GAM Multicash - Money Market Sterling,

un Comparto della SICAV GAM Multicash

(Codice ISIN: LU0032254376, classe di azioni: B - GBP)

Il Comparto è gestito da GAM (Luxembourg) S.A., appartenente a GAM Holding AG

Obiettivi e politica d'investimento

2 L'obiettivo del comparto (il "Comparto") consiste nel conseguire stabilmente un rendimento adeguato. A tal fine, il Comparto investe in obbligazioni emesse per generare liquidità a breve termine (i cosiddetti "strumenti del mercato monetario") denominate in sterline britanniche (GBP). Il Comparto si qualifica come Comparto monetario ai sensi della normativa vigente.

2 Il Comparto investe almeno i 2/3 del patrimonio in strumenti del mercato monetario denominati in sterline britanniche (GBP) nonché in depositi a vista e in altri depositi rimborsabili. La vita residua media degli strumenti del mercato monetario detenuti dal Comparto non può superare i sei mesi. Inoltre, la vita residua media ponderata degli strumenti del mercato monetario non può oltrepassare i 12 mesi.

2 Il Comparto investe in strumenti del mercato monetario denominati in sterline britanniche (GBP) emessi o garantiti da organismi pubblici e/o privati. Gli strumenti del mercato monetario sono di qualità elevata, pertanto vi è un'elevata probabilità di rimborso alla scadenza. Il Comparto può altresì investire in strumenti del mercato monetario denominati in altre valute. In questo caso il Comparto può proteggersi dalle fluttuazioni valutarie rispetto alla sterlina britannica (GBP).

2 In condizioni di mercato sfavorevoli il Comparto può investire in titoli che generano rendimenti nulli o negativi, il che avrà effetti sul rendimento del Comparto.

Il Comparto presenta inoltre le seguenti caratteristiche rilevanti per gli investitori:

2 Il Comparto raffronta la propria performance con quella di un indice di riferimento, il SONIA (Sterling OverNight Index Average), basato sui tassi d'interesse a breve termine in GBP. Per la selezione e la ponderazione degli investimenti il Comparto non è vincolato all'indice di riferimento.

2 Gli investitori possono acquistare o vendere azioni del Comparto in ogni giorno lavorativo delle banche in Lussemburgo.

2 Il Comparto presenta diverse classi di azioni, che differiscono tra loro per caratteristiche quali le aliquote delle commissioni, la valuta e la destinazione dei proventi.

2 I proventi vengono reinvestiti all'interno della classe di azioni.

2 Raccomandazione: questo Comparto potrebbe non essere indicato per gli investitori che prevedono di ritirare il proprio capitale entro sei mesi.

Profilo di rischio e di rendimento

Xxxxxxx più basso Rischio più elevato

L'indicatore tiene conto dei rischi insiti nel valore patrimoniale netto del Comparto. Si tratta in particolare delle oscillazioni del valore degli

Potenziale di rendimento più basso

Potenziale di rendimento

più elevato

investimenti. Oltre ai rischi espressi dall'indicatore, anche i seguenti fattori possono influire in misura significativa sul valore patrimoniale netto del Comparto:

2 Il Comparto investe in strumenti di norma facilmente negoziabili, che pertanto in normali condizioni possono essere venduti al rispettivo valore di mercato. Tuttavia, non è possibile escludere che in situazioni estreme (quali le turbolenze dei mercati) la negoziabilità degli investimenti del

L'indicatore di cui sopra mostra il profilo di rischio e rendimento del Comparto in base alla performance storica registrata dal medesimo negli ultimi 5 anni. Nei casi di assenza dei dati storici quinquennali, la performance storica è stata simulata in base a un indice di riferimento adeguato.

2 Il Comparto è stato classificato nella suddetta categoria in ragione delle sue fluttuazioni di valore in passato.

2 L'indicatore permette all'investitore di comprendere meglio le opportunità di guadagno e i rischi di perdita connessi al Fondo. In questo contesto, neppure l'appartenenza alla categoria più bassa garantisce un investimento esente da rischi.

2 L'andamento del valore passato del Fondo non è indicativo dell'andamento di quelli presente o futuro.

2 La classificazione in una categoria di rischio può cambiare nel tempo, poiché l'andamento futuro del Fondo può fluttuare diversamente dall'andamento storico.

2 Il Comparto non offre alcuna garanzia di rendimento agli investitori, né assicura il recupero dell'importo inizialmente investito.

Comparto sia limitata. In tali casi gli investimenti possono essere venduti unicamente a fronte di una perdita, il che comporta una riduzione del valore del Comparto.

2 Il Comparto investe in obbligazioni, che sono esposte al rischio che l'emittente non sia in grado di adempiere ai propri obblighi di pagamento.

Spese una tantum prelevate prima o dopo l’investimento
Commissione di emissione	2.00%
Commissione di riscatto	1.00%
Commissione di conversione	1.00%
Percentuale massima che può essere prelevata dal vostro capitale prima che venga investito / prima che il rendimento dell’investimento venga distribuito.
Spese prelevate dal fondo in un anno
Spese correnti	0.40%
Spese prelevate dal fondo a determinate condizioni specifiche
Commissioni legate al rendimento	Nessuna

Risultati ottenuti nel passato

Rendimento in %

Valore patrimoniale netto (NAV)

XXXXX (Sterling OverNight Index Average)

2 L'andamento del valore passato non è un indicatore dell'andamento presente o futuro.

2 I dati relativi alla performance si riferiscono al valore patrimoniale netto. Non sono comprese le eventuali commissioni applicabili all'emissione, al rimborso o alla conversione (ad es. i costi di transazione e di custodia a carico dell'investitore).

2 Anno di attivazione della classe di azioni: 1992

2 L'andamento del valore passato è stato calcolato in GBP.

Informazioni pratiche

2 La Banca depositaria è Xxxxx Xxxxxx Xxxx Xxxxxxxxxx X.X.X., 00, Xxxxxx J. F. Xxxxxxx, L-1855 Luxembourg.

2 Per ulteriori informazioni in merito al presente Comparto, nonché ad altre Classi di azioni o ad altri Comparti della SICAV si prega di consultare il prospetto, lo statuto, l'ultima relazione annuale o le più recenti relazioni semestrali della SICAV presso la sede di quest'ultima, presso i rappresentanti o i distributori nazionali o sul sito internet xxx.xxxxx.xxx.xxx. I documenti citati sono disponibili gratuitamente su richiesta in una delle lingue ufficiali o in inglese.

2 Il valore patrimoniale netto viene pubblicato giornalmente su xxx.xxxxx.xxx.xxx e xxx.xxxxxxxx.xxx.

2 La SICAV è soggetta alla normativa fiscale lussemburghese. Ciò può incidere sulla situazione fiscale dell'investitore.

2 GAM (Luxembourg) S.A. può essere ritenuta responsabile unicamente delle dichiarazioni contenute nel presente documento che siano fuorvianti, inesatte o in disaccordo con le parti corrispondenti del prospetto dell'OICVM.

2 È possibile effettuare conversioni tra i comparti della SICAV lussemburghese.

2 GAM Multicash è stata costituita sotto forma di "Société d'Investissement à Capital Variable" di diritto lussemburghese.

2 Le informazioni relative all'attuale politica delle commissioni della Società di gestione sono disponibili su internet all'indirizzo xxx.xxxxx.xxx.xxx. Esse includono una descrizione dei metodi di calcolo delle commissioni e degli altri contributi, l'indicazione dei soggetti responsabili della loro attribuzione e la composizione delle commissioni. Su richiesta, tali informazioni vengono rese disponibili gratuitamente dalla Società di gestione in formato cartaceo.

GAM Multistock - Luxury Brands Equity,

un Comparto della SICAV GAM Multistock

(Codice ISIN: LU0329429897, classe di azioni: B - EUR)

Il Comparto è gestito da GAM (Luxembourg) S.A., appartenente a GAM Holding AG

Obiettivi e politica d'investimento

2 L'obiettivo del comparto (il "Comparto") consiste nel conseguire un incremento del capitale a lungo termine. A tal fine, il Comparto investe a livello mondiale in azioni di società selezionate con marchi consolidati, che offrono prodotti e servizi nel settore dei beni di lusso.

2 Il Comparto investe almeno i 2/3 del patrimonio in società attive nel settore dei beni di lusso. Il Comparto seleziona le società leader del settore del lusso che dispongono di marchi di eccellenza, offrono prodotti di qualità eccezionale e puntano costantemente all'innovazione.

Il Comparto presenta inoltre le seguenti caratteristiche rilevanti per gli investitori:

2 Il Comparto non si orienta ad alcun indice di riferimento. Pertanto, non è soggetto ad alcuna limitazione nella selezione delle classi di attività, delle strategie, degli strumenti finanziari da utilizzare e della relativa ponderazione.

2 Gli investitori possono acquistare o vendere azioni del Comparto in ogni giorno lavorativo delle banche in Lussemburgo.

2 Il Comparto presenta diverse classi di azioni, che differiscono tra loro per caratteristiche quali le aliquote delle commissioni, la valuta e la destinazione dei proventi.

2 I proventi vengono reinvestiti all'interno della classe di azioni.

2 Raccomandazione: questo Comparto potrebbe non essere indicato per gli investitori che prevedono di ritirare il proprio capitale entro cinque anni.

Profilo di rischio e di rendimento

Xxxxxxx più basso Rischio più elevato

L'indicatore tiene conto dei rischi insiti nel valore patrimoniale netto del Comparto. Si tratta in particolare delle oscillazioni del valore degli

Potenziale di rendimento più basso

Potenziale di rendimento

più elevato

investimenti. Oltre ai rischi espressi dall'indicatore, anche i seguenti fattori possono influire in misura significativa sul valore patrimoniale netto del Comparto:

2 In ragione della sua performance storica, il Comparto è stato classificato nella suddetta categoria.

2 L'andamento del valore passato del Fondo non è indicativo dell'andamento di quelli presente o futuro.

2 La classificazione in una categoria di rischio può cambiare nel tempo, poiché l'andamento futuro del Fondo può fluttuare diversamente dall'andamento storico.

2 Il Comparto non offre alcuna garanzia di rendimento agli investitori, né assicura il recupero dell'importo inizialmente investito.

Comparto sia limitata. In tali casi gli investimenti possono essere venduti unicamente a fronte di una perdita, il che comporta una riduzione del valore del Comparto.

2 La situazione politica, giuridica ed economica nei paesi emergenti è spesso instabile e può essere soggetta a cambiamenti rapidi e imprevisti. Tale situazione può avere ripercussioni negative sugli investitori esteri e sui mercati dei capitali di tali paesi. Di conseguenza, l'andamento del valore dei comparti che investono in tali paesi può essere penalizzato.

Spese una tantum prelevate prima o dopo l’investimento
Commissione di emissione	5.00%
Commissione di riscatto	3.00%
Commissione di conversione	1.00%
Percentuale massima che può essere prelevata dal vostro capitale prima che venga investito / prima che il rendimento dell’investimento venga distribuito.
Spese prelevate dal fondo in un anno
Spese correnti	2.06%
Spese prelevate dal fondo a determinate condizioni specifiche
Commissioni legate al rendimento	Nessuna

Risultati ottenuti nel passato

Rendimento in %

Valore patrimoniale netto (NAV)

2 L'andamento del valore passato non è un indicatore dell'andamento presente o futuro.

2 Anno di attivazione della classe di azioni: 2008

2 L'andamento del valore passato è stato calcolato in EUR.

Informazioni pratiche

2 La Banca depositaria è Xxxxx Xxxxxx Xxxx Xxxxxxxxxx X.X.X., 00, Xxxxxx J. F. Xxxxxxx, L-1855 Luxembourg.

2 Il valore patrimoniale netto viene pubblicato giornalmente su xxx.xxxxx.xxx.xxx e xxx.xxxxxxxx.xxx.

2 La SICAV è soggetta alla normativa fiscale lussemburghese. Ciò può incidere sulla situazione fiscale dell'investitore.

2 È possibile effettuare conversioni tra i comparti della SICAV lussemburghese.

2 GAM Multistock è stata costituita sotto forma di "Société d'Investissement à Capital Variable" di diritto lussemburghese.

GAM MULTICASH

A SICAV UNDER LUXEMBOURG LAW

PROSPECTUS

1ST DECEMBER 2017

Subscriptions are validly made only on the basis of this Prospectus or the Key Investor Information Document in conjunction with the most recent annual report and the most recent semi-annual report where this is published after the annual report.

No information other than that contained in this Prospectus or the Key Investor Information Document may be given.

TABLE OF CONTENTS

1. Introduction 5

2. Organisation and management 7

3. Investment objectives and investment policy 9

4. Investor profile 11

5. Investment limits 12

6. Special investment techniques and financial instruments 17

6.1. Options on securities 17

6.2. Financial futures, swaps and options on financial instruments 17

6.3. Efficient Portfolio management – other investment techniques and–instruments 19

6.4. Securities lending 19

6.5. Securities repurchase agreements 20

6.6. Management of collateral for OTC derivatives and efficient portfolio management techniques 21

6.7. Techniques and instruments for hedging currency risks 22

6.8. Structured products 22

6.9. Swaps and other financial derivatives with comparable properties 22

6.10. Investments in financial indices pursuant to Article 9 of the Grand Ducal Ordinance 23

of 8 February 2008 23

6.11. Risks associated with the use of derivatives and other special investment techniques 24

and financial instruments 24

7. The Company 26

8. Custodian 27

9. Management Company And domiciliary paying agent 29

10. Central Administrative, and principal paying agent; Registrar and transfer agent 29

11. General information on Investment management and investment Advice 30

11.1. Investment Managers / Investment Advisor 30

12. Paying agents and representatives 30

13. Distributors 31

14. Co-management 31

15. Description of Shares 32

16. Issue of Shares / Application procedure 34

16.1. Application and confirmation 36

16.2. General 37

17. Redemption of Shares 37

18. Switching of Shares 39

19. Dividends 40

20. Calculation of net asset value 40

21. Suspension of calculation of net asset value, and of the issue, redemption and switching of Shares 41

22. Fees and costs 42

23. Taxation 44

23.1. Company 44

23.2. Shareholders 44

23.3. Foreign Account Tax Compliance Act (“FATCA”) of the United States of America (“US”) 45

24. General meeting of shareholders and reporting 46

25. Applicable law, jurisdiction 47

26. Remuneration policy 47

27. General Conflicts Associated with the Company 47

28. Documents for inspection 50

Annex I: Overview of comparative index 52

1. INTRODUCTION

GAM Multicash (the ”Company“, „GAM Multicash“) is established as a „société d'investissement à capital variable“ (SICAV) in accordance with the current version of the law of the Grand Duchy of Luxembourg dated August 10, 1915 (”the 1915 Law“), and authorised in Luxembourg as an undertaking for collective investments in transferable securities (UCITS) under Part I of the law dated December 17, 2010 (”the 2010 Law“).

The Company has an “umbrella structure”, which allows establishing subfunds (“Subfunds”) that correspond to different investment portfolios and that can be issued in different categories of shares.

The Board of Directors of the Company is authorised to issue shares ("Units", "Shares“) without par value in various investment portfolios („Subfunds“) relating to the Subfunds described in the section “Investment objectives and investment policy“, and, as noted in the section ”Description of Shares“, the following share categories ("Share Category") with different characteristics may be issued for each Subfund

The price of the Shares is denominated in the same currency of the Subfund in question. As described in the section „Issue and sale of Shares / Application procedure“, a selling fee of up to 2% may be charged in addition to the Issue Price.

Fund name: GAM Multicash -	Currency	Initial subscription period
MONEY MARKET DOLLAR	USD	April 30, 1991
MONEY MARKET EURO	EUR	April 30, 1991
MONEY MARKET STERLING	GBP	April 30, 1991
MONEY MARKET SWISS FRANC	CHF	April 30, 1991

The Company may issue Shares in new, additional Subfunds at any time. In this case, this prospectus will be supplemented accordingly.

The Company currently issues Share Categories with different fee structures (see sections ”Issue and sale of Shares / Application procedure“ and ”Fees and costs“).

Investors may purchase shares either directly from the Company or via an intermediary, which acts in its own name but for the investor’s account. In the latter case an investor may not necessarily assert all his/her investor’s rights directly against the Company. For details reference is made to the chapter “Issue of shares / Application procedure”, under “Nominee Service”.

Shares may be redeemed at a price as described in the section ”Redemption of Shares“. Shares may be switched using the formula described in the section ”Switching of Shares“.

The Shares of individual share categories of the Company can be quoted on the Luxembourg Stock Exchange.

Subscriptions are only accepted on the basis of the valid prospectus or the valid Key Investor Information Document in conjunction with (i) the most recent annual report of the Company or (ii) the most recent semi-annual report where this is published after the annual report.

