Investment Services Directive – Markets in Financial Instruments Directive (MiFID)

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Regulatory Framework

Code of Conduct for M.F.M.C. and P.I.C.

The Code of Conduct for Fund Management Companies (F.M.Cs) & Portfolio Investment Companies (P.I.Cs) is mandatory by law under Capital Market Commission Regulation 1/462/7.2.2008 and aims at the protection of the integrity of the market, the establishment of rules dealing with conflicts of interests and the development of efficient capital markets, as well as ensuring that the conduct of business is effected solely in the interest of investors. Main rules of the Code of Conduct seek to ensure that:
F.M.Cs and P.I.Cs act in honesty and lawfully in their business undertakings in the interest of collective and discretionary portfolios under management and of the integrity of the market F.M.Cs and P.I.Cs act with due diligence and care in the interest of the UCITS under management and the integrity of the market.
F.M.Cs and P.I.Cs take measures to avoid situations of conflict of interest F.M.Cs and P.I.Cs follow all regulations in force regarding their conduct of business and take all appropriate measures to ensure the interests of their clients and the integrity of the market.

Code of Conduct for Asset Management Firms

The Code of Conduct for Asset Management Firms is established by Capital Market Commission Regulation 1/452/1.11.2007. It aims at ensuring the provision of services by Asset Managers to their clients in honesty, professionally, independently and objectively, so as to best serve their clients' interests and to comply with existing regulation.

Mutual Funds Tax Status

Mutual Funds
The tax status governing greek Mutual Funds is provided for in article 15 of Law 3522/22.12.2006, replacing article 33 of Law 3283/2.11.04, as in force today.
Income from transferable securities acquired by Mutual Funds in Greece or abroad is exempt income taxation and is not subject to withholding tax. In particular regarding interest on bond debt, the exemption is valid on the condition that the units giving rise to such interest have been acquired at least thirty (30) days prior to the due time for the redemption of interest payments. In the opposite case, income tax is withheld in accordance with the provisions of articles 12 and 54 of the Income Tax Code as ratified by Law 2238/1994 (Official Gazette of the Hellenic Republic 151 A), and this withholding covers the totality of tax obligations of the Mutual Fund and of the unitholders for this income.
The Mutual Fund Management Company is required to pay tax, at a coefficient set at ten per cent (10%) of the main refinancing operations rate (MRO) of the European Central Bank with a surcharge added, depending on the Mutual Fund classification, as follows: Money Market Funds: no surcharge
Bond Funds: 0,25%
Balanced Funds: 0,5%
Equity Funds, and any other type Fund not included in above categories: 1%
The tax is calculated on the half-yearly average of the Fund’s net assets, is computed daily and paid to the appropriate tax authorities within the first fortnight of July and January of the semester following the calculation by the Mutual Fund Management Company in the name and on behalf of the Mutual Fund
In the case of Funds of Funds, the due tax is calculated according to their classification as above. Tax pertaining to and paid by the sub Funds will be deducted from the tax due from the Funds of Funds.
In case of a change to the MRO or to the classification of Mutual Funds, the new tax level is applicable as of the first day of the month following the change.
The tax payment constitutes the sole tax obligation of the Mutual Fund and of its unitholders. The provisions of articles 113 and 116 of the Income Tax Code are also applied accordingly to the due tax on the basis of the provisions of the present paragraph