, you are always welcome to contact us. You find our contact details on www.lysa-capital/contact.

Read more at www.fi.se.

To protect both you and us from being used for money laundering purposes, we are required under the Swedish Anti-Money Laundering Act to have documented knowledge of you as a customer.

Anti-money laundering

The suitability assessment is performed in order for us to be able to act in your best interest. It is therefore important that you provide us with the correct information and answers on the questions that we ask. In some instances, the questions may be perceived as intimate, but Lysa needs the information in order to be able to perform the service for you in the best way possible.
 

We will ask you to answer the questions again once a year to ensure that your portfolio still is suitable for you. If anything happens in the meantime you should change your answers in the suitability assessment when signed in on Lysas website. 
 

Our recommendation is based only on the answers you provide to the questions in the digital suitability assessment. If you need help in understanding a question you are welcome to contact us.

For us to be able to act in your best interest, we perform something called a “suitability assessment”. The suitability assessment means that we collect information about your knowledge and experience relating to investments, your investment goal, your risk profile and your financial situation. We do this in order to determine whether saving with Lysa is suitable for you and which kind of portfolio that is suitable.

Information about suitability assessment

Retail (non-professional) have the highest level of protection, while eligible counterparties have the lowest. All of Lysa’s customers are categorised as retail customers. The customer categories are described below.

Retail customers 
Retail customers belong to the highest level of protection. This means, among other things, that Lysa has an extensive information obligation. For example, you will receive information about financial instruments and the risks associated with these, as well as information about costs and fees.

In order for Lysa to be able to provide portfolio management to a retail customer, Lysa must first make an assessment of the customer (a so called suitability assessment) based on the customer’s financial situation, whether the customer can bear the financial risk associated with the investment, risk propensity, investment horizon, the customer's needs and desires and its investment objectives.

Professional customers
Professional customers do not have as high protection as retail customers. Professional customers include e.g., larger companies, financial institutions and institutional investors. The protection of professional customers includes e.g.: 
Information about risks in conjunction with investment in financial instruments.

When providing portfolio management to professional customers, Lysa must first make a suitability assessment based on the objectives with the investment and whether the customer can bear the financial risk associated with the investment.

Eligible counterparty
An eligible counterparty has the lowest level of protection. For example, securities companies, insurance companies and credit institutions belongs to this group.

Change of customer category
A customer can request to change customer category. Such a request must be in writing. Lysa determines whether the customer may change customer category and informs the customer whether the change is approved or not. A change in customer category means, among other things, that the customer will have another protection, see the descriptions above.

Lysa is obligated to divide its customers in categories. The categorisation is based on your knowledge, experience and other conditions. The customer category you fall into affects, among other things, which information you receive from Lysa and thus, your customer protection level.

Customer categorisation and customer protection

Lysa strives to maintain a high level of service. If you are dissatisfied with our services, we gladly accept your views through our customer service. If you are still dissatisfied after such a contact, and you have a claim for financial compensation or correction, you can refer the case to our complaint officer.


Your complaint must be made in writing. Specify times and events as extensively as you can. Please also attach the supporting documents you have in the form of notes, correspondence etc. This to ensure that all the facts and the background to the complaint are included in the complaint. Also state your claim for financial compensation.


Lysa handles the complaints we receive with care and urgency, and our goal is that all cases should be answered within fourteen days. If an investigation of the case would require longer processing time, you will receive information about this and when we think we will be able to respond. If we are unable to meet your complaint, you as a customer have the right to receive a written reply with the reasons for this.


The complaint officer is Linn Kihlstrand. You can send a complaint to our complaint officer by email complaint@lysa.se.  


If you are not satisfied with our decision
You have the opportunity to receive free advice from the Swedish Consumers’ Banking and Finance Bureau, see www.konsumernas.se. If you do not have success with your case at Lysa’s Complaints Officer function, you have the opportunity to refer the case to the Swedish National Board for Consumer Disputes (Swe. Allmänna reklamationsnämnden - ARN), see www.arn.se for more information, or to the general court.