Under the 2010 Law, the Company is authorised to produce one or more special prospectuses for the distribution of Shares in one or more Subfunds or for one specific distribution country.

This prospectus, the Key Investor Information Document and any special prospectuses do not constitute an offer or advertisement in those jurisdictions where such an offer or advertisement is prohibited, or in which persons making such offer or advertisement are not authorised to do so, or in which the law is infringed if persons receive such offer or advertisement.

In addition to the Prospectus, a key investor information document is produced for each share category and is handed to each purchaser before he/she subscribes to Shares (“Key Investor Information Document”). By subscribing to the Shares, each purchaser declares that he/she has received the Key Investor Information Document prior to effecting the subscription.

The information in this prospectus is in accordance with the current law and rules and regulations of the Grand Duchy of Luxembourg, and is thus subject to alterations.

In this prospectus, figures in „Swiss Francs“ or „CHF“ refer to the currency of Switzerland; „US Dollars“, dollars or ”USD“ to the currency of the United States of America; ”Euro“ or ”EUR“ to the currency of the European Economic and Monetary Union; ”£ Sterling“, “Sterling” or ”GBP“ to the currency of Great Britain.

Potential purchasers of Shares are responsible for informing themselves on the relevant foreign exchange regulations and on the legal and tax regulations applicable to them.

Because Shares in the Company are not registered in the USA in accordance with the United States Securities Act of 1933, they may neither be offered nor sold in the USA including the dependent territories, unless such offer or such sale is permitted by way of an exemption from registration in accordance with United States Securities Act of 1933.

In general, shares in the Company may neither be offered, nor sold nor transferred to persons engaging in transactions within the scope of any US American defined benefit plan. Exceptions hereto are possible, provided the Board of Directors of the Company has issued a corresponding special authorization for it. In this sense, a “defined benefit pension plan” means any (i) “defined benefit pension plan for employees”, within the meaning of Section 3(3) of the US Employee Retirement Income Security Act of 1974, as amended (“ERISA”) that is subject to the provisions of Part 4 of Title I of ERISA, (ii) individual retirement account, Xxxxx Plan or other plan described in Section 4975(e)(1) of the US Internal Revenue Code of 1986, as amended, (iii) entity whose underlying assets include “plan assets” by reason of 25% or more of any class of equity interest in the entity being held by plans described in (i) and (ii) above, or (iv) other entity (such as segregated or common accounts of an insurance company, a corporate group or a common trust) whose underlying assets include “plan assets” by reason of an investment in the entity by plans described in (i) and (ii) above. Should investors participating in a defined benefit pension plan hold more than 25% of a share category, the company’s assets shall be considered, in accordance with ERISA, "plan assets", which could have an adverse effect on the Company and its shareholders. In this case, the Company may, if appropriate, require the compulsory redemption of the shares affected.

Further information can be obtained at xxx.xxxxx.xxx.xxx .

2. ORGANISATION AND MANAGEMENT

The Company’s registered office is at 00, Xxxxx-Xxx, X-0000 Xxxxxxxxxx.

Board of Directors of the Company Chairman:

Xxxxxx Xxxxx Member of the Group Management Board, GAM Group

Members:

Xxxxxx Xxxxxx Region Head (UK), GAM (UK) Limited, London

Me Xxxxxx Xxxxxxx Independent Director, Partner, Linklaters LLP, Luxembourg Xxxx-Xxxxxx Xxxxx Independent Director, Luxembourg

Xxxx Xxxxxxx Member of the Group Management Board, GAM Group

Management Company

GAM (Luxembourg) S.A., 00, Xxxxx-Xxx, X-0000 Xxxxxxxxxx

Board of Directors of the Management Company Chairman:

Xxxxxx Xxxxx Member of the Group Management Board, GAM Group

Members:

Xxxxxx Xxxxxx Member of the Group Management Board, GAM Group Xxxx Xxxxxx Independent Director, Luxembourg

Xxxxxxx Xxxxxx Head of Operations and IT, GAM Fund Management Ltd., London Xxxxx Xxxxxxx Member of the Group Management Board, GAM Group

Managing directors of the Management Company

Xxxx Xxxxx Managing Director, GAM (Luxembourg) S.A., Luxembourg Xxxxx Xxxxxxx Managing Director, GAM (Luxembourg) S.A., Luxembourg

Custodian, Central administration, principal paying agent, registrar and transfer agent State Street Bank Luxembourg S.C.A., 00, Xxxxxx Xxxx X. Xxxxxxx, X-0000 Xxxxxxxxxx Investment managers and investment advisers

The Company and the Management Company have appointed investment managers and/or investment advisers and may appoint further investment managers and/or investment advisers.

Distributors

The Company, respectively the Management Company, has appointed Distributors and may appoint additional Distributors to sell Shares in various legal jurisdictions.

Auditor of annual report

PricewaterhouseCoopers Société coopérative, 0 xxx Xxxxxxx Xxxxxxxx, X-0000 Xxxxxxxxxx has been appointed as the auditor of the annual report of the Company.

Legal adviser

Linklaters LLP, 00, Xxxxxx Xxxx X. Xxxxxxx, X-0000 Xxxxxxxxxx is the legal adviser to the Company in Luxembourg.

Supervisory authority in Luxembourg

Commission de Surveillance du Secteur Financier (“CSSF”), 283, route d’Arlon, L-1150 Luxembourg, Grand Duchy of Luxembourg

Further information and documents about the Company and the individual Subfunds may also be inspected on the web site xxx.xxxxx.xxx.xxx .

Investors will also find there a form for lodging complaints.

3. INVESTMENT OBJECTIVES AND INVESTMENT POLICY

The investment objective of the Company is to achieve an appropriate return for each Subfund in the applicable currency, applying the principles of risk diversification, value stability and high liquidity. In order to achieve this, the fund assets can be invested, in accordance with the investment policy and investment limits, in fixed-interest or floating-rate securities (including zero bonds) of with a short remaining term to maturity as well as in money market instruments denominated in the currency of the particular Subfund, the currency of another OECD member state or in Euro, and which are traded on the money market, a securities exchange of a recognised country or on other regulated markets in a recognised country. In this context, a recognised country is a member state of the Organisation for Economic Cooperation and Development (OECD), and all other countries in Europe, North and South America, Africa, Asia and Pacific basin (hereafter «recognised country”). A regulated market is a market which is recognised and open to the public, and whose operation is properly regulated (hereafter “regulated market“). The money market is a segment of the financial market, in which financial instruments with short durations are traded (hereinafter “Money Market”).

In addition to securities and the other assets permitted as described in the section „Investment limits“, it is also possible to hold liquid assets, these being in principle of an ancillary nature.

In order to pursue the investment objectives, the Subfunds may, in the context of the guidelines and limits established on the basis of Luxembourg law, use the investment techniques and financial instruments described below in the section „Special investment techniques and financial instruments“.

Consequently, a Shareholder runs the risk that he/she may not recover the amount originally invested. Depending on the orientation of the individual Subfunds this risk may differ from Subfund to Subfund. It is also noted that there are increased risks in relation to the settlement of the Company’s securities transactions, above all the risk that the securities may be delivered late or not at all. Furthermore, the attention of investors is drawn to the fact that in case of adverse market conditions, the Subfund may invest in zero or negative yielding securities, which will have an impact on the income of the individual Subfund.

Currency risks may also arise for shareholders whose reference currency differs from the investment currency of a Subfund. The following description of the Subfunds shall not be construed as a recommendation to acquire Shares in a particular Subfund. Rather, each shareholder should consult his/her financial adviser regarding the acquisition of Shares in the Company and the selection among the Subfunds and their Share Categories.

The performance of the individual Subfunds is set out in the Key Investor Information Document.

The Board of Directors of the Company ("Board of Directors“) has determined the following investment objectives and investment policy for each Subfund:

GAM Multicash – MONEY MARKET DOLLAR

(a money market fund)

The investment objective of the Company in relation to GAM Multicash – MONEY MARKET DOLLAR (“MONEY MARKET DOLLAR“) is to achieve a return appropriate for the level of the US dollar money market, while applying the principle of risk spreading, value stability and liquidity.

In order to achieve this investment objective, the MONEY MARKET DOLLAR invests at least two thirds of its assets in money-market instruments in accordance with directive 2009/65/EC and in sight deposits or deposits subject to withdrawal notice held with qualified banking institutions, with these investments having to be denominated in US dollars.

Furthermore the Company may invest up to a maximum of one third of the assets of MONEY MARKET DOLLAR in the above-mentioned investments which are denominated in other freely convertible currencies.

Furthermore derivative financial instruments and special investment techniques can also be used for efficient portfolio management and hedging purposes. Derivative investment techniques for efficient portfolio management may only be used in accordance with section 11 of Box 2 of the CESR Guidelines on a Common Definition of European Money Market Funds (CESR/10-049).

MONEY MARKET DOLLAR is denominated in US dollars. As far as investments of MONEY MARKET DOLLAR are denominated in currencies other than the US dollar, foreign currency risks will be hedged.

GAM Multicash – MONEY MARKET EURO

(a money market fund)

The investment objective of the Company in relation to GAM Multicash – MONEY MARKET EURO (“MONEY MARKET EURO“) is to achieve a return appropriate for the level of the euro money market, while applying the principle of risk spreading, value stability and liquidity.

In order to achieve this investment objective, the MONEY MARKET EURO invests at least two thirds of its assets in money-market instruments in accordance with directive 2009/65/EC and in sight deposits or deposits subject to withdrawal notice held with qualified banking institutions, with these investments having to be denominated in euros.

Furthermore the Company may invest up to a maximum of one third of the assets of MONEY MARKET EURO in the above-mentioned investments which are denominated in other freely convertible currencies.

MONEY MARKET EURO is denominated in euros. As far as investments of MONEY MARKET EURO are denominated in currencies other than the euro, foreign currency risks will be hedged.

GAM Multicash – MONEY MARKET STERLING

(a money market fund)

The investment objective of the Company in relation to GAM Multicash – MONEY MARKET STERLING (“MONEY MARKET STERLING“) is to achieve a return appropriate for the level of the sterling money market, while applying the principle of risk spreading, value stability and liquidity.

In order to achieve this investment objective, the MONEY MARKET STERLING invests at least two thirds of its assets in money-market instruments in accordance with directive 2009/65/EC and in sight deposits or deposits subject to withdrawal notice held with qualified banking institutions, with these investments having to be denominated in sterling.

Furthermore the Company may invest up to a maximum of one third of the assets of MONEY MARKET STERLING in the above-mentioned investments which are denominated in other freely convertible currencies.

MONEY MARKET STERLING is denominated in sterling. As far as investments of MONEY MARKET STERLING are denominated in currencies other than sterling, foreign currency risks will be hedged.

GAM Multicash – MONEY MARKET SWISS FRANC

(a money market fund)

The investment objective of the Company in relation to GAM Multicash – MONEY MARKET SWISS FRANC (“MONEY MARKET SWISS FRANC“) is to achieve a return appropriate for the level of the Swiss franc money market, while applying the principle of risk spreading, value stability and liquidity.

In order to achieve this investment objective, the MONEY MARKET SWISS FRANC invests at least two thirds of its assets in money-market instruments in accordance with directive 2009/65/EC and in sight deposits or deposits subject to withdrawal notice held with qualified banking institutions, with these investments having to be denominated in Swiss francs.

Furthermore the Company may invest up to a maximum of one third of the assets of MONEY MARKET SWISS FRANC in the above-mentioned investments which are denominated in other freely convertible currencies.

MONEY MARKET SWISS FRANC is denominated in Swiss francs. As far as investments of MONEY MARKET SWISS FRANC are denominated in currencies other than the Swiss franc, foreign currency risks will be hedged.

The attention of investors in the Subfund is drawn to the fact that money-market instruments may involve a higher risk than sight deposits or deposits subject to withdrawal notice held with banking institutions. Investors must take into account the fact that the MONEY MARKET DOLLAR, MONEY MARKET SWISS FRANC, MONEY MARKET EURO and MONEY MARKET STERLING have a longer

weighted average maturity (“WAM”) and a longer weighted average life (“WAL”) than money-market funds with a short maturity structure. In addition, not every currency hedging process provides complete protection. No guarantee can be given that hedging will be successful. Furthermore an interest-rate risk may result from possible future changes in the level of the market interest rate. Losses may arise for the Subfunds as a result of the default or changes to the credit rating of an issuer or counterparty. There is not always a regulated secondary market for money-market instruments. Therefore it is not always guaranteed that these investments will be saleable at any time. As far as derivative financial instruments and special investment techniques are used in a Subfund for efficient portfolio management and for hedging purposes, account must be taken of the risk characteristics of derivatives and other investment techniques and instruments, in addition to those of securities, as described in the section “Special investment techniques and financial instruments”. Depending on the scale of possible fluctuations in value, the investor must expect capital losses if shares are redeemed. A loss of value cannot therefore be ruled out.

Although the Company makes every effort to achieve the investment objectives of the Subfunds to the best of its knowledge, no guarantee can be given as to whether the investment objectives will be achieved. As a result, the net asset values of the Shares may be greater or smaller, and different levels of positive as well as negative income may be earned.

4. INVESTOR PROFILE

Each of these Subfunds is a low-risk investment vehicle subject to low fluctuations and focusing on asset preservation, on the one hand suitable for investors who do not have an in-depth knowledge of the capital markets and on the other hand allowing experienced investors to invest their liquid assets efficiently. Each of these Subfunds may be used as a basic investment within the portfolio, or as a temporary investment for experienced investors.

5. INVESTMENT LIMITS

1. Investments in securities, money market instruments, deposits and derivatives

These investments comprise:

(a) Securities and money market instruments:

- which are admitted to or dealt in on a regulated market within the meaning of Directive 2004/39/EC;

- which are dealt in on another regulated market in a member state of the European Union ("EU") which is recognized, open to the public and operates regularly;

- which are admitted to official listing on a stock exchange in a non-EU state1 or is traded on another regulated market of a non-EU state which is recognized, open to the public and operates regularly;

- resulting from new issues, provided the terms of issue contain an undertaking to apply for official listing on a stock exchange or another regulated market which is recognized, open to the public and operates regularly, and that the admission will be obtained within one year of the issue.

(b) Sight deposits or deposits repayable on demand maturing in no more than 12 months with qualified credit institutions whose registered office is located in a member state of the EU or in a member state of the OECD or in a country with equivalent money-laundering regulations ("qualified credit institutions").

(c) Derivatives, including equivalent cash-settled instruments, which are dealt in on a regulated market as specified in (a), first, second or third indent, and/or OTC (over the counter) derivatives provided that:

- the underlying securities are instruments as defined by Article 41 paragraph 1 of the 2010 Law or are financial indices, interest rates, exchange rates or currencies in which the Subfund may invest according to its investment objectives;

- the counterparties in transactions with OTC derivatives are institutions subject to supervision belonging to the categories approved by the Commission de Surveillance du Secteur Financier (CSSF); and

- the OTC derivatives are subject to reliable and verifiable valuations on a daily basis and can be sold, liquidated or settled through an offsetting transaction at any time at the initiative of the Company at their fair value.

(d) Shares in UCITS authorised in accordance with Directive 2009/65/EC and/or other UCIs within the meaning of Article 1 paragraph (2), first and second indent of Directive 2009/65/EC having their registered office in a member state of the EU or a non-EU state, provided that:

- such other UCIs are authorised in accordance with legal requirements which submit them to prudential supervision considered by the CSSF to be equivalent to that under the EU community law and that there is sufficient guarantee of cooperation between the authorities;

- the level of protection of unitholders of such other UCIs is equivalent to the level of protection of the unitholders of a UCITS and in particular that the requirements for segregation of the fund’s assets, borrowing, lending and uncovered sales of transferable securities and money market instruments are equivalent to the requirements of Directive 2009/65/EC;

- the business activities of the other UCIs are subject to semi-annual and annual reports which enable an assessment of the assets and liabilities, income and transactions over the reporting period;

- the UCITS or this other UCI, whose units are to be acquired may, according to its constitutional documents, invest in total no more than 10% of its net asset value in units of other UCITS or other UCIs.

1 As used in the Directive 2009/65/EG, a non-EU state is a country which is not a member of the EU.

shareholding, the Management Company or the other company may not charge the Company any fees for subscription or redemption of shares in other UCITS and/or UCI.

A Subfund may invest in other Subfunds of the Company, subject to the prerequisites laid down in Article 181 paragraph 8 of the 2010 Law.

