Policy for best execution and order execution

The policy applies for Sparinvest S.A. and its branch ID-Sparinvest, Filial af Sparinvest S.A., Luxembourg (“Sparinvest”).

Sparinvest will apply the policy in the execution of orders placed on behalf funds un-der management (the “Funds”) or institutional clients (the “Clients”).

Read or download the "Policy for best execution and order execution" here.

Appendix 1 - Trading venue and brokers_Policy for best execution and order execution.

Concerning trading of equities: All trading of equities and FX on Sparinvest funds are carried out with Nykredit Bank A/S trading desk. See Nykredit Bank A/S’ order and execution policy here

Remuneration policy

Sparinvest SICAV has delegated the day to day management to Sparinvest S.A.

Sparinvest S.A. is as a management company obliged to have a remuneration policy.

Read or download the "Summary of the remuneration policy" here.

Policy for managing conflicts of interest

Sparinvest trades in securities and other financial instruments for Danish and international clients. When providing investment and related services, Sparinvest must, pursuant to national legislation, ensure that conflicts of interest are identified, managed and prevented so that the interests of our clients are safeguarded in the best possible way.

Sparinvest S.A. is part of the Sparinvest Group. Accordingly, this policy applies to conflicts of interest in Sparinvest S.A. as well as conflicts of interest that may arise as a result of other group entities’ organisational structure, ownership and business activities. 

Read or download the "Policy for managing conflicts of interest at Sparinvest" here.

Code of Conduct

Pursuant to the applied rules and guidelines, the purpose of the Code of Conduct is to provide the Board of Directors of Sparinvest S.A. with a framework of principles and best practice recommendations for the governance of controlling the Company and the UCITS, AIFs and mandates managed by Sparinvest S.A. This Code of Conduct serves as the Board of Directors guidelines to Management who is responsible for setting out the necessary procedures in order to oversee compliance with the instructions set out in this Code of Conduct and likewise to report any deviation hereof to the Board of Directors.

Download "Code of Conduct" - click here


Sparinvest is committed to foster a culture of ethical conduct within the organization. Therefore, Sparinvest encourages whistleblowers to report any breaches through our reporting platform (Whisteblower Platform). The reporting platform protects and enables whistleblowers to raise concerns confidently, without fear of retaliation, by ensuring anonymity.

To learn more about our how and what to report, please read out Whistleblowing Policy – click here.

CSR Policy

Sparinvest’s corporate social responsibility (CSR) policy defines the framework for the strategic areas we have chosen to focus on for our social responsibility. Our ambition to make a positive contribution to a socially sustainable development is fully in line with Sparinvest’s values, which are based on spirit, thoughtfulness, decency and presence.

Sparinvest considers CSR to be value creating rather than an expense. Responsibility for the chosen focus areas should be integrated into every facet of the business to bring comfort to all our stakeholders: employees, investors, partners, customers and shareholders. Our goal is to anchor CSR in every part of our organisation and our value chain, from handling data, servicing and advising customers, human resources, and climate and environmental considerations, right through to local social initiatives and – last but not least – our approach to investing.

With more than 100,000 investors, Sparinvest is deeply rooted in local financial institutions. Through these, we have a great responsibility to ensure investor confidence and to create an interest in contributing to local initiatives for social responsibility. We have also established long-term, mutually satisfying customer relations among institutional investors, both on a national and international level.

We have defined CSR ambitions for the following areas:

  • Customers
  • Environment and climate
  • Suppliers and purchasing
  • Employee relations
  • Community and commitment
  • Responsible investment
  • Structure of the Board of Directors

Read our CSR policy - click here