If you are dissatisfied with our services, you can always contact our customer service. You can also make a written complaint.

Customer complaints

Lysa is obliged to keep your holdings separate from its own assets. The same applies to the money which we have received in connection with the portfolio management. Since your holdings and money must be separate from Lysa's assets, you are entitled to them if Lysa would enter into bankruptcy. Once a year, Lysa's external auditor verifies that the Lysa’s measures and procedures to ensure the preservation of the separation right are appropriate and suitable.

For fund units and funds, the assets of an individual fund cannot be used in the event of a bankruptcy in Lysa or in the fund company. The assets of a fund are jointly owned by the fund's unit holders (the customers) and are stored at a depositary. When the customer’s fund units are registered on a deposit account with Lysa, they are nominee registered with the fund company. The customer's holdings of fund units are registered in Lysa's unit-holder register. In the register, Lysa differentiates the customer's holdings from other customers' holdings.


State-provided investor protection for your holdings

In the event that Lysa nevertheless cannot dispense your property, for example if it after a bankruptcy would not be possible to find out which are yours and the institution's assets, respectively, you are entitled to compensation from the Swedish state-provided investor protection. Investor protection means that the state protects customers’ securities in transactions or when stored with a bank or an investment firm. 

 

Since Lysa is an Swedish registered investment firm, your holdings are protected by the Swedish state-provided investor protection which is regulated in the Swedish Act (1999:158) on Investor Protection. The compensation is limited to SEK 250,000 per customer and institute. The protection does not apply to changes in the value of shares and other securities.The right to reimbursement also applies to money associated with requirements of record keeping received by the institute from customers, i.e. money that must not be mixed with the institution's own assets.

More information on the investor protection can be found on the website of the Swedish National Debt Office, www.riksgalden.se.


State-provided deposit guarantee for your money

Lysa receives money from customers with an obligation of record keeping. This means that the customer’s money must be kept separate from Lysa’s own assets. The customer is thereby entitled to its money in the event of Lysa’s bankruptcy.

Lysa keeps customers’ money in a client funds account, currently with Danske Bank A/S, Denmark (the “Credit Institution”). Your money is protected under the Danish deposit guarantee called the Guarantee Fund (Dan. Garantiformuen). It provides protection for an amount equivalent to EUR 100,000 per depositor.

A client funds account is an account where money has been deposited on behalf of several customers on the same account. The general rule for client accounts is that the underlying owners of the funds, that is, each customer at Lysa, can each receive compensation from the deposit guarantee up to the maximum amount.

If the Credit Institution fails, the Guarantee Fund in Denmark will within seven working days repay your deposits with up to the maximum amount of EUR 100,000 by sending a payment order to the institution in your home country that administers the deposit guarantee fund, in Sweden the National Debt Office, which will then make the payment. Compensation is given in the local currency.

More information about the Guarantee Fund can be found on the Guarantee Fund’s website, www.garantifonden.dk.

Investor protection and deposit guarantee

An investment firm such as Lysa must identify the conflicts of interest that may arise in the business, for example between Lysa and its customers or between different customers in connection with Lysa’s services. Examples of circumstances which are to be considered are whether Lysa or its owners, in addition to agreed remuneration, may gain a profit or avoid a financial loss at the customer's expense.


Furthermore, Lysa has an obligation to prevent customers' interests from being adversely affected by conflicts of interest. If measures taken are not sufficient to prevent a customer’s interests from being adversely affected, Lysa must clearly inform the customer about the nature or source of the conflict of interest before performing a service on behalf of the customer.


The Board of Directors of Lysa has adopted an instruction for handling conflicts of interest. The purpose of the instruction is to prevent conflicts of interest and, if a conflict still arises, to prevent a negative impact on the customers’ interests. The instruction describes potential conflicts of interest and the measures taken to prevent such adverse effects. The instruction states, among other things, how a sufficient degree of independence can be achieved in order to, as far as possible, avoid that conflicts of interest arise between different departments and units within Lysa and how any conflicts of interest that arise should be managed.