(e) Money market instruments which are not traded on a regulated market and fall under the definition of Article 1 of the 2010 Law, provided the issue or issuer of these instruments are themselves subject to regulations concerning the protection of savings and investors, and provided:

- they are issued or guaranteed by a central governmental, regional or local authority or the central bank of a EU member state, the European Central Bank, the EU or the European Investment Bank, a non-EU state or, in the case of a federal state, one of the members making up the federation, or by a public international institution to which at least one EU member state belongs; or

- they are issued by an undertaking whose securities are traded on the regulated markets designated in 1. (a); or

- they are issued or guaranteed by an establishment subject to supervision in accordance with the criteria defined by EU Community law, or by an institution which is subject to and complies with prudential rules which in the opinion of the CSSF are at least as stringent as those under EU Community law; or

- they are issued by other issuers belonging to a category approved by the CSSF provided such instruments are subject to investor protection regulations which are equivalent to those of the first, second or third indent and provided the issuer is either a company with own funds of at least ten (10) million euros which presents and publishes its annual accounts in accordance with the provisions of the 4th Directive 78/660/EEC, or an entity within a group comprising one or more companies listed on an official stock exchange which is dedicated to the financing of that group, or is an entity which is dedicated to the financing of the securitization of liabilities by use of a credit line granted by a bank.

(f) However:

- the Company may invest no more than 10% of the net asset value of each Subfund in transferable securities and money market instruments other than those referred to in (a) to (e);

- the Company may not acquire precious metals or certificates representing them.

(g) The Company may accessorily hold liquid assets.

2. Investment restrictions

(a) The Company may invest not more than 10% of the net asset value of each Subfund in securities or money market instruments of one and the same issuer. The Company may invest not more than 20% of the net asset value of each Subfund in deposits made with one and the same institution.

The risk exposure to a counterparty in OTC-derivatives transactions by the Company must not exceed the following percentages:

- 10% of the net asset value of each Subfund when the counterparty is a qualified credit institution;

- and otherwise 5% of the net asset value of each Subfund.

In the case of UCITS, the aggregate risk exposure is determined either by using the Commitment Approach or by means of a model approach (Value-at-Risk model), which takes into account all general and specific market risks that may lead to a significant change in the value of the portfolio. If the Commitment Approach is used, the aggregate risk associated with derivatives (market risk) of each Subfund must not exceed the net asset value of the Subfund concerned.

If a Subfund uses a value-at-risk (VaR) method to calculate its aggregate risk, the calculation of the VaR is based on a confidence interval of 99%. The holding period corresponds to one month (20 days) for the purpose of calculating the aggregate risk.

The calculation of the aggregate risk is done for the respective Subfund, either using the Commitment Approach or according to the VaR model (absolute or relative VaR with the corresponding benchmark) as listed in the table below:

Subfunds	Relative VAR/ Absolute VAR/ Commitment Approach	Benchmark used to calculate the risk exposure (only in the case of relative VaR)
GAM Multicash – MONEY MARKET DOLLAR	Commitment Approach	_
GAM Multicash – MONEY MARKET EURO	Commitment Approach	_
GAM Multicash – MONEY MARKET STERLING	Commitment Approach	_
GAM Multicash – MONEY MARKET SWISS FRANC	Commitment Approach	_

The aggregate risk of the underlying instruments must not exceed the investment limits set out in (a) to (f). The underlying instruments of index-based derivatives do not have to observe these investment limits. However, if a derivative is embedded in a transferable security or money market instrument, it must be taken into account for the purpose of the provisions of this section.

(b) The total value of the issuers' securities and money market instruments in which a Subfund invests more than 5% of its net asset value must not exceed 40% of its net asset value. This limitation does not apply to deposits or OTC derivative transactions made with financial institutions subject to prudential supervision.

(c) Irrespective of the individual maximum limits under (a), a Subfund may invest not more than 20% of its net asset value with a single institution in a combination of:

- securities or money market instruments issued by this institution and/or

- deposits made with this institution and/or

- OTC derivatives transactions undertaken with this institution.

(d) The limit stated in (a), first sentence, is raised to 35% if the securities or money market instruments are issued or guaranteed by a EU member state or by its local authorities, by a non-EU state or by public international institutions of which at least one EU member state is a member.

(e) The limit stated in (a), first sentence, is raised to 25% for certain debt securities when they are issued by a credit institution with its registered office in an EU member state which is subject, by law, to special prudential supervision designed to protect investors in debt securities. In particular sums deriving from the issue of these debt securities must be invested in conformity with the law in assets which, during the whole period of validity of the debt securities, are capable of covering claims attaching to the debt securities and which, in case of failure of the issuer, would be used on a priority basis for the repayment of principal and of the accrued interest.

If a Subfund invests more than 5% of its net asset value in the debt securities referred to in the above paragraph and which are issued by one issuer, the total value of such investments may not exceed 80% of the net asset value of the Subfund concerned.

(f) Securities and money market instruments mentioned in (d) and (e) are not taken into account in the calculation of the limit of 40% referred to in (b).

The limits stated in (a) to (e) may not be combined, and thus investments in accordance with (a) to (e) in securities or money market instruments of one and the same issuer or in deposits with the said issuer or in derivatives made with that issuer may not exceed a total of 35% of the net asset value of a Subfund.

Companies which are included in the same group for the purpose of consolidated accounts as defined in the Directive 83/349/EEC or in accordance with recognized international accounting rules are regarded as a single issuer for the purpose of calculating the aforementioned limits.

The investments by a Subfund in securities and money market instruments within the same group of companies may cumulatively not exceed 20% of its net asset value; this is without prejudice to paragraphs (d) and (e) above.

(g) Notwithstanding points (a) to (f), the Company is authorized in accordance with the principle of risk diversification to invest up to 100% of a Subfund's net asset value in securities and money market instruments from different issues, which are issued or guaranteed by an EU member state or by its local authorities, by a member state of the OECD or by public international organizations of which at least one EU member state is a member, provided, however, that the Subfund must hold securities and money market instruments of at least six different issues, whereby the securities and money market instruments of each single issue may not account for more than 30% of the net asset value of the Subfund concerned.

(h) Without prejudice to the limits laid down in (j), the upper limit laid down in (a) for investments in shares and/or debt securities issued by the same issuer may be raised to a maximum of 20% when the investment strategy of the Subfund is to replicate the composition of a certain stock or bond index which is recognized by CSSF. This depends on the following conditions:

- that the composition of the index is sufficiently diversified;

- that the index represents an adequate benchmark for the market to which it refers;

- that the index is published in an appropriate manner.

The limit laid down in the previous paragraph is of 35% where that proves to be justified by exceptional market conditions, in particular in regulated markets where certain securities or money market instruments are highly dominant. The investment up to this limit is only permitted for a single issuer.

(i) A Subfund may acquire units of target funds as defined within 8.1 (d) above, for a maximum of 10% of its net asset value.

(j)

(A) The Company or the Management Company acting in connection with all of the investment funds which it manages and which qualify as a UCITS, may not acquire any shares carrying voting rights which would enable it to exercise significant influence over the management of the issuer.

(B) Moreover, for the respective Subfund, the Company may acquire no more than:

- 10% of the non-voting shares from the same issuer;

- 10% of debt securities from the same issuer;

- 25% of the units of the same target fund;

- 10% of the money market instruments of any single issuer.

The limits laid down in the second, third and fourth indents may be disregarded at the time of acquisition if at that time the gross amount of debt securities or money market instruments or the net amount of the shares in issue cannot be calculated.

Paragraphs (A) and (B) shall not apply:

- to securities and money market instruments issued or guaranteed by a EU member state or its local authorities;

- to securities and money market instruments issued or guaranteed by a non-EU state;

- to securities and money market instruments issued by public international institutions of which one or more EU member states are members;

- to shares held by the Company in the capital of a company incorporated in a non-EU state which invests its assets mainly in the securities of issuers having their registered office in that

state, where under the legislation of that state, such a holding represents the only way in which the Company can invest in the securities of issuers of that state. This derogation, however, shall only apply if in its investment policy the company from the non-EU state complies with the limits laid down in (a) to (f) and (i) and (j) (A) and (B). Where the limits set in

(a) to (f) and (i) are exceeded, (k) shall mutatis mutandis apply;

- to shares held by the Company alone or together with other UCIs in the capital of subsidiary companies which, exclusively on its or their behalf carry on only the business of management, advice or marketing in the country where the subsidiary is located, in regard to the redemption of shares at the request of shareholders.

(k)

(A) The Company need not comply with the limits laid down herein when exercising subscription rights attaching to transferable securities and money market instruments which form part of its assets. Irrespective of its obligation to comply with the principle of risk diversification, each Subfund may derogate from the rules set out in (a) to (h) for a period of six months following the date of its launch.

(B) If the Company exceeds the limits referred to in (A) for reasons beyond its control or as a result of the exercise of subscription rights, it must adopt as a priority objective for its sales transactions the remedying of that situation, taking due account of the interests of its shareholders.

(l)

(A) The Company may not borrow. However, the Company may acquire foreign currency by means of a "back-to-back" loan.

(B) By way of derogation from paragraph (A), the Company may (i) borrow up to 10% of its net asset value per Subfund provided that the borrowing is on a temporary basis, and (ii) borrow up to 10% of its net asset value provided that the borrowing is to make possible the acquisition of immovable property essential for the direct pursuit of its business; in no case may the borrowings referred to in (i) and (ii) together exceed 15% of the net asset value concerned.

(m) The Company and the custodian bank may not grant loans or act as guarantor for third parties for the account of the Subfund, without prejudice to points (a) to (e) under point 1. This shall not prevent the Company from acquiring transferable securities or money market instruments or shares in target funds or financial instruments referred to in (c) and (e) under point 1 which are not fully paid.

(n) The Company and the custodian bank may not carry out short sales of transferable securities, money market instruments, shares in target funds or financial instruments referred to in (c) and (e) under point 1.

(o) The Company may hold liquid assets, which under certain circumstances can be increased to up to 49% of the assets of the relevant Subfund.

3. Further guidelines on investment

(a) The Company will not acquire securities which entail unlimited liability.

(b) The fund’s assets must not be invested in real estate, precious metals, precious metal contracts, commodities or commodity contracts.

(c) The following additional investment limits shall apply to investments of MONEY MARKET DOLLAR, MONEY MARKET SWISS FRANC, MONEY MARKET EURO and MONEY MARKET STERLING respectively:

(A) The weighted average maturity (WAM) may not exceed six months. The WAM measures the average duration until maturity of all securities held in the respective Subfund, according to the percentage share of the assets of the respective Subfund for which they account. In the case of floating-rate securities, the maturity is assumed to be the remaining duration until the date of the next possible interest-rate adjustment.

(B) The weighted average life (WAL) may not exceed 12 months. The WAL is a weighted average of the remaining duration (until maturity) of all securities held in the respective Subfund. Unlike the WAM, in the case of the WAL the date of final maturity is assumed for floating-rate securities, instead of the next possible interest-rate adjustment.

(C) The maximum residual term to maturity of individual fixed-interest securities and the maximum interest-rate adjustment period of the individual floating-rate securities may not exceed 397 days. The maximum residual term to maturity of the individual floating-rate securities may not exceed two years. In the case of first-time issues, the residual term to maturity is computed from the first settlement date of a security.

(D) Money-market instruments must carry one of the two highest available short-term credit ratings awarded by any recognized credit rating agency which has rated the instrument, or if the instrument is not rated by a recognized credit rating agency, it must have an equivalent rating, as determined by the internal rating process of the management company. An exception to this rule is instruments with a good credit rating (at least investment grade), which are issued or guaranteed either by a central governmental, regional or local authority or by the central bank of an EU member state, the European Central Bank, the EU or the European Investment Bank.

(d) The Company can implement further investment restrictions in order to comply with the requirements in countries in which Shares shall be offered for sale.

6. SPECIAL INVESTMENT TECHNIQUES AND FINANCIAL INSTRUMENTS

In the interests of efficient management or for hedging purposes, the Company may make use of the following investment techniques and financial instruments for each Subfund. It may, in addition, use derivative financial instruments for investment purposes if due provision is made for this in the investment policy. It must at all times comply with the investment restrictions stated in Part I of the 2010 Law and in the section "Investment limits" in this prospectus, and must in particular be aware of the fact that the underlying of the derivative financial instruments and structured products used by each Subfunds have to be taken into account in the calculation of the investment limits stated in the previous section. The Company will at all times observe the requirements of CSSF ordinance 10-04 and the Luxembourg regulations issued from time to time when using special investment techniques and financial instruments. In respect of each Subfund the Company will also take into account the requirement to maintain an appropriate level of liquidity when employing special investment techniques and financial instruments (particularly in the case of derivatives and structured products).

6.1. OPTIONS ON SECURITIES

The Company may, for each Subfund and regarding the permitted investments, buy and sell call or put options as long as they are traded on a regulated market, or (“OTC options”) provided the counterparties of such transactions are first class financial institutions specializing in this kind of transactions.

6.2. FINANCIAL FUTURES, SWAPS AND OPTIONS ON FINANCIAL INSTRUMENTS

Subject to the exceptions mentioned below, futures and options on financial instruments are, as a matter of principle, limited to contracts traded on regulated markets. OTC derivatives may only be concluded if the counterparties are first class financial institutions which specialize in transactions of this kind.

a) Xxxxxx against market risks and risks associated with stock market performance

For the purpose of hedging against poor market performance, the Company may, for each Subfund sell forward transactions and call options on share price indexes, bond market indexes or other indexes or financial instruments or buy put options on share price indexes, bond market indexes or other indexes or buy financial instruments or enter into swaps in which the payments between the Company and the counterparty depend on the development of certain share price indexes, bond market indexes or other indexes or financial instruments.

As these call and put transactions are for hedging purposes, there must be a sufficient correlation between the structure of the securities portfolio to be hedged and the composition of the stock index employed.

b) Xxxxxx against interest rate risks

For the purpose of hedging against the risks associated with changes in interest rates the Company may sell interest rate futures and call options on interest rates, buy put options on interest rates and enter into interest rate swaps, forward rate agreements and options on interest rate swaps (swaptions) with first class financial institutions specializing in this kind of transactions as part of OTC transactions for each Subfund.

c) Xxxxxx against inflation risks

For the purpose of hedging against risks resulting from an unexpected acceleration of inflation, the Company may conclude so-called inflation swaps with first class financial institutions specializing in this type of transaction as part of OTC transactions or make use of other instruments to hedge against inflation for each Subfund.

d) Xxxxxx against credit default risk and the risk of a deterioration in a borrower's credit standing

For the purpose of hedging against credit default risk and the risk of losses owing to a deterioration in the borrower's credit standing, the Company may engage in credit options, credit spread swaps ("CSS"), credit default swaps ("CDS"), CDS (index) baskets, credit-linked total return swaps and similar credit derivatives with first class financial institutions specializing in this kind of transactions as part of OTC transactions for each Subfund.

e) Non-hedging transactions ("active management")

The Company may for each Subfund use financial derivatives for purposes of efficient asset management. Thus the Company may, for example, buy and sell forward contracts and options on all types of financial instrument and use derivatives in order to control currency fluctuations.

The Company can also enter into interest and credit swaps (interest rate swaps, credit spread swaps ("CSS"), credit default swaps ("CDS"), CDS (index) baskets, etc.), inflation swaps, options on interest rate and credit swaps (swaptions), but also swaps, options or other transactions in financial derivatives in which the Company and the counterparty agree to swap performance and/or income (total return swaps, etc.) for each Subfund. This comprises also so-called Contracts for Difference - “CFD”. A contract for difference is a contract between two parties, the buyer and the seller, which specifies that the seller will pay the buyer the differential amount between the current value of an asset (a security, instrument, basket of securities or an index) and its value at the time the contract is closed out. If the differential amount is negative, the buyer owes the seller the (corresponding) payment. Contracts for difference allow the Subfunds to take synthetic long or short positions with provision of variable collateral, where the maturity date and the size of the contract are not defined, unlike in the case of futures contracts. The counterparties must be first class financial institutions which specialize in such transactions.

f) Securities forward settlement transactions

In the interests of efficient management or for hedging purposes, the Company may conclude forward transactions with broker/dealers acting as market makers in such transactions, provided they are first class financial institutions specializing in this type of transaction and participate in the OTC markets. The transacti ons in question include the purchase or sale of securities at their current price; delivery and settlement then take place on a later date that is fixed in advance.

Within an appropriate period in advance of the transaction settlement date, the Company can arrange with the broker/dealer either for it to sell or buy back the securities or for it to extend the time limit, all realized profits or losses from the transaction being paid to the broker/dealer or paid by it to the Company. However, the Company concludes purchase transactions with the intention of acquiring the securities in question.

The Company can pay the normal charges contained in the price of the securities to the broker/dealer in order to finance the costs incurred by the broker/dealer because of the later settlement.