At the customer's request, Lysa can provide further information on the instruction for handling conflicts of interest.

Lysa’s goal is to avoid conflicts of interest to the greatest extent possible. As part of this, we work to identify and see how we can avoid such conflicts.

Conflicts of interest

Internal governance and control comprises the framework of internal steering documents, processes, procedures and reporting which have been established to ensure a sound and efficient operation, reliable financial reporting and the compliance with applicable external regulations. An important part of the internal control is risk management. Risk management means the identification, measure, surveillance, control and reporting of the risks connected to the operations.


Lysa’s shareholders appoint the Board of Directors at the General Meeting. Lysa’s Board of Directors is ultimately responsible for internal governance and control. More information about Lysa’s board members and their experience and competence can be found under “About Lysa”.


As part of the management of the internal governance and control, Lysa applies the three lines of defence model. 
The first line of defence consists of the operational management. The first line of defence is responsible for the risks in the business. This entails a responsibility to control and manage the risks that arise. This responsibility rests with the CEO, CTO and COO as well as other employees.


The second line of defence consists of the functions for risk management and compliance which are independent of the business. The second line is responsible for controls, advice and support relating to the first line’s management of the risks and compliance. Further, the compliance function will evaluate whether the measures taken to remedy any deficiencies are sufficient and provide advice and support to the Board of Directors, the CEO and the General Counsel regarding compliance in the company’s licensed operations. The risk management and compliance functions report regularly to Lysa’s Board of Directors.


The third line of defence consists of the function for internal audit. The function must be independent of the company’s other functions and the business, and operates on behalf of the Board of Directors. The function will, based on a revision plan set by the Board of Directors, review and assess whether the company’s systems, control mechanisms and procedures are suitable and efficient based on regulatory requirements and the activities conducted. The function must also issue recommendations based on the results and review and control that the recommendations are adhered to. The function must regularly report to the Board of Directors.


The auditor is appointed by the shareholders at the Annual General Meeting. The auditor reviews whether Lysa’s annual report and accounts are correct and complete and gives a true and fair view of Lysa and its financial position. The auditor also reviews the Board of Directors’ and the CEO’s management of Lysa’s affairs.

An investment firm must on its website explain how it organises and controls its operations. Here you can find information about Lysa’s internal governance and control.

Internal governance and control

Company and business information
Lysa AB, Reg. No. 559028-0821, is an investment firm with authorisation to conduct securities business. The licensing and supervisory authority is the Swedish Financial Supervisory Agency. All agreements and information material from Lysa is in Swedish or English. Information from Lysa may also be in the language of the country in which the customer registers. Communication between Lysa and the customer will be in Swedish or English.


General information about the right of withdrawal
The account holder has the right to cancel the contract entered into (right of withdrawal) with Lysa by sending a message to Lysa within 14 days from the date the agreement was concluded. The right of withdrawal applies only to the initial product agreement and not to services or transactions already performed. This means that you cannot use the right of withdrawal if you have deposited money into your account and Lysa has invested these for you.

Lysa enters into distance agreements with private individuals regarding investment accounts and portfolio management. According to national legislation implementing Directive 2011/83/EU of the European Parliament and of the Council of 25 October 2011 on consumer rights, in Sweden law (2005:59) on distance contracts and agreements outside business premises (the Distance Contracts Act), Lysa must provide the consumer with certain information a reasonable time before entering into a financial services agreement. Below, you can find company and business information and general information about the right of withdrawal. In addition to this, reference is made to the general terms and conditions of our services.

Distance contracts and right of withdrawal 

Responsible for the document: Chief Executive Officer

The Swedish original version of the Best execution policy (Swe. Instruktion för bästa orderutförande och sammanläggning av order) has been adopted by the Board of Directors. The English version is a translation.