6.3. EFFICIENT PORTFOLIO MANAGEMENT – OTHER INVESTMENT TECHNIQUES AND–INSTRUMENTS

In addition to investments in derivatives, the Company may also make use of other investment techniques and instruments based on securities and money market instruments such as repurchase agreements (repurchase or reverse repurchase transactions) and securities lending transactions pursuant to the terms of the CSSF Circular 08/356 (as last amended and any replacement circular) and the Guidelines of the European Securities and Markets Authority ESMA/2012/832, as implemented in Luxembourg by the CSSF Circular 13/559 (as last amended by the CSSF Circular 14/592), as well as any other guidelines introduced in this regard. Investment techniques and instruments based on securities and money market instruments that are used for the purposes of efficient portfolio management, including derivatives that are not used for direct investment purposes, shall fulfil the following criteria:

a) they are economically appropriate in that they are used cost-effectively;

b) they are used with one or more of the following specific aims:

i. To reduce risk;

ii. To cut costs;

iii. Generation of additional capital or revenue for the Company, associated with a risk that is compatible with the risk profile of the Company and the relevant Subfunds of the Company and with the applicable rules on risk diversification;

c) their risks are appropriately captured by the Company's risk management process; and

d) they may not result in any change to the Subfund's declared investment objective or be associated with any substantial supplementary risks compared with the general risk strategy as described in the prospectus or the key investor information.

Potential techniques and instruments for efficient portfolio management are detailed below and are subject to the conditions described below.

Moreover, such transactions may be entered into for 100% of the assets held by the Subfund concerned provided that (i) their scope remains appropriate or the Company is entitled to recall the securities that have been lent so that it is always in a position to meet its redemption obligations and (ii) such transactions do not jeopardise the management of the Company's assets in line with the investment policy of the Subfund concerned. Risk monitoring must be carried out in line with the Company's risk management process.

Efficient portfolio management may possibly have a negative impact on the return for shareholders.

Efficient portfolio management may lead to direct and indirect operational costs that are deducted from the revenue. These costs shall not include hidden charges.

Care shall also be taken to ensure that no conflicts of interest are created to the detriment of investors as a result of efficient portfolio management techniques being applied.

6.4. SECURITIES LENDING

For the purposes of generating additional capital or income or reducing costs and risks in the context of a standardised system and pursuant to the provisions of the CSSF Circular 08/356, (as last amended and any replacement circular) and the Guidelines of the European Securities and Markets Authority ESMA/2012/832 and other guidelines introduced in this regard, the Company is permitted to lend securities of a Subfund to third parties (up to a maximum of 100% of the estimated total value of the instruments of the Subfund provided the Company has the right to terminate the contract at any time and recover the lent securities), although such transactions may only be carried out through recognized clearing houses such as Euroclear or Clearstream SA or other recognized national clearing houses or using highly rated financial institutions specialized in this type of transaction, and according to their terms of business. The counterparty in a securities lending transaction must in addition be subject to supervisory regulations which are considered by the CSSF to be equivalent to those under the EU community law. The rights to refund must in principle be protected by collateral security to a value which at the time the contract is entered into and throughout the lending term at least corresponds to the estimated total value of the relevant lent securities; this can be done through the provision of collateral security

in the form of fixed-term deposits or securities which are issued or guaranteed by OECD member states, their local authorities or institutions of a supranational or regional character, or by other highly rated issuers, or else through the provision of collateral security in the form of shares in highly rated companies (on condition that hedging is provided against any fall in price between the time the collateral security is created and the time the lent security in question is returned), with such collateral security remaining blocked, on behalf of the Company, until expiry of the applicable securities lending transaction. The collateral received is not re-invested. The Company must have the right to terminate at any time any securities lending agreement into which it has entered or to recall any security that has been lent.

All revenues arising from efficient portfolio management techniques, net of direct and indirect operational costs/fees, shall be returned to the respective Subfund.

From the gross revenues from securities lending, the services connected to it will be paid, such as particularly the depositary, lending agent, indemnification, consisting of a minimum amount and a pro-rate participation, as well as a remuneration for risk and collateral management, legal and IT support to the Management Company. The Management Company will ensure that only market-compliant costs will be applied. The remaining revenues will be fully credited to the respective Subfund.

The Company shall further ensure that the volume of securities lending is maintained at an appropriate level or that the Company is entitled to have the lent securities returned in a manner that ensures that it is always in a position to meet its redemption obligations and that such transactions do not jeopardise the management of the assets of the Subfunds in accordance with its investment policy.

The risk exposures to a counterparty resulting from securities lending and OTC financial derivatives should be combined in order to calculate the counterparty risk pursuant to the Section "Risks in conjunction with the use of derivatives and other special investment techniques and financial instruments".

Non-cash collateral received may not be sold, re-invested or pledged during the term of the transaction. Cash collateral received should only be:

- placed on deposit with credit institutions described in Article 50(f) of the UCITS Directive;

- invested in high-quality government bonds;

- used for the purpose of reverse repurchase transactions provided that the transactions are with credit institutions subject to supervision and the Company is able to recall at any time the full amount of cash on accrued basis;

- invested in short-term money market funds as defined in the CESR's Guidelines on a Common Definition of European Money Market Funds.

Re-invested cash collateral must be diversified in accordance with the diversification requirements applicable to non-cash collateral.

The Section "Risks in conjunction with the use of derivatives and other special investment techniques and financial instruments" contains further risk information in this regard.

6.5. SECURITIES REPURCHASE AGREEMENTS

The Company may, in compliance with the provisions of CSSF circular 08/356 and the investment policy of the relevant Subfund, for that Subfund engage in repurchase agreements (“Repurchase Agreements”) and reverse repurchase agreements (“Reverse Repurchase Agreements”) involving the purchase and sale of securities where the seller has the right or obligation to repurchase the securities sold from the buyer at a fixed price and within a certain period stipulated by both parties upon conclusion of the agreement.

The Company may effect repurchase transactions either as a buyer or a seller. However, any transactions of this kind are subject to the following guidelines:

- Securities may only be purchased or sold under a repurchase agreement if the counterparty is a first class financial institution specializing in this kind of transaction and is subject to supervisory regulations which are considered by the CSSF to be equivalent to those under the EU community law.

- As long as the repurchase agreement is valid, the securities bought cannot be sold before the right to repurchase the securities has been exercised or the repurchase period has expired.

- In addition, it must be ensured that the volume of repurchase agreements of each Subfund is structured in such a way that the Subfund can meet its redemption obligations towards its shareholders at any time.

If the Company agrees repurchase transactions for a Subfund, it must be able to either recall the underlying securities or terminate the transaction at any time. Repurchase Agreements that do not exceed seven days should be considered as transactions that allow the assets to be recalled at any time by the Company.

If the Company enters into a Reverse Repurchase Agreement it should ensure that it is able at any time to recall the full amount of cash or to terminate the Reverse Repurchase Agreement on either an accrued basis or a mark-to-market basis. When the cash is recallable at any time on a mark-to-market basis, the mark-to-market value of the reverse repurchase agreement should be used for the calculation of the net asset value. Reverse repurchase agreements that do not exceed seven days should be considered as arrangements on terms that allow the assets to be recalled at any time by the Company. The Company must publish the total amount of outstanding repurchase transactions as at the reference date in its yearly and half-yearly reports.

6.6. MANAGEMENT OF COLLATERAL FOR OTC DERIVATIVES AND EFFICIENT PORTFOLIO MANAGEMENT TECHNIQUES

The following provisions are in line with the requirements of the Guidelines of the European Securities and Markets Authority ESMA/2012/832, which may be amended in future.

1. Collateral received ("collateral") in connection with OTC derivative transactions and efficient portfolio management techniques, such as e.g. in the context of repurchase transactions or securities lending, must at all times fulfil all of the following criteria:

(a) Liquidity: Any collateral received other than cash should be highly liquid and traded on a regulated market or multilateral trading facility with transparent pricing in order that it can be sold quickly at a price that is close to pre-sale valuation. Collateral received should also comply with the provisions of Article 48 of the Law of 2010.

(b) Valuation: Collateral received should be able to be valued on a daily basis, and assets that exhibit high price volatility should not be accepted as collateral unless suitably conservative haircuts are in place.

(d) Correlation: The collateral must be issued by an entity that is independent from the counterparty and is expected not to display a high correlation with the performance of the counterparty.

(e) Diversification: Collateral should be sufficiently diversified in terms of countries, markets and issuers. The criteria of sufficient diversification in terms of the concentration of the issuers is deemed to be fulfilled when a Subfund receives from the counterparty a collateral basket, in which the maximum exposure towards a particular issuer does not exceed 20% of the net asset value. When a Subfund is exposed to different counterparties, the different baskets of collateral should be aggregated to calculate the 20% limit of exposure to a single issuer.

By way of derogation from this sub-paragraph, a Subfund may be fully collateralised in different transferable securities and money market instruments issued or guaranteed by a Member State, one or more of its local authorities, a third country, or a public international body to which one or more Member States belong. Such a Subfund should receive securities from at least six different issues, but securities from any single issue should not account for more than 30% of the Subfund’s net asset value. Subfunds that intend to be fully collateralised in securities issued or guaranteed by a Member State should disclose this fact in the Prospectus. Subfunds should also identify the Member States, local authorities, or public international bodies issuing or guaranteeing securities which they are able to accept as collateral for more than 20% of their net asset value.

(f) Immediate availability: The Company must be able to realise the collateral at any time without reference to the counterparty or requiring the counterparty's approval.

2. Subject to the above criteria, collateral admissible for any Subfund must meet the following requirements:

(a) Liquid assets such as cash or short-term bank deposits, money market instruments as defined in Directive 2007/16/EC of 19 March 2007, letters of credit or "pay upon first request" suretyships issued by a first-class credit institution that is not linked to the counterparty;

(b) Bonds issued or guaranteed by a member state of the OECD.

3. Where there is a title transfer, the collateral received should be held by the depositary or its representative. For other types of collateral arrangement, the collateral can be held by a third party custodian that is subject to prudential supervision and unrelated to the provider of the collateral.

4. The Company has introduced a haircut strategy for each class of assets received as collateral. A haircut is a deduction from the value of collateral to take account of a deterioration in the valuation or in the liquidity profile of the collateral over time. The haircut strategy takes into account the characteristics of the respective assets, including the credit standing of the issuer, price volatility and the outcome of stress tests performed as part of collateral management. Subject to existing transactions with the counterparty concerned, which may include minimum amounts for the transfer of collateral, the Company intends applying a haircut of at least 2% to collateral received (as defined in No. 2b), at least corresponding to the counterparty risk.

5. Risks and potential conflicts of interest in conjunction with OTC derivatives and efficient portfolio management

(a) Specific risks are associated with OTC derivative transactions, efficient portfolio management and the management of collateral. Further information in this regard is provided in this prospectus in the Section "Risks in conjunction with the use of derivatives and other special investment techniques and financial instruments" and also in the comments on the risks associated with derivatives, counterparty risk and depositary counterparty risk. These risks may expose shareholders to an elevated risk of loss.

(b) The combined counterparty risk arising from a transaction with OTC derivatives or techniques for efficient portfolio management may not exceed 10% of the assets of a Subfund if the counterparty is a credit institution based in the EU or in a country in which, according to the Luxembourg supervisory authority, the supervisory system is equivalent to that applicable in the EU. In all other cases this limit is 5%.

6.7. TECHNIQUES AND INSTRUMENTS FOR HEDGING CURRENCY RISKS

For the purpose of hedging against currency risks the Company may at a stock exchange or on another regulated market, or in the context of OTC transactions, conclude currency futures contracts, sell currency call options or buy currency put options in order to reduce exposure to the currency that is deemed to present a risk or to completely eliminate such risk and to shift into the reference currency or into another of the permissible currencies that is deemed to present less risk for each Subfund.

Currency futures and swaps may be executed by the Company in the open market with first class financial institutions specializing in this kind of transaction.

6.8. STRUCTURED PRODUCTS

The Company may use structured products in the interests of efficient management or for hedging purposes for any Subfund. The range of structured products includes in particular credit-linked notes, equity-linked notes, performance-linked notes, index-linked notes and other notes whose performance is linked to basic instruments which are permitted in accordance with Part I of the 2010 Law and the associated implementing regulations. For this, the counterparty must be a first class financial institution specializing in this type of transaction. Structured products are combinations of other products. Derivatives and/or other investment techniques and instruments may be embedded in structured products. In addition to the risk features of securities, those of derivatives and other investment techniques and instruments therefore also have to be noted. In general, they are exposed to the risks of the markets or basic instruments underlying them. Depending on the structure, they may be more volatile and thus entail greater risks than direct investments, and there may be a risk of a loss of earnings or even the total loss of the invested capital as a result of price movements on the underlying market or in the basic instrument.

6.9. SWAPS AND OTHER FINANCIAL DERIVATIVES WITH COMPARABLE PROPERTIES

The Subfunds may invest in total return swaps or other derivatives with comparable properties, which can be defined as follows:

with paragraphs 48-61 of ESMA Guidelines 2012/832. The components of the financial indices include, among others, equities, bonds, derivatives on commodities. The investment policy of the various Subfunds includes further details on the deployment of total return swaps or other derivatives with comparable properties, which may have different underlyings and strategies compared with those described above.

- The counterparties of such transactions are regulated financial institutions with a good credit rating and that specialise in such transactions.

- The failure of counterparty may have a negative impact on the return for shareholders. The asset manager intends to minimise counterparty performance risk by only selecting counterparties with a good credit rating and by monitoring any changes in those counterparties' ratings. Additionally, these transactions are only concluded on the basis of standardised framework agreements (ISDA with Credit Support Annex; Deutscher Rahmenvertrag with Besicherungsanhang, or similar). The Credit Support Annex or Besicherungsanhang defines the conditions under which collateral is transferred to or received from the counterparty in order to reduce the default risk associated with derivative positions and thus the negative impact on the return for shareholders should a counterparty fail.

- The counterparties in the case of total return swaps or other derivatives with comparable properties have no discretionary power with regard to how the portfolio of a Subfund is composed or managed or with regard to the underlyings of these financial derivatives. Similarly, the counterparty’s consent is not required for the execution of such transaction. Any deviation from this principle is detailed further in the Subfund's investment policy.

-Total return swaps or derivatives with comparable properties will be included in the calculation of the investment restrictions.

6.10. INVESTMENTS IN FINANCIAL INDICES PURSUANT TO ARTICLE 9 OF THE GRAND DUCAL ORDINANCE OF 8 FEBRUARY 2008

The Company may invest in Derivatives with indices as their underlying, and may increase the diversification limits for an index component pursuant to Article 44 of the Law of 2010.

Diversification limits may be increased in exceptional market circumstances if one or more components of an index occupy a dominant position within a given market, sector or segment. A domination position may be created as a result of special economic or market developments or as a result of market, sector or segment- specific restrictions. Further details in this regard are provided where applicable in the relevant Subfund's investment policy.

The Company shall invest in derivative financial instruments with indices as their underlying that generally include a half-yearly or yearly adjustment of the index composition ("rebalancing frequency"). A distinction should be made between the following cases:

- In the case of derivatives that are traded on a stock market, the rebalancing merely changes the calculation but has no direct or indirect impact on the costs of the corresponding Subfund.

- In the case of OTC derivatives, the counterparty will generally not physically hold the index components but will secure its position primarily using derivative instruments. If transactions take place as a consequence of rebalancing, these should be carried out on very liquid derivative markets so that the impact on the costs of the relevant Subfund is kept low.

In the case of investments in commodity indices, the following rules also apply:

Commodity indices contain a representative balance of commodities taken from the entire commodities universe and represented by futures. This representative and balanced selection of commodities reflects the existence of several commodities. The Company should not invest in commodity indices that do not consist of different commodities. Commodity indices are assessed on the basis of the correlation of various different index components.

6.11. RISKS ASSOCIATED WITH THE USE OF DERIVATIVES AND OTHER SPECIAL INVESTMENT TECHNIQUES AND FINANCIAL INSTRUMENTS

Prudent use of these derivative and other special investment techniques and financial instruments may bring advantages, but does also entail risks which differ from those of the more conventional forms of investment and in some cases may be even greater. Further below follows a general outline of important risk factors and other aspects relating to the use of derivative and other special investment techniques and financial instruments and about which the shareholder should be informed before investing in a Subfund.

- Market risks: These risks are of general nature and are present in all types of investments; the value of a particular financial instrument may change in a way that can be detrimental to the interests of a Subfund.

- Monitoring and control: Derivatives and other special investment techniques and financial instruments are specialized products which require different investment techniques and risk analyses than equities or bonds. The use of derivatives requires not just knowledge of the underlying instrument, but also of the derivative itself, although the performance of the derivative cannot be monitored under all the possible market conditions. The complexity of such products and their use in particular require suitable control mechanisms to be set up for monitoring the transactions and the ability to assess the risks of such products for a Subfund and estimate the developments of prices, interest rates and exchange rates.

- Liquidity risks: Liquidity risks arise when a certain stock is difficult to acquire or dispose of. In large-scale transactions or when markets are partially illiquid (e.g. where there are numerous individually agreed instruments) it may not be possible to execute a transaction or close out a position at an advantageous price.