1. Background
In accordance with Chapter 9, Section 33 of the Securities Markets Act, a securities company must establish guidelines for the best execution of orders. Further, Lysa must under the Commission Delegated Regulation (EU) 2017/565 make an annual revision of the guidelines. Therefore, Lysa has adopted the following policy. 
This policy includes information on how Lysa will ensure that the customers’ best interest is taken into account when placing orders. Orders are placed against the fund company Lysa Fonder AB when trading in the funds distributed by Lysa (“Lysa’s funds”).


2. Best execution and order accumulation in Lysa’s funds
Lysa’s funds are funds which are traded outside the market by transmitting an order to Lysa Fonder AB for execution in accordance with the fund rules. Lysa will execute a customer’s order fast, efficient and fair. 
Lysa will accumulate a customer’s order of fund shares in Lysa’s funds with other customers’ orders. An accumulated order which has been executed in its entirety will be distributed with regard to the NAV applicable for the relevant business day. If an accumulated order only can be partly executed, the executed part will be divided proportionally between the customers based on the NAV applicable for the relevant business day.


3. Disruptions 
In case of market disruptions, insufficient access to Lysa’s internal technical systems or other force majeure events outside of Lysa’s control, it may according to Lysa’s assessment be impossible or inappropriate to execute an order according to any of the methods specified. If so, Lysa will take all reasonable measures to by other means achieve the best possible result for the customer.


4. Compliance and updates 
The Chief Executive Officer is responsible for the compliance and implementation of this document. Lysa will on an annual basis review its policy that has been adopted for best execution. The policy will also be reviewed when there has been a material change which affects Lysa’s possibilities to achieve the best possible result when executing customers’ orders. The policy will be updated annually or more regularly if necessary.

The Best execution policy has been adopted by the Board of Directors of Lysa AB (”Lysa”) 2021-02-23 and replaces the previously applicable policy.

Best execution policy

If you are not authorised to have access to the material on this website or if you are in any doubt of whether you are so authorised, please leave the website.


The products and services described on the webpage are not available for all persons in all locations. Lysa will not provide the services to a person if Lysa deems (without having to prove) that providing such services might be in conflict with legislation or other rules in the person’s home country or any other country.


Lysa or a third party that has made a specific reservation thereof, will keep the ownership, copyright and other intellectual property rights to the content on the website. All rights are reserved in all countries. The publication, reproduction, transfer or storage of whole or part of the content on the website without the permission of the rights holder is prohibited, except in the case of storage on a computer or the printing for personal use. The content on the website may be cited to the extent permissible by applicable copyright law. When citing, the source must be clearly stated. Trademarks and logotypes on the website may not be reproduced, published or distributed without the written consent of Lysa.

Lysa’s website is directed only to persons who are not prohibited by law applicable in their countries of residence or citizenship to have access to such a website. This especially applies for persons located in the United States, Australia, Canada or Japan.

Terms of use

Lysa has the following authorisations:

 

  • Portfolio management (the Swedish Securities Markets Act (2007:528), Chapter 2, Section 1, item 4)

  • Safekeeping of financial instruments on behalf of customers and receive funds associated with requirements of record keeping (the Swedish Securities Markets Act, Chapter 2, Section 2, item 1)

  • Register as manager of fund units (the Swedish Mutual Funds Act (2004:46), Chapter 4, Section 12)

  • Insurance distribution of direct insurance in the insurance category Ia. Life insurance and III Insurance linked to securities funds (the Swedish Insurance Distribution Act (2018:1219) Chapter 2, Section 1 and 2, and the Swedish Insurance Business Act (2010:2043) Chapter 2, Section 12.

For more information, please visit the Swedish Financial Supervisory Authority’s website www.fi.se. You can reach the Swedish Financial Supervisory Authority, on phone number +468 408 980 00 or adress Finansinspektionen, Box 7821, 103 97 Stockholm, Sweden.

Lysa AB, Reg. No. 559028-0821, conducts securities business under the supervision of the Swedish Financial Supervisory Authority.

Legal information

Security

Sustainability information

An investment firm which provides portfolio management must publish certain sustainability information on its website.