- Counterparty risks: There is a risk that a counterparty will not be able to fulfil its obligations (performance risk) and/or that a contract will be cancelled, e.g. due to bankruptcy, subsequent illegality or a change in the tax or accounting regulations since the conclusion of the OTC derivative contract and/or that the counterparty will fail to meet one of its financial obligations or liabilities towards the Subfund (credit risk). This relates to all counterparties with which derivative, repurchase, reverse repurchase or securities lending transactions are entered into. A direct counterparty risk is associated with trading in non-collateralised derivatives. The respective Subfund can reduce a large proportion of the counterparty risk arising from derivative transactions by demanding that collateral at least in the amount of the commitment be provided by the respective counterparty. If, however, derivatives are not fully collateralised, the failure of the counterparty may cause the Subfund's value to fall. New counterparties are subject to a formal review and all of the approved counterparties are subsequently monitored and reviewed on an ongoing basis. The Company ensures that its counterparty risk and collateral management are actively managed.

- Counterparty risk in relation to depositary: The Company's assets are entrusted to the depositary for safekeeping. A note should be entered in the depositary's books highlighting that the assets belong to the Company. The securities held by the depositary should be kept separately from other securities/assets of the depositary, thereby reducing although not completely excluding the risk of non-return in the event of the depositary becoming bankrupt. The shareholders are therefore exposed to the risk of the depositary, should it become bankrupt, being unable to meet its obligation to return all of the Company's assets in full. Additionally, a Subfund's cash stocks held with the depositary may possibly not be kept separately from the depositary's own cash or that of other customers, with the result that the Subfund may not be classed as a privileged creditor in the event of the depositary becoming bankrupt.

- The depositary may not hold all of the Company's assets itself but may make use of a network of sub- depositaries, which may not belong to the same corporate group as the depositary. In cases in which the depositary is not liable, shareholders may possibly be exposed to the risk of a becoming bankrupt.

- A Subfund may invest in markets in which the deposit and/or settlement systems are not yet fully developed. The assets of the Subfunds traded on these markets and entrusted to these sub-depositaries may possibly be exposed to risk in cases in which the depositary is not liable.

- Risks associated with credit default ("CDS") transactions: The purchase of CDS protection allows the Company, by paying a premium, to protect itself against the risk of default by an issuer. In the event of default by an issuer, settlement can be effected in cash or in kind. In the case of a cash settlement, the

purchaser of the CDS protection receives from the seller of the CDS protection the difference between the nominal value and the attainable redemption amount. Where settlement is made in kind, the purchaser of the CDS protection receives the full nominal value from the seller of the CDS protection and in exchange delivers to him the security which is the subject of the default, or an exchange shall be made from a basket of securities. The detailed composition of the basket of securities shall be determined at the time the CDS contract is concluded. The events which constitute a default and the terms of delivery of bonds and debt certificates shall be defined in the CDS contract. The Company can if necessary sell the CDS protection or restore the credit risk by purchasing call options.

Upon the sale of CDS protection, the Subfund incurs a credit risk comparable to the purchase of a bond issued by the same issuer at the same nominal value. In either case, the risk in the event of issuer default is in the amount of the difference between the nominal value and the attainable redemption amount.

Besides the general counterparty risk (see "Counterparty risks", above), upon the concluding of CDS transactions there is also in particular a risk of the counterparty being unable to establish one of the payment obligations which it must fulfil. The different Subfunds which use credit default swaps will ensure that the counterparties involved in these transactions are selected carefully and that the risk associated with the counterparty is limited and closely monitored.

- Risks associated with credit spread swap ("CSS") transactions: Concluding a CSS transaction allows the Company, on payment of a premium, to share the risk of default by an issuer with the counterparty of the transaction concerned. A CSS is based on two different securities with differently rated default risks and normally a different interest rate structure. At maturity, the payment obligations of one or other party to the transaction depend on the differing interest rate structures of the underlying securities.

Besides the general counterparty risk (see "Counterparty risks", above), upon the concluding of CSS transactions there is also in particular a risk of the counterparty being unable to establish one of the payment obligations which it must fulfil.

- Risks associated with inflation swap transactions: The purchase of inflation swap protection helps the Company to hedge a portfolio either entirely or partially from an unexpectedly sharp rise in inflation or to draw a relative performance advantage therefrom. For this purpose, a nominal, non-inflation-indexed debt is exchanged for a real claim that is linked to an inflation index. When the transaction is arranged, the inflation expected at this point is accounted for in the price of the contract. If actual inflation is higher than that expected at the time the transaction was entered into and accounted for in the price of the contract, the purchase of the inflation swap protection results in higher performance; in the opposite instance it results in lower performance than if the protection had not been purchased. The functioning of the inflation swap protection thus corresponds to that of inflation-indexed bonds in relation to normal nominal bonds. It follows that by combining a normal nominal bond with inflation swap protection it is possible to construct synthetically an inflation-indexed bond.

On the sale of inflation swap protection the Subfund enters into an inflation risk which is comparable with the purchase of a normal nominal bond in relation to an inflation-indexed bond: If actual inflation is lower than that expected at the time the transaction was entered into and accounted for in the price of the contract, the sale of the inflation swap protection results in higher performance; in the opposite instance it results in lower performance than if the protection had not been purchased.

Besides the general counterparty risk (see "Counterparty risks", above), upon the conclusion of inflation swap transactions there is also in particular a risk of the counterparty being unable to establish one of the payment obligations which it must fulfil.

- Risks connected with contracts for difference (“CFD”). Unlike direct investments, in the case of CFDs the buyer may be liable for a considerably higher amount than that paid as collateral. The Company will therefore use risk management techniques in order to ensure that the Subfund concerned can sell the necessary assets at any time, so that the payments of redemption proceeds relating to redemption requests can be made and the Subfund can meet its obligations resulting from contracts for difference and other techniques and instruments.

- Other risks / derivatives: The use of derivative and other special investment techniques and financial instruments also entails the risk that the valuations of financial products will differ as a result of different

approved valuation methods (model risks) and the fact that there is no absolute correlation between derivative products and the underlying securities, interest rates, exchange rates and indexes. Numerous derivatives, particularly the OTC derivatives, are complex and are frequently open to subjective valuation. Inaccurate valuations can result in higher cash payment obligations to the counterparty or a loss in value for a Subfund. Derivatives do not always fully reproduce the performance of the securities, interest rates, exchange rates or indexes which they are designed to reflect. The use of derivative and other special investment techniques and financial instruments by a Subfund may therefore in certain circumstances not always be an effective means of achieving the Subfund's investment objective and may even prove counterproductive. Under certain circumstances, the use of derivatives exposes the Subfunds to higher risks. These risks may take the form of credit risk in relation to counterparties with which a Subfund enters into transactions, performance risk, the risk that the derivatives will not be sufficiently liquid, the risk of a mismatch between the change in value of the derivative and that of the underlying that the corresponding Subfund is looking to replicate, or the risk of higher transaction costs than would have been incurred from a direct investment in the underlying.

Securities Financing Transactions

At the time of preparation of this Prospectus, none of the Company's Subfunds were invested in securities financing transactions, in accordance with Regulation (EU) 2015/2365 on the transparency of securities financing transactions and of reuse and amending Regulation (EU) No 648/2012. Should this change in future, the Prospectus will be amended accordingly at the time of the next submission.

7. THE COMPANY

General information

The Company is established in the Grand Duchy of Luxembourg as a ”société d'investissement à capital variable“ (SICAV) under the current version of the 2010 Law. In accordance with Part I of the 2010 Law, the Company is authorised to perform collective investments in securities.

The Company was established on March 15, 1991 for an indefinite period.

The Company is registered under number B 36405 in the Luxembourg trade and companies’ register. The articles of association may be consulted and sent out on request. The articles of association were published in Luxembourg in the “Mémorial” on May 6, 1991. The articles of association were last amended on 30 June 2017 and published in the Recueil Electronique des Sociétés et Associations (“RESA”) in Luxembourg on 20 July 2017.

The registered office of the Company is 00, Xxxxx-Xxx, X-0000 Xxxxxxxxxx.

Minimum capital

The minimum capital of the Company corresponds in Swiss francs to the equivalent of EUR 1,250,000. If one or more Subfunds are invested in shares of other Subfunds of the Company, the value of the relevant shares is not to be taken into account for the purpose of verifying the statutory minimum capital. In the event that the capital of the Company falls below two-thirds of the minimum capital laid down by law, the Board of Directors of the Company is required to submit the question of liquidation of the Company to a general meeting of shareholders within forty (40) days. The general meeting may resolve the question of liquidation with a simple majority of the shareholders present/represented, with no quorum being required.

In the event that the capital of the Company falls below one-fourth of the minimum capital laid down by law, the Board of Directors of the Company is required to submit the question of liquidation of the Company to a general meeting of shareholders within forty (40) days. In this case, a liquidation may be resolved by one-fourth of the votes of the shareholders present/represented at the general meeting, with no quorum being required.

Liquidation/merger

Under the terms of Articles 67-1 and 142 of the 1915 Law, the Company may be liquidated with the approval of the shareholders. The liquidator is authorised to transfer all assets and liabilities of the Company to a Luxembourg UCITS against the issue of shares in the absorbing UCITS (in proportion to the Shares in the

Company in liquidation). Otherwise, any liquidation of the Company is carried out in accordance with Luxembourg law. Any liquidation proceeds remaining to be distributed to shareholders but which could not be paid out to them at the end of liquidation will be deposited at the Caisse de Consignation in Luxembourg in favour of the entitled person or persons, in accordance with Article 146 of the 2010 Law.

In addition, the Company may decide on or propose the liquidation of one or more Subfunds or the merger of one or more Subfunds with another Subfund of the Company or another UCITS in accordance with Directive 2009/65/EC, or with a subfund within such other UCITS, as described in more detail in the section ”Redemption of Shares“.

Independence of the Subfunds

The Company assumes liability in respect of third parties for the obligations of each Subfund only with the respective assets of the Subfund in question. In dealings among the shareholders each Subfund is treated as an independent unit and the obligations of each Subfund are assigned to that Subfund in the list of assets and liabilities.

Board of Directors

The articles of association contain no provisions with regard to the remuneration (including pensions and other benefits) of the Board of Directors. The expenses of the Board of Directors are reimbursed. Its remuneration must be approved by the shareholders of the Company at the general meeting.

8. CUSTODIAN

The Company has appointed State Street Bank Luxembourg S.C.A. (“SSB-LUX”) as Custodian Bank (the “Custodian Bank”) of the Company with responsibility for:

a) Custody of the assets,

b) Monitoring duties,

c) Cash flow monitoring

in accordance with applicable Luxembourg law, the relevant CSSF circular and other applicable mandatory provisions of the Regulation (hereinafter referred to as the “Luxembourg Regulation“ in the respective current version) and the Custodian Agreement, which was entered into between the Company and SSB-LUX (“Custodian Agreement”).

SSB-LUX is constituted in the legal form of a “société en commandite par actions”, a corporate partnership limited by Shares under Luxembourg law. Its registered office is located at 00, Xxxxxx Xxxx X. Xxxxxxx, X- 0000 Xxxxxxxxxx.

SSB-LUX was established in 1990 and is enrolled in the Luxembourg trade and companies’ register (R.C.S.) under the number B-32.771. It holds a banking licence in accordance with the Luxembourg law of April 5, 1993 on the financial sector and is specialised in custody, fund management and related services. Its share capital is over EUR 65 million.

On a) Custody of the assets

In accordance with the Luxembourg Regulation and the Custodian Agreement, the Custodian Bank is responsible for the safekeeping of the financial instruments that can be held in safekeeping and for the accounting and verification of ownership of the other assets.

Delegation

Furthermore, the Custodian Bank is authorized to delegate its custodian obligations under the Luxembourg Regulation to sub-custodians and to open accounts with sub-custodians, provided that (i) such delegation complies with the conditions laid down by the Luxembourg Regulation - and provided such conditions are observed; and (ii) the Custodian Bank will exercise all customary and appropriate care and expertise with regard to the selection, appointment, regular monitoring and control of its sub-custodians.

To b) Monitoring duties

In accordance with the Luxembourg Regulation and the articles of association of the Company, as well as with the Custodian Agreement, the Custodian Bank will:

(i) ensure that the sale, issue, redemption, switching and cancellation of the Company's shares are conducted in accordance with the Luxembourg Regulation and the articles of association of the Company;

(ii) ensure that the value of the Company's shares is calculated in accordance with the Luxembourg Regulation;

(iii) execute the Management Company’s instructions, provided they do not conflict with the Luxembourg Regulation and the articles of association of the Company;

(iv) ensure that in transactions concerning the Company's assets, any remuneration is remitted/forwarded to the Company within the customary time limits;

(v) ensure that the Company's income is recorded in the accounts in accordance with the Luxembourg Regulation and the articles of association of the Company.

To c) Cash flow monitoring

The Custodian Bank is obligated to perform certain monitoring duties with regard to cash flows as follows:

(i) reconciling all cash flows and conducting such reconciliation on a daily basis;

(ii) identifying cash flows which in its professional judgment are significant and in particular those which may possibly not be in keeping with the Company's transactions. The Custodian Bank will conduct its verification on the basis of the previous day's transaction statements;

(iii) ensuring that all bank accounts within the Company's structure have been opened in the name of the Company;

(iv) ensuring that the relevant banks are EU or comparable banking institutions;

(v) ensuring that the monies that have been paid by the shareholders have been received and recorded on bank accounts of the Company.

Current information on the Custodian, its duties, potential conflicts, a description of all depositary functions delegated by the Custodian, a list of delegates and sub-delegates and the disclosure of all conflicts of interest that may arise in connection with the delegation of duties are made available to the shareholders, upon request, by the Custodian. Furthermore, a list of delegates and sub-delegates is available at xxx.xxxxxxxxxxx.xxx/xxxxx/xxxxxx-xxxxxxxxx/xxxxxxxxxx/xxxxxxxxxxxxx.xxxx .

Conflicts of interest

The Custodian Bank is part of an international group of companies and businesses that, in the ordinary course of their business, act simultaneously for a large number of clients, as well as for their own account, which may result in actual or potential conflicts. Conflicts of interest arise where the Custodian Bank or its affiliates engage in activities under the Custodian agreement or under separate contractual or other arrangements. Such activities may include:

(i) providing nominee, administration, registrar and transfer agency, research, securities lending agent, investment management, financial advice and/or other advisory services to the Company;

(ii) engaging in banking, sales and trading transactions including foreign exchange, derivative, principal lending, broking, market making or other financial transactions with the Company, either as principal and in the interests of itself, or for other clients.

In connection with the above activities, the Custodian Bank or its affiliates:

(i) will seek to profit from such activities and are entitled to receive and retain any profits or compensation in any form and are not bound to disclose to, the Company, the nature or amount of any such profits or compensation including any fee, charge, commission, revenue share, spread, mark-up, mark-down, interest, rebate, discount, or other benefit received in connection with any such activities;

(ii) may buy, sell, issue, deal with or hold, securities or other financial products or instruments as principal acting in its own interests, the interests of its affiliates or for its other clients;

(iii) may trade in the same or opposite direction to the transactions undertaken, including based upon information in its possession that is not available to the Company;

(iv) may provide the same or similar services to other clients including competitors of the Fund;

(v) may be granted creditors’ rights by the Company which it may exercise.

The Company may use an affiliate of the Custodian Bank to execute foreign exchange, spot or swap transactions for the account of the Company. In such instances the affiliate shall be acting in a principal capacity and not as a broker, agent or fiduciary of the Company. The affiliate will seek to profit from these transactions and is entitled to retain and not disclose any profit to the Company. The affiliate shall enter into such transactions on the terms and conditions agreed with the Company.

Where cash belonging to the Company is deposited with an affiliate being a bank, a potential conflict arises in relation to the interest (if any) which the affiliate may pay or charge to such account and the fees or other benefits which it may derive from holding such cash as banker and not as trustee.

The Investment Manager or the Management Company may also be a client or counterparty of the Custodian Bank or its affiliates.

For its services, the Company pays to the custodian a remuneration based on the net asset value of the respective Subfund at the end of each month and payable monthly in arrears. In addition, the custodian is entitled to payment to recover expenses and the fees charged, in turn, by other correspondent banks.

SSB-LUX is part of a company operating globally. In connection with the settlement of subscriptions and redemptions and the fostering of business relations, data and information about customers, their business relationship with SSB-LUX (including information about the beneficial owner) as well as, to the extent legally permissible, information about business transactions may be transmitted to affiliated entities or groups of companies of SSB-LUX abroad, to its representatives abroad or to the management company or the company. These service providers and the management company or society are required to keep the information confidential and use it only for the purposes for which they have been made available to them. The data protection laws in foreign countries may differ from the Privacy Policy in Luxembourg and provide a lower standard of protection.

9. MANAGEMENT COMPANY AND DOMICILIARY PAYING AGENT

The Company is managed by GAM (Luxembourg) S.A. (the “Management Company”), which is subject to the provisions of Chapter 15 of the 2010 Law.

In addition, the Company is domiciled at the Management Company.

The Management Company was established on January 08, 2002 for an unlimited period. The corporate capital amounts to EUR 5,000,000. It is registered under number B-85.427 in the Luxembourg commercial and companies’ register, where copies of the articles of association are available for inspection and can be received on request. The articles of association were last amended on 31 December 2015, as published in the Mémorial in Luxembourg on 16 January 2016.

The registered office of the Management Company is 00, Xxxxx-Xxx, X-0000 Xxxxxxxxxx.

Xxxxxxx managing the Company, the Management Company administers further undertakings for collective investment

10. CENTRAL ADMINISTRATIVE, AND PRINCIPAL PAYING AGENT; REGISTRAR AND TRANSFER AGENT

SSB-LUX has been appointed to provide services as the central administrative agent, principal paying agent and registrar and transfer agent. In consideration of the services rendered, SSB-LUX receives a remuneration which is based on the net asset value of the respective Subfund each month, payable monthly in arrears.

11. GENERAL INFORMATION ON INVESTMENT MANAGEMENT AND INVESTMENT ADVICE

The Company and/or the Management Company have authorized various competent financial services providers to act in this capacity as investment managers (“Investment Managers"), investment advisors (“Investment Advisors”) and/or advisers (“Advisers”) for one or more Subfunds of the Company.

The Investment Managers, Investment Advisers and/or Advisers shall receive a fee for their work from the net asset value of the Subfund concerned, as detailed in the section “Fees and Costs”.

The Investment Managers and Investment Advisers may, as a matter of principle, make use of the assistance of affiliated companies in the performance of their duties, at their own expense and under their own responsibility and supervision, and are authorized to appoint sub-investment advisers and/or, with the consent of the Management Company, sub-investment managers.

The Management Company and the Investment Managers are not obliged to carry out transactions with any particular broker. Transactions may also be carried out using affiliated companies, provided their terms and conditions are comparable with those of other brokers or traders and regardless of the fact that they make a profit from such transactions. All transactions of this type are subject to the provisions relating to transactions between associated companies as described in the section „Investment limits“. Although low and competitive commissions are generally looked for, the cheapest brokerage fees or the most favourable margins will not be paid in every case.

11.1. INVESTMENT MANAGERS / INVESTMENT ADVISOR

The Investment Managers are authorized by right to make investments directly for the corresponding Subfund, taking into account the relevant investment objectives, policy and limits of the Company and under the ultimate supervision of the Management Company or the Board of Directors or the auditor(s) appointed by the Management Company. The Investment Advisers can make recommendations to the Management Company for investing the assets of the corresponding Subfunds, taking into account their investment objectives, policy and limits.

For the Subfunds of the Company, GAM Investment Management (Switzerland) AG, Xxxxxxxxxxx 000, X.X. Xxx, XX-0000 Xxxxxx, Xxxxxxxxxxx, has been appointed as Investment Manager. GAM Investment Management (Switzerland) AG was established in 1990 as a joint-stock company under Swiss law. It is today a subsidiary of GAM Holding AG, Zürich. GAM Investment Management (Switzerland) AG is a fund management company as defined by the Swiss Law on undertakings for collective investment and as such is supervised by the Swiss Financial Market Supervisory Authority (“FINMA”). FINMA approval covers in particular activities as a fund management company of Swiss UCIs, as a representative of foreign UCI(TS) in Switzerland and as portfolio manager.

12. PAYING AGENTS AND REPRESENTATIVES

The Company/Management Company has concluded agreements with various paying agents and/or representatives concerning the provision of certain administrative services, the distribution of Shares or the representation of the Company indifferent countries in which Shares are distributed. The fees charged by the paying agents and representatives may be borne by the Company as agreed in each case. Furthermore, the paying agents and representatives may be entitled to the reimbursement of all reasonable costs that have been duly incurred in connection with the performance of their respective duties.

The paying agents or (processing) establishments necessitated by the local regulations on distribution specified in the various distribution countries, for example correspondent banks, may charge the shareholder additional costs and expenses, in particular the transaction costs entailed by customer orders, in accordance with the particular institution's scale of charges.

13. DISTRIBUTORS

The Company/Management Company may, in accordance with the applicable laws, appoint distributors („Distributors“) responsible for the offering and selling of Shares of various Subfunds in all countries in which the offering and selling of such Shares is permitted. The Distributors are authorised to retain a selling fee (up to a maximum of 2%) for the Shares it markets, or else to waive all or part of the selling fee.

Distributors have been appointed, and further Distributors may be appointed.

A Distributor is authorised, taking into account the applicable national laws and rules and regulation in the country of distribution, to offer „A“, „B“ and „E“ Shares in connection with savings plans.

In this respect, the Distributor is authorised in particular:

(a) to offer savings plans of several years' duration, giving details of the conditions and features and of the initial subscription amount and the recurrent subscriptions;

(b) to offer, in respect of selling, switching and redemption fees, more favourable terms and conditions for savings plans than the maximum rates for the issue, switching and redemption of Shares otherwise quoted in this prospectus.

The terms and conditions of such savings plans, especially with regard to fees, are based on the law of the country of distribution, and may be obtained from the local Distributors offering such savings plans.

A Distributor is also authorised, taking into account the applicable national laws and rules and regulation in the country of distribution, to include Shares in a fund-linked life assurance as an investment component, and to offer Shares in such indirect form to the public. The legal relationship between the Company or Management Company, the Distributor/insurance company on the one hand and the investors/policyholders on the other hand is governed by the life assurance policy and the applicable laws.

The Distributors and SSB-LUX must at all times comply with the provisions of the Luxembourg law on the prevention of money laundering, and in particular the law of 7 July 1989, which amends the law of 19 February 1973 on the sale of drugs and the combating of drug dependency, the law of 12 November 2004, on the combat against money laundering and terrorist financing and of the law of 5 April 1993 on the financial sector, as amended, as well as other relevant laws passed by the government of Luxembourg or by supervisory authorities.

Subscribers of Shares must inter alia prove their identity to the Distributor and/or SSB-LUX or the Company, whichever accepts their subscription request. The Distributor and/or SSB-LUX or the Company must request from subscribers the following identity papers: in the case of natural persons a certified copy of the passport/identity card (certified by the Distributor or the local government administration); in the case of companies or other legal entities a certified copy of the certificate of incorporation, a certified copy of the extract from the commercial register, a copy of the latest published annual accounts, the full name of the beneficial owner.

The Distributor must ensure that the aforementioned identification procedure is strictly applied. The Company and the Management Company may at any time require confirmation of compliance from the Distributor or SSB- LUX. SSB-LUX checks compliance with the aforementioned rules in all subscription/redemption requests which it receives from Distributors in countries with non-equivalent money-laundering regulations. In case of doubt as to the identity of the party applying for subscription or redemption because of inadequate, inaccurate or lack of identification, SSB-LUX is authorized, without involving costs, to suspend or reject subscription/redemption requests for the reasons cited above. Distributors must additionally comply with all provisions for the prevention of money laundering which are in force in their own countries.

14. CO-MANAGEMENT

In order to reduce current administration costs and achieve broader asset diversification, the Company may decide to manage all or part of a Subfund’s assets together with the assets of other Luxembourg UCIs managed by the same Management Company or the same investment manager and established by the same promoter, or have some or all Subfunds co-managed. In the following paragraphs, the words “co-managed units” refer

generally to all Subfunds and units with or between which a given co-management agreement exists, and the words “co-managed assets” refer to the total assets of those co-managed units managed under the same agreement.

Under the co-management agreement, investment and realization decisions can be made on a consolidated basis for the co-managed units concerned. Each co-managed unit holds a part of the co-managed assets corresponding to its net asset value as a proportion of the total value of the co-managed assets. This proportional holding is applicable to each category of investments held or acquired under co-management, and its existence as such is not affected by investment and/or realization decisions. Additional investments will be allocated to the co-managed units in the same proportion, and sold assets deducted pro rata from the co- managed assets, held by each co-managed unit.

When new Shares are subscribed in a co-managed unit, the subscription proceeds will be allocated to the co- managed units in the new proportion resulting from the increase in the net asset value of the co-managed units to which the subscriptions have been credited, and all categories of investments will be changed by transferring assets from one co-managed unit to the other and thus adapted to the changed situation. Similarly, when Shares in a co-managed unit are redeemed, the required cash may be deducted from the cash held by the co- managed units accordingly, to reflect the changed proportions resulting from the reduced net asset value of the co-managed unit to which the redemptions were charged, and in such cases all categories of investments will be adapted to the changed situation. Shareholders should therefore be aware that a co-management agreement may cause the composition of the Subfund’s portfolio to be influenced by events caused by other co-managed units, such as subscriptions and redemptions. Provided there are not other changes, subscriptions of shares in a unit with which a Subfund is co-managed will lead to an increase in that Subfund’s cash. Conversely, redemptions of shares in a unit with which a Subfund is co-managed will lead to a reduction in that Subfund’s cash. However, subscriptions and redemptions may be held in the specific account opened for each co- managed unit outside the co-management agreement and through which subscriptions and redemptions must pass. The possibility of large payments and redemptions being allocated to such specific accounts, and of a Subfund ceasing to participate in the co-management agreement at any time, prevent changes in a Subfund’s portfolio caused by other co-managed units if these changes are likely to adversely affect the interests of the Subfund and the shareholders.

If a change in the composition of a Subfund’s assets as a result of redemptions or payments of charges and costs relating to another co-managed unit (i.e. not attributable to the Subfund) would cause a breach of the investment restrictions applying to that Subfund, the assets concerned will be excluded from the co- management agreement before the changes are carried out, so that they are not affected by the changes.

Co-managed assets of a Subfund may be co-managed only with assets which are to be invested in accordance with investment objectives and investment policy compatible with those of the Subfund’s co-managed assets, to ensure that investment decisions are fully compatible with the Subfund’s investment policy. Co-managed assets of a Subfund may be managed jointly only with assets for which the custodian bank also acts as custodian, to ensure that the custodian bank can fully comply with its functions and responsibilities under the 2010 Law . The custodian bank must always keep the Company’s assets separate from those of other co-managed units, and must therefore always be able to identify the Company’s assets. As co-managed units may be following an investment policy which is not completely the same as that of a Subfund, the joint policy applied may be more restrictive than that of the Subfund.

The Company may end the co-management agreement at any time and without prior notice.

Shareholders may contact the Company at any time for information on the percentage of assets which is co- managed, and the units with which such co-management exists at the time of their inquiry. Annual and semi- annual reports are also required to specify the composition and percentage proportions of co-managed assets.

15. DESCRIPTION OF SHARES

General

Shares in the Company have no par value. The Company only issues Shares for each Subfund in registered form. To the extent that bearer shares were issued previously, ownership of these bearer shares can be proved

by possession of the bearer Shares having the corresponding coupons. In principle, no physical Share certificates will be issued. A Share acknowledgement is issued and sent to the investor. Registered Shares are also issued in fractions, which are rounded up or down to three decimal places. In addition, within each Subfund it is possible to issue distributing and accumulating Shares. Distributing Shares entitle the shareholder to a dividend as determined at the general meeting of shareholders. Accumulating Shares do not entitle the shareholder to a dividend. When dividend payments are made, the dividend amounts are deducted from the net asset value of the distributing Shares. The net asset value of the accumulating Shares, on the other hand, remains unchanged.

Each Share grants a right to part of the profits and result of the Subfund in question. Unless provided for otherwise in the articles of association or by law, each Share entitles the shareholder to one vote, which he may exercise at the general meeting of shareholders or at other meetings of the Subfund in question either in person or through a proxy. The Shares do not include rights of priority or subscription rights. Nor are they now or will they in the future be associated with any outstanding options or special rights. The Shares are transferable without restriction unless the Company, in accordance with its articles of association, has restricted ownership of the Shares to specific persons or organisations („restricted category of purchasers“).

Immobilisation of bearer shares

The Luxembourg Law of 28 July 2014 on the mandatory deposit and immobilisation of bearer shares (Immobilisation Law) provides for a new regulation that will apply to physical securities (bearer shares) issued by the management company.

Within the scope of implementing the Immobilisation Law, BIL Banque Internationale à Luxembourg, société anonyme, whose registered office is at 00, xxxxx x'Xxxx, X-0000 Xxxxxxxxxx, was appointed depository for the safekeeping and registration of bearer shares. The holders of physical securities must deposit these with the depository by 17 February 2016 at the latest and register them under the name and address of the current owner at the time of deposit. Any claims to distributions and associated voting rights attached to bearer shares will be suspended in accordance with the Immobilisation Law and shall only be restored once the bearer shares in question are delivered to a securities deposit account managed by the bank or deposited with the depository stated above.

In accordance with the Immobilisation Law, units not deposited or registered when the prescribed legal deadline has passed shall be valued at the rate valid for 18 February 2016 and the corresponding amount shall be transferred to the Luxembourg Caisse de Consignation. Every shareholder affected can request payment of the amount apportioned to them until expiry of the statutory period of limitation. At the same time, the collected units are deleted.

As of 18 February 2016, the management company will therefore no longer act as a contact for the affected shareholders. Claims for payment of the deposited net asset values can only be made to the Luxembourg Caisse de Consignation.

Share categories

The Company’s Board of Directors has approved the issue of Share Categories with different minimum subscriptions, dividend policies and fee structures. Following Share Categories may be issued:

Share Categories	Description
“A“ Shares	distributing
“B“ Shares	accumulating
“C“ Shares	accumulating for “institutional investors“*
“Ca“ Shares	distributing for “institutional investors“*
“E“ Shares	accumulating for certain distributors*
“R“ Shares	accumulating for certain intermediaries*
“Ra“	distributing for certain intermediaries *

* as defined hereafter

“C“ and “Ca“ Shares are issued only to “institutional investors“ according to Article 174 of the 2010 Law – defined, in principle, as companies constituted as a corporate legal entity or equivalent legal form – holding these Shares either as part of their own business assets or under contract on behalf of institutional investors as defined above, or else reselling the Shares exclusively to institutional investors or using them on their own behalf and for account of third parties within the scope of discretionary portfolio management (re. minimum subscriptions, see the section “Issue and sale of Shares / Application procedure“ and “Fees and costs“).For entities incorporated in the EU, the definition of “institutional investors” includes all eligible counterparties and all clients considered per se to be professionals pursuant to Directive 2014/65/EU on markets in financial instruments (“MIFID- Directive”) who have not requested non-professional treatment.

“E“ Shares are issued exclusively to Distributors domiciled in Spain or in Italy and to other determined Distributors in other distribution markets, provided the Board of Directors of the Company has decided for the latter on a special authorisation for the distribution of the “E“ Shares. All other Distributors are not allowed to acquire “E“ Shares.

“R” and “Ra” Shares are available for specified intermediaries only, who are not allowed to accept and retain fees, commissions or any monetary or non-monetary benefits (except for minor non-monetary benefits) paid or provided by any third party or a person acting on behalf of a third party, be this (i) due to legal requirements or

(ii) due to the fact that they have concluded contractual agreement (e.g. individual discretionary portfolio management or advisory agreements with separate fee arrangements or other agreements) with their customers which exclude such payments.

16. ISSUE OF SHARES / APPLICATION PROCEDURE

General points about issuance

The Shares are offered for sale on each valuation day following the initial issue.

Subscription requests can either be sent to one of the Distributors, which will forward them to SSB-LUX, or directly to the Company in Luxembourg (or to SSB-LUX, registrar and transfer agent, 00, Xxxxxx X.X. Xxxxxxx, X-0000 Xxxxxxxxxx). The subscriber should instruct his bank to transfer the amount due to the applicable SSB- LUX foreign exchange account shown below to the payee, GAM Multicash, giving precise details of the identity of the subscriber(s), the Subfund(s) to which the subscription for Shares relates and, within each Subfund, whether the subscription relates to distributing or accumulating Shares. All subscriptions for Shares in Subfunds received by SSB-LUX no later than 15:00 Luxembourg local time (the cut-off time) on a valuation day (as defined in the section „Calculation of net asset value“) will be treated at the Issue Price determined on the following valuation day. Subscriptions received by SSB-LUX after this time are covered by the Issue Price of the valuation day after the following valuation day. To ensure punctual transmission to SSB-LUX, applications placed with Distributors in Luxembourg or abroad may be subject to earlier cut-off times for the delivery of subscription applications. These times can be obtained from the Distributor concerned.