Integration of sustainability risks in the decision-making process

Lysa has adopted a policy which includes information on the integration of sustainability risks and the consideration of adverse sustainability impacts in Lysa’s investment decision-making process (the “Policy”). The following is stated in the Policy:

Since Lysa invests in funds, and not directly in individual companies, Lysa’s decision-making process is about deciding which funds to include in the portfolios offered. One part of the decision-making process is that Lysa evaluates different types of risks, including sustainability risks. In practice, Lysa does this mainly by evaluating how the relevant fund and management company integrates sustainability risks in their decision-making process. This evaluation is made both before including a fund in the portfolios and  continuously thereafter.

Lysa strives to offer portfolios with maximum diversification. Since considering sustainability risks would make the portfolios less diversified, these risks are generally not considered relevant when deciding which funds should be included in the portfolios.

Lysa’s remuneration policy and its consistency with the integration of sustainability risks

As Lysa only pays remuneration that is based on predetermined criteria that is not related to, and does not encourage, risk taking (including sustainability risks), Lysa’s remuneration policy is deemed consistent with the integration of sustainability risks in the decision-making process. More information about Lysa’s remuneration policy is available here.

Consideration of adverse sustainability impacts

There are a number of sustainability factors that are considered important for a sustainable development. These sustainability factors include environmental, social and employee matters, respect for human rights, anti-corruption and anti-bribery matters. If an investment decision leads to adverse impacts on one or several of these sustainability factors it is also deemed to have an adverse impact on sustainable development.

As Lysa strives to offer portfolios with maximum diversification, Lysa does generally not consider adverse impacts of investment decisions on sustainability factors as that would make the portfolios less diversified.

Financial products that promotes environmental or social characteristics

The portfolios offered to Lysa’s customers outside of Sweden does not promote environmental or social characteristics

Please note that Lysa in some regions offer portfolios with focus on sustainability factors. In these portfolios, sustainability risks are considered relevant in the decision-making process and principal adverse impacts on sustainability factors of investment decisions are considered. These portfolios also promote environmental and social characteristics. Currently, Lysa ‘s portfolios with focus on sustainability factors are only available for customers in Sweden. More information about these portfolios are available on our Swedish website here.

Remuneration policy

Here you can find information about Lysa’s remuneration policy. None of Lysa’s employees receive bonuses. Employees may instead be offered variable remuneration consisting of qualified employee stock options.

Lysa AB is part of a company group (the “Lysa Group”) consisting of three companies; Lysa Group AB (the “Parent company”), Lysa Fonder AB (the “Fund Company”) and Lysa. Lysa and the Fund Company are wholly owned subsidiaries to the Parent Company.

Lysa is an investment firm and must therefore have a formal remuneration policy. A remuneration policy aims to promote a sound and efficient risk management and counteract excessive risk-taking. Slightly simplified, this is done mainly by setting specific rules for how and when variable compensation and bonuses may be paid out. Lysa’s remuneration system must be in line with Lysa’s long term interests, encourage good performance and be able to maintain and attract competent employees.

Lysa’s remuneration policy has been adopted by the Board of Directors. Lysa applies individual salaries and does not pay bonuses. To be able to hire competent employees, the Lysa Group however offers qualified employee stock options in the Parent Company.

In order to fulfill the regulatory requirements, we will annually review and update our remuneration policy. On a yearly basis we will also analyse and identify which employees that have a material impact on the company’s risk profile.

Capital adequacy

In accordance with the Swedish Financial Supervisory Authority’s regulations regarding prudential requirements and capital buffers (FFFS 2014:12) on supervisory requirements and capital buffers, and Regulations regarding management of liquidity risks in credit institutions and investment firms (FFFS 2010:7), the following information shall be provided quarterly and be made available on the company’s website (available in Swedish only).

Individuell information (PDF)

Konsoliderad information (PDF)

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Lysa may change this policy. The latest version of the policy is always available on Lysa's website.