The Company or the Management Company may set different cut-off times for certain groups of investors, for example, for investors in countries in which this is justified by a different time zone. If such times are set, the valid cut-off time must as a matter of principle be earlier than the time at which the net asset value in question is calculated. Different cut-off times may be agreed separately either with the distributors concerned or be published in an appendix to the full prospectus or another marketing document used in the countries concerned.

Hence, Shares are subscribed for an unknown net asset value (forward pricing).

Irrespective of this, the Company or the Management Company may instruct the Transfer Agent to deem subscription applications to have been received only when the total amount of the subscription has been received by the Custodian Bank ("Cleared funds settlement“). Comparable subscription applications received on the same valuation day are to be treated equally. The Issue Price applicable to subscriptions processed in accordance with this procedure shall be that of the valuation day after receipt of the subscription amount by the Custodian Bank.

Issue Price/Selling fees

The Issue Price is based on the net asset value per share on the relevant valuation day, rounded to two decimal places, plus any applicable selling fee charged by the Distributor or the Company. Further details of the Issue Price may be requested from the registered office of the Company.

The selling fees payable to a Distributor and expressed as a percentage of the net asset value or of the Issue Price may be up to 2%.

In the case of larger transactions, the Distributor may waive all or part of the selling fee to which it is entitled.

Minimum Subscription Amount

A minimum subscription amount per Subfund, as specified below, is required when subscribing to certain Share Categories for the first time.

Share Category	Minimum subscription amount per Subfund in EUR or the equivalent amount in the currency of the Share Category concerned
C and Ca Shares (“Shares for institutional investors”)	500 000,-

The Company's Board of Directors may at its discretion accept initial subscription applications for an amount lower than the stated minimum subscription amount. Subsequent subscriptions of the Share Categories listed above are not subject to minimum subscription amounts.

Payments

The value of the total amount of the subscription must be credited to one of the accounts below in the currency of the relevant Subfund no later than four (4) Luxembourg business days after the end of the initial subscription period during the period of the initial issue, or after this period, no later than four (4) Luxembourg business days after the applicable valuation day, or in accordance with any particular national regulations. The Company and the Management Company are entitled without further ado to re-process or retroactively refuse subscriptions for which the amount subscribed is not credited within the specified term.

However, if the Company or the Management Company have instructed the Transfer Agent to only consider subscriptions as received once the total amount subscribed has been credited to the Custodian (“Cleared funds settlement”), then the shareholders will be recorded in the register on such day on which the receipt of the amount subscribed is booked.

The subscriber should instruct his bank to transfer the amount due to the SSB-LUX currency account indicated below for the beneficiary, GAM MULTICASH, together with the exact identity of the subscriber(s), the Subfund(s) of which Shares are to be subscribed, and (if applicable) the currency and Share Category within the Subfund to be subscribed.

Payments in the respective currencies must have been credited to the following accounts until the day indicated above for this purpose. In case payments are credited late, the subscriber may be charged debit interest, if applicable:

Payments in the respective currencies must be made to the following accounts:

Currency	Correspondence Bank	Account number	for further credit
CHF	BOFACH2X (Bank of America Zurich)	XX00 0000 0000 0000 0000 0	GAM (Luxembourg) S.A.
EUR	BOFADEFX (Bank of America Frankfurt)	XX00 0000 0000 0000 0000 00	GAM (Luxembourg) S.A.
GBP	BOFAGB22 (Bank of America London)	XX00 XXXX 0000 0000 0000 00	GAM (Luxembourg) S.A.
USD	BOFAUS3N (Bank of America New York)	6550068052	GAM (Luxembourg) S.A.

After settlement of the subscription request, an order confirmation will be issued which will be sent to the shareholder on the day after settlement of the order, at the latest.

Contribution in kind

In exceptional cases, a subscription can, with the Company’s consent, take the form of a contribution in kind, in whole or in part, whereby the composition of the contribution in kind must be consistent with the investment objectives and policy as well as the investment limits of the respective Subfund. Furthermore, the valuation of the contribution in-kind must be confirmed independently by the Company’s auditor. The costs incurred in connection with in-kind contributions (mainly for the independent audit report) will be borne by the investors contributing in kind.

Multiple applicants

Where there is more than one joint applicant, the application must include the signatures of all applicants. The registrar is authorised to accept instructions from the first-named applicant in the application until receipt of a corresponding confirmation. In the case of savings plans, the Distributor/Company is required to treat all joint applicants equally with regard to their rights relating to the Shares.

Nominee Service

Investors can subscribe Shares directly from the Company. Investors may also purchase Shares in a Subfund by using the nominee services offered by the relevant Distributor or its correspondent bank. A Distributor or its correspondent bank having its registered office in a country with equivalent money-laundering regulations then subscribes and holds the Shares as a nominee in its own name but for the account of the investor. The Distributor or correspondent bank then confirms the subscription of the Shares to the investor by means of a letter of confirmation. Distributors that offer nominee services either have their registered office in a country with equivalent money-laundering regulations or execute their transactions through a correspondent bank having its registered office in a country with equivalent money-laundering regulations.

Investors who use a nominee service may issue instructions to the nominee regarding the exercise of votes conferred by their Shares as well as request direct ownership by submitting an appropriate request in writing to the relevant Distributor or custodian bank.

The Company draws investors’ attention to the fact that each investor can only assert his/her investor’s rights (in particular the right to take part in shareholders’ meetings) in their entirety directly against the Company if the investor him-/herself is enrolled in his/her own name in the Company’s register of shareholders. In cases where an investor makes his/her investment in the Company via an intermediary, which makes the investment in its own name but for the investor’s account, not all investor’s rights can necessarily be asserted by the investor directly against the Company. Investors are advised to obtain information on their rights.

16.1. APPLICATION AND CONFIRMATION

(a) In the case of joint applicants, the Company is authorised to accept instructions relating to voting rights, transfers and redemptions from the first-named applicant in the application and, where the Shares are distributing Shares, to make payment to the first-named applicant in the application unless it receives instructions to the contrary.

(b) A legal entity must submit its application under its own name through an authorised member of the Company, whose authority must be demonstrated.

(c) If an application or confirmation is signed by a person with power of attorney, the power of attorney must be included with the application.

(d) Notwithstanding (a), (b) and (c) an application may be accepted if it is signed by a bank or on behalf of or apparently on behalf of another natural person or legal entity.

(e) If an application is received in which it is not clear whether the application is for distributing or accumulating Shares, the Company will automatically issue accumulating Shares.

(f) Additional information for Investors in Italy: If not excluded by local provisions, subscription of shares may also be validated by means other than by a signed subscription form. This may be done by an

intermediary providing investment services under a written contract, in the name and on behalf of the investor, or in his own name and for the account of the investor.

16.2. GENERAL

Once the subscription application has been processed, an order confirmation will be issued, which will be sent to the shareholder no later than one day after the order has been executed to the address quoted by the applicant(s) on the application form (or to the first-named applicant in the case of joint applicants).

The Company retains the right to reject applications or to accept them only in part.

If an application is rejected in full or in part, the subscription amount or the corresponding balance is transferred to the (first-named) applicant at the risk of the authorised person(s)/organisations(s) within thirty (30) days of the decision of non-acceptance. The Company retains the right to withhold any overpaid subscription amounts until the final account is issued.

In addition, the Company or the Management Company may refuse to accept new applications from new investors for a specific period if this is in the interests of the Company and/or shareholders, including situations where the Company or a Subfund have reached a size such that they can no longer make suitable investments.

Subscriptions and redemptions should be made for investment purposes only. Neither the Company nor the Management Company nor SSB-LUX will permit market timing or any other excessive trading practices. Such practices may be detrimental to the performance of the Company or the Subfunds, thereby interfering with the management of the portfolio. To minimize these negative consequences, the Company, the Management Company and SSB-LUX reserve the right to refuse subscription and switching applications from investors whom they believe to be carrying out, or to have carried out, such practices or whose practices would adversely affect the other investors.

The Company may also compulsorily redeem the Shares of a shareholder engaging in or having engaged in such practices. It shall not be liable for any gain or loss resulting from such rejected applications or compulsory redemptions.

17. REDEMPTION OF SHARES

General points about redemption

Applications for redemption received by the Company or SSB-LUX, registrar and transfer agent, 00, Xxxxxx X.X. Xxxxxxx, X-0000 Xxxxxxxxxx by no later than 15:00 Luxembourg local time (the cut-off time) are treated at the Redemption Price of the following valuation day. To ensure punctual forwarding to SSB-LUX, applications placed with Distributors in Luxembourg or abroad may be subject to earlier cut-off times for the delivery of redemption applications. These times can be obtained from the Distributor concerned.

Hence, Shares are redeemed for an unknown net asset value (forward pricing).

A correctly submitted application for redemption is irrevocable, except in the case of and during the period of a suspension or postponement of redemptions.

Applications for redemption received by SSB-LUX after the time specified above are processed one valuation day later unless the Company, in receipt of applications for redemption corresponding to more than 10% of the net asset value of the relevant Subfund, decides to postpone all redemptions by a period not exceeding seven successive valuation days.

Once the redemption application has been processed, an order confirmation will be issued, which will be sent to the shareholder no later than one day after the order has been executed.

Payments are normally made in the currency of the relevant Subfund or in the reference currency of the respective Share Category within a maximum of five (5) bank business days in Luxembourg after the valuation day concerned.

The value of Shares at the time of redemption may be higher or lower than their purchase price, depending on the market value of the assets of the Company or of the particular Subfund at the time of purchase/redemption. All redeemed Shares are cancelled.

Redemption price

The price of each Share offered for redemption („Redemption Price“) is calculated according to the net asset value per Share of the Subfund concerned on the relevant valuation day, rounded to two decimal places, less any redemption fee where applicable.

For the Redemption Price to be paid, the Company must have received the redemption application form.

In the event that under extraordinary conditions the redemption application leads to one or more assets of the Subfund concerned having to be sold at below its/their value, the Board of Directors of the Company may decide that the differential amount (known as the “spread”) between the actual value and the selling value be charged proportionally to the investor filing the redemption application concerned, in favour of the Subfund. The amount debited may be determined by the Board of Directors at its due discretion and taking account of the interests of all shareholders. Shareholders shall be informed appropriately of any such measure that is taken.

The redemption price can be requested from the registered office of the Company or one of the Distributors or be consulted at xxx.xxxxx.xxx.xxx .

Redemption fee

If no selling fee has been charged (“no-load“), the Distributor is entitled to charge a redemption fee of up to 1% of the relevant net asset value per Share.

Payment in kind

In special cases, the Company's Board of Directors may decide to pay the redemption proceeds to a shareholder upon request in the form of a full or partial payment in kind. It must be ensured that all shareholders are treated equally and the valuation of the payment in kind must be confirmed independently by the auditor of the Company's annual report.

Redemption postponement

The Company is not obliged to redeem more than 10% of the currently issued Shares in a Subfund on one valuation day or within a period of seven (7) successive valuation days. For the purposes of this provision, the switching of Shares of a Subfund is deemed to constitute the redemption of the Shares. If, on any valuation day or over a period of seven (7) consecutive valuation days, the number of Shares for which redemption is requested is greater than indicated above, the Company may postpone the redemptions until the seventh valuation day thereafter. Such applications for redemption will take precedence over applications received subsequently.

If the calculation of the net asset value is suspended or redemption is postponed, Shares submitted for redemption will be redeemed on the next valuation day after suspension of calculation of the net asset value or postponement of redemption has ended, at the net asset value applicable on that day, unless the redemption request has previously been revoked in writing.

Liquidation of Subfunds

If, during a period of sixty (60) consecutive days, the total net asset value of all outstanding Shares of the Company is less then twenty-five million Swiss francs (CHF 25 million) or the equivalent in another currency, the Company may inform all shareholders in writing within three (3) months of any such situation that, following requisite notification, all Shares will be redeemed at the prevailing net asset value on the defined valuation day. If, during a period of sixty (60) consecutive days, the net asset value of a Subfund, for whatever reason, falls

below ten (10) million Swiss francs (CHF million) or the equivalent in another Subfund currency, or if the Board of Directors deems it necessary because of changes in the economic or political circumstances that affect the Subfund, the Board of Directors may redeem all, but not some, of the Shares of the Subfund concerned on the valuation day defined for this purpose at a Redemption Price which reflects the estimated realization and liquidation costs for closure of the Subfund concerned, without applying any other redemption fee.

The liquidation of a Subfund associated with the compulsory redemption of all affected Shares for reasons other than that indicated in the previous paragraph may only be carried out with the prior agreement of the shareholders of the Subfund to be liquidated or merged at a meeting of shareholders of the Subfund in question, convened in accordance with the regulations. Such a resolution may be passed with no quorum requirement and with a majority of 50% of Shares present/represented.

Any liquidation proceeds which could not be paid out to the shareholders after completion of the liquidation of a Sub-Fund will be deposited with the Caisse de Consignation in Luxembourg in favour of the beneficiary or beneficiaries, in accordance with article 146 of the 2010 Law and will be forfeited after thirty (30) years.

Merging of Subfunds

In addition, the Board of Directors may, once it has informed in advance the shareholders concerned in the manner required by law, merge a Subfund with another Subfund of the Company or with another UCITS in accordance with Directive 2009/65/EC, or with a subfund thereof.

A merger decided on by the Board of Directors, which is to be conducted in accordance with the provisions of section 8 of the 2010 Law, is binding on the shareholders of the Subfund concerned after expiry of a 30 -day period from the corresponding notification of the shareholders concerned. During this notification period the shareholders may return their shares to the Subfund without paying a redemption fee, with the exception of the sums retained by the Company to cover costs connected with disinvestments. The above-mentioned time-limit ends five (5) bank working days before the valuation day that is determining for the merger.

A merger of one or more Subfunds, as a result of which the SICAV ceases to exist must be resolved by the General Meeting and be recorded by the notary. No quorum is required for such decisions and a simple majority of the shareholders present or represented is sufficient.

Merger or liquidation of Share Categories

In addition, the Board of Directors may, once it has informed in advance the shareholders concerned, merge a Share Category with another Share Category of the Company, or liquidate said Share Category. A merger of Share categories is conducted on the basis of the net asset value on the valuation day that is determining for the merger and is confirmed independently by the Company’s auditor.

18. SWITCHING OF SHARES

Shareholders in each Subfund are entitled to switch some or all of their Shares for Shares in another Subfund on a valuation day which is valid for both Subfunds. All the qualification prerequisites and minimum subscription amounts (“Minimum Switching Value”) and the other conditions applicable to the original Share Category or the new Share Category shall apply for the Distributors and/or shareholders effecting a switch. The Company’s Board of Directors may at its discretion accept initial switching applications for an amount lower than the stated minimum switching amount.

To do this, a written application must be submitted directly to the Company or to SSB-LUX, registrar and transfer agent, 00, Xxxxxx X.X. Xxxxxxx, X-0000 Xxxxxxxxxx, or to a Distributor. The application must contain the following information: The number of Shares of the Subfund or Share category to be switched and the desired new Subfunds or Share categories and the value ratio according to which the Shares in one or more Subfunds or Share categories are to be divided if more than the desired Subfund(s) or Share categories are to be replaced. In addition, the provisions relating to the cut-off time and forward pricing (see the sections ”Issue and sale of Shares / Application procedure“ and ”Redemption of Shares“) must be observed.

The switching is based on the applicable net asset value per Share of the Subfund in question. The Company applies the following formula to calculate the number of Shares into which the shareholder would like to convert his holding:

A  [(B x C)  E] x F

where:

A	=	Number of Shares to be issued in the new Subfund;
B	=	Number of Shares in the Subfund originally held;
C	=	Redemption Price per Share of the Subfund originally held, less any selling costs;
D	=	Issue Price per Share of the new Subfund, plus reinvestment costs;
E	=	Switching fee, if any (max. 1% of net asset value) – whereby comparable switching requests on the same day are charged the same switching fee;
F	=	exchange rate; if the old and new Subfunds have the same currency the exchange rate is 1.

The Company will inform the shareholders concerned of details relating to the switch and will issue new confirmations.

19. DIVIDENDS

The Board of Directors proposes to the general meeting of shareholders a reasonable annual dividend payment for the distributing Shares in the Subfund, ensuring that the net asset value does not fall below the minimum of 1,250,000 Euro. Subject to the same limitation in respect of the minimum net asset value, the Board of Directors may also fix interim dividends. In the case of accumulating Shares, no dividend payments are made. Instead, the values allocated to the accumulating Shares are reinvested for the benefit of the shareholders holding them.

The dividends fixed are published on xxx.xxxxx.xxx.xxx and as the case may be, in other media designated by the Company from time to time.

Distributions take place, in principle, for the annually distributing A, Ca and Ra Shares within one (1) month from the fixing of the dividend in the currency of the Subfund or Share Category concerned. At the request of shareholders holding distributing Shares, the dividends may also be paid in another currency established by the Management Company using the exchange rates applicable at the time and at the expense of these shareholders.

Dividends for distributing bearer Shares are paid on submission of the called up coupons (where applicable) and those for distributing registered Shares are paid to the investors entered in the Company's book of registered shareholders. Further details with regards to dividends for distributing bearer Shares are outlined in the section 15 “Description of Shares”.

Claims for dividends which have not been asserted within five (5) years from distribution, shall be forfeited and revert to the Subfund in question.

20. CALCULATION OF NET ASSET VALUE

The net asset value of a Subfund and the net asset value of the Shares (as defined in the section ”Description of Shares“) issued in the Subfund, are determined in the applicable currency on every valuation day – as defined below – apart from in the cases of suspension as described in the section ”Suspension of calculation of net asset value, and of the issue, redemption and switching of Shares“. The valuation day for each Subfund will be each bank business day in Luxembourg which is not a normal public holiday for the stock exchanges or other markets which represent the basis for valuation of a major past of the net assets of the corresponding Subfund, as determined by the Company (“Valuation Day”). The total net asset value of a Subfund represents the market value of its assets less its liabilities (the “assets of the Subfunds”). The net asset value of a Share of a Share

Category is determined by dividing the total of all assets of the Subfund that are allocated to this category, minus all the liabilities allocated to this category, by the number of outstanding Shares of the same Share Category. The net asset values of the Subfunds are calculated in accordance with the valuation regulations and guidelines (”valuation regulations“) laid down in the articles of association and issued by the Board of Directors.

The valuation of securities held by a Subfund and listed on a stock exchange or on another regulated market is based on the last known listing price on the principal market on which the securities are traded, using a procedure for determining prices accepted by the Board of Directors.

The valuation of securities whose listing price is not representative and all other eligible assets (including securities not listed on a stock exchange or traded on a regulated market) is based on their probable realization price determined with care and in good faith by or, if applicable, under the supervision of the Board of Directors.

All assets and liabilities in a currency other than that of the Subfund in question are converted using the exchange rate determined at the time of valuation.

The net asset value determined per Share in a Subfund is considered final and binding once it is confirmed by the Board of Directors or an authorised member of the Board of Directors/authorised representative of the Board of Directors, except in the case of a manifest error.

In its annual reports, the Company must include audited consolidated annual reports for all Subfunds in Swiss Francs.

If, in the opinion of the Board of Directors, and as a result of particular circumstances, the calculation of the net asset value of a Subfund in the applicable currency is either not reasonably possible or is disadvantageous for the shareholders in the Company, the calculation of the net asset value, the Issue Price and the Redemption Price may temporarily be carried out in another currency.

Valuation of the derivatives and structured products used in any of the Subfunds is performed on a regular basis by use of the mark-to-market principle, in other words at the last available price.

21. SUSPENSION OF CALCULATION OF NET ASSET VALUE, AND OF THE ISSUE, REDEMPTION AND SWITCHING OF SHARES

The Company may temporarily suspend the calculation of the net asset value of each Subfund and the issue, redemption and switching of Shares of a Subfund in the following circumstances:

(a) where one or more stock exchanges or other markets which are the basis for valuing a significant part of the net asset value are closed (apart from on normal public holidays), or where trading is suspended;

(b) where in the opinion of the Board of Directors of the Company it is impossible to sell or to value assets as a result of particular circumstances;

(c) where the communication technology normally used in determining the price of a security of the Subfund fails or provides only partial functionality;

(d) where the transfer of monies for the purchase or sale of investments of the Company is impossible;

(e) in the event of a merger of a Subfund with another Subfund or with another UCITS (or a subfund thereof), if this appears justified for the purpose of protecting the shareholders;

(f) if owing to unforeseeable circumstances a large volume of redemption applications has been received and, as a result, the interests of the shareholders remaining in the Sub-Fund are endangered in the opinion of the Board of Directors; or

(g) in the case of a resolution to liquidate the Company: on or after the date of publication of the first convening of a general meeting of shareholders for the purpose of such resolution.

The Company’s articles of association provide that the Company must immediately suspend the issue and switching of Shares when an event resulting in liquidation occurs or such is required by the CSSF. Shareholders who have offered their Shares for redemption will be notified of any suspension in writing within seven (7) days, and of the ending of suspension immediately.

22. FEES AND COSTS

Fee structure

For the activity of the Management Company, the custodian, the central administration agent, the principal paying agent, the registrar and transfer agent, the Investment Manager or Investment Adviser, the paying agents, the representatives and distributors (if applicable), as well as for additional advisory services and support activities, fees and, where applicable, additional costs will be charged to the respective Subfunds.

The fees are calculated on each valuation day and are payable monthly in arrears.

Management Fee

The Management Fee (“Management Fee”) serves as remuneration (a) for the Investment Managers and/or investment advisors and (b) for distributors, together in each case with associated support services. All or part of the Management Fee may be paid to distributors, placement agents and similar financial intermediaries as commission, retrocession or rebate.

The Management Fee may be charged by the Management Company at different rates for individual Subfunds and/or share categories within a given Subfund or may be waived in full. The annual maximum Management Fee is shown in the table below.

Servicing Fee

In addition, a servicing fee (“Servicing Fee”) will be debited by the Management Company to each Subfund and/or share category. The Servicing Fee constitutes remuneration for the following services rendered by the Management Company or its appointees and delegates:

 Custody and Administration Services: business activities in accordance with custody and sub-custody services, registrar and transfer agency, central administration (fund administration, fund accounting), principal paying agency;

 Operational Management: Remuneration of the Management Company for the operational management and supervision of the business activities of the Company; Risk Management; remuneration and expenses of the Board of Directors of the Company; expenses in relation to the convening of general meetings of shareholders; notary fees;

 Sales and Marketing: Sales and marketing expenses, further distribution support, licence fees;

 Regulatory: Public charges: taxes (particularly the taxe d’abonnement); mandatory fund documents (prospectus, KIID, annual and semi-annual reports); auditing fees; costs associated with registration and reporting to supervisory authorities in different distribution countries; listing fees; publication costs for NAVs and corporate actions;

 Other Services: Legal and tax services; paying agents and representatives; insurance premiums; and any other costs incurred by the Management Company on behalf of the Company.

The Servicing Fee may be charged by the Management Company at different rates for individual Subfunds and/or share categories within a given Subfund or may be waived in full. The annual maximum Servicing Fee is shown in the table below.

Both, Management Fee and the Servicing Fee, will be calculated on the basis of the net asset value of the respective Subfund and/or share category and debited to such Subfund and/or such share category on each Valuation Day (as defined in the section “Calculation of net asset value”), and will be payable monthly in arrears.

The Management Fee and the Servicing Fee together constitute the Total Expense Ratio (TER) of the respective Subfund and/or share category.

As shown in the table below, the Management Fee and the Servicing are both capped. Any costs exceeding this cap are borne by the Management Company.

Subfunds	Maximum fee p.a. in % of the net asset value (NAV)
Subfunds	Share category	Management Fee	Servicing Fee	Total Expense Ratio (TER)
MONEY MARKET DOLLAR	A/B	0.50%	0.30%	0.80%
	C/Ca**)	0.30%	0.20%	0.50%
	E*)	0.75%	0.30%	1.05%
	R/Ra**)	0.30%	0.20%	0.50%
MONEY MARKET EURO	A/B	0.50%	0.30%	0.80%
	C/Ca**)	0.30%	0.20%	0.50%
	E*)	0.75%	0.30%	1.05%
	R/Ra**)	0.30%	0.20%	0.50%
MONEY MARKET STERLING	A/B	0.50%	0.30%	0.80%
	C/Ca**)	0.30%	0.20%	0.50%
	E*)	0.75%	0.30%	1.05%
	R/Ra**)	0.30%	0.20%	0.50%
MONEY MARKET SWISS FRANC	A/B	0.50%	0.30%	0.80%
	C/Ca**)	0.30%	0.20%	0.50%
	E*)	0.75%	0.30%	1.05%
	R/Ra**)	0.30%	0.20%	0.50%

*) The Management Fee contains an additional distribution fee capped at 0.25% p.a.

**) Regarding the distribution, offering or holding of C and Ca Shares, the Company will not pay any commission to Distributors for public distribution.

Regarding the distribution, offering or holding of R and Ra Shares, the intermediaries will therefore not be paid any fees, commissions or any monetary or non-monetary benefits (except for minor non-monetary benefits).

Investments in Target Funds

Subfunds that may invest in other existing UCIs and UCITS (target funds) as part of their investment policy can incur charges both at the level of the target funds and at that of the investing Subfund. If a Subfund acquires shares of target funds that are managed directly or indirectly by the management company itself, or by a company to which the latter is linked by common management or control or by a significant direct or indirect shareholding (“related target funds”), no selling fee or redemption fees may be charged for the scope of such investments when these shares are subscribed or redeemed.

Incentives

The Management Company, individual employees of the latter or outside service providers may under certain circumstances receive or grant pecuniary or other advantages which could, as the case may be, be regarded as incentives. The main provisions of the relevant agreements on fees, commissions, and/or gratifications offered or granted in non-pecuniary form are available for inspection in summary form at the registered office of the Company. Details are available on request from the Management Company.

23. TAXATION

The following summary is based on the law and the rules and regulations currently valid and applied in the Grand Duchy of Luxembourg, and are subject to changes in the course of time.

23.1. COMPANY

Luxembourg

The Company is subject to Luxembourg tax jurisdiction. Under Luxembourg law and the current practice, the Company is subject neither to income tax nor to any tax on capital gains in respect of realised or unrealised valuation profits, neither are distributions carried out by the Company currently subject to Luxembourg withholding tax. No taxes are payable in Luxembourg on the issue of Shares.

The Company is subject to an annual tax of 0.05% of the net asset value as valued at the end of each quarter, and which is payable quarterly. Subfunds of the Company, which invest exclusively in deposits and money- market instruments within the meaning of the tax legislation (currently MONEY MARKET DOLLAR, MONEY MARKET EURO, MONEY MARKET STERLING, MONEY MARKET SWISS FRANC) are subject to the reduced

tax rate of 0.01% per annum of their net asset value. To the extent that parts of the Company’s assets are invested in other Luxembourg UCITS and/or UCI which are subject to the tax, such parts are not taxed.

This classification is based on the Company’s understanding of the current legal situation. This legal situation may change, even with retrospective effect, which may result in a tax of 0.05% being applied, even with retrospective effect.

The Company is subject to a net asset tax ("NAT") in Belgium for Subfunds that are registered for distribution with the local supervisory authority in that that country, the "Autorité des services et marchés financiers". The NAT is currently 0.0925% and is levied on the portion of the net asset value of the relevant Subfund which as at

31 December of each calendar year was actively being offered to Belgian residents by Belgian financial intermediaries.

In general

Capital gains and income from dividends, interest and interest payments which the Company generates from its investments in other countries may be subject to a non-recoverable withholding tax or capital gains tax of different amounts in such countries. It is often not possible for the Company to take advantage of tax breaks due to existing double taxation agreements between Luxembourg and these countries or because of local regulations. Should this situation change in future and a lower tax rate result in tax refunds to the Company, the net asset value of the Company as at the original time the tax was withheld will not be recalculated; instead the repayments will be made indirectly pro rata to the existing shareholders at the time the refund is made.

23.2. SHAREHOLDERS

Luxembourg

Under Luxembourg law and current practice, shareholders in Luxembourg are not subject to capital gains tax, income tax, gifts tax, inheritance tax or other taxes (with the exception of shareholders domiciled or resident or having their permanent establishment in Luxembourg, as well as former residents of Luxembourg, if they hold more than 10% of Company’s shares).

Automatic exchange of financial information in the field of taxation

Many countries, including Luxembourg and Switzerland, have already concluded agreements on the automatic exchange of information (AEOI) with regard to taxation or are considering concluding such agreements. To this end, a reporting standard has been coordinated within the OECD. This so-called common reporting standard (CRS) forms the framework for the exchange of financial information in the field of taxation between countries.

CRS obliges financial institutions to gather and, as the case may be, report information on financial assets which are kept under custody or administered across the border for taxpayers from countries and territories which participate in the AEOI. This information will be exchanged between the participating countries’ tax authorities. The member countries of the European Union have decided to implement the AEOI and CRS within the EU by

means of Directive 2014/107/EU of the Council of 9 December 2014 amending Directive 2011/16/EU as regards mandatory automatic exchange of information in the field of taxation.

Luxembourg has implemented Directive 2014/107/EU by enacting the Law of 18th December 2015 on the automatic exchange of information regarding financial accounts (the “Financial Accounts Information Exchange Law”) and substantiated by further regulations. Accordingly, from 2016 on, in-scope Luxembourg financial institutions will collect certain investor information relating to the holders of financial accounts (as well as, as the case may be, relating to persons controlling account holders) and, from 2017, will begin reporting this information relating to the reportable accounts to Luxembourg tax authorities. These reports will be transferred by the Luxembourg tax authorities to certain foreign tax authorities, in particular within the EU.

According to the assessment of the Board of Directors, the Company is subject to the Financial Accounts Information Exchange Law in Luxembourg. The Company has been classified as “reporting financial institute” (investment entity) according to the Financial Accounts Information Exchange Law. Therefore, the Company gathers and, as the case may be, reports information relating to account holders pursuant to the principles laid down above.

The Company reserves the right to refuse applications for the subscription of Shares or compulsorily redeem Shares if the information provided by the applicant respectively investors does not meet the requirements of Directive 2014/107/EU and, respectively, of the Financial Accounts Information Exchange Law. Moreover, to fulfil their obligations in Luxembourg under the Financial Accounts Information Exchange Law, respectively, under Directive 2014/107/EU, the Company, the Management Company or the nominees may require, depending on the circumstances, additional information of the investors in order to comply or dispense with their fiscal identification and, as the case may be, reporting duties.

Applicants and investors are made aware of the Company’s duty to transmit information on reportable accounts and their holders as well as, as the case may be, of controlling individuals to the Luxembourg tax authorities, which, depending on the circumstances, may forward this information to certain tax authorities in other countries with which a treaty on the automatic exchange of information has been concluded.

The scope and application of the AEOI or CRS may vary from country to country and the applicable rules may change. It is the responsibility of investors to seek advice on taxes and other consequences (including on the exchange of tax information) which may result from the subscription, ownership, return (redemption), switching and transfer of Shares, as well as distributions, including any regulations regarding the control on the movement of capital.

23.3. FOREIGN ACCOUNT TAX COMPLIANCE ACT (“FATCA”) OF THE UNITED STATES OF AMERICA (“US”)

The US have introduced FATCA to obtain information with respect to foreign financial accounts and investments beneficially owned by certain US taxpayers.

In regards to the implementation of FATCA in Luxembourg, the Grand Duchy of Luxembourg has signed a Model 1 intergovernmental agreement with the US on 28 March 2014 (the "Lux IGA"), which has been transposed into Luxembourg legislation according to the terms of the Law of 24th July 2015 (“Lux IGA Legislation”). Under the terms of the Lux IGA, a Luxembourg resident financial institution (“Lux FI”) will be obliged to comply with the provisions of the Lux IGA Legislation, rather than directly complying with the US Treasury Regulations implementing FATCA. A Lux FI that complies with the requirements of the Lux IGA Legislation will be treated as compliant with FATCA and, as a result, will not be subject to withholding tax under FATCA (“FATCA Withholding”), provided the Lux FI properly certifies its FATCA status towards withholding agents.

The Board of Directors considered the Company to be a Lux FI that will need to comply with the requirements of the Lux IGA Legislation and classified the Company and its sub-funds as Sponsored Investment Entities under the Lux IGA. Sponsored Investment Entities qualify for a deemed-compliant status and constitute a Non- Reporting Lux FI under the Lux IGA.

For Sponsorship purposes under the Lux IGA, the Company appointed the Management Company as Sponsoring Entity, which registered in this capacity on the FATCA online registration portal of the US Internal Revenue Service (“IRS”) and agreed to perform the due diligence, withholding, and reporting obligations on behalf of the Company (“Sponsoring Entity Service”).

As determined in the Lux IGA, the Company retains the ultimately responsibility for ensuring that it complies with its obligations under the Lux IGA Legislation, notwithstanding the appointment of the Management Company to act as Sponsoring Entity to the Company.

In the performance of the Sponsoring Entity Service, the Management Company may use the assistance and contribution of sub-contractors, including the Company’s Registrar and Transfer Agent.

Under the Lux IGA Legislation, the Management Company will be required to report to the Luxembourg Tax Authority certain holdings by and payments made to certain direct and indirect US investors in the Company, as well as investors that do not comply with the terms of FATCA or with an applicable Intergovernmental Agreement, on or after 1 July 2014 and under the terms of the Lux IGA, such information will be onward reported by the Luxembourg Tax Authority to the IRS.

Investors not holding investments in the Company directly as shareholders (i.e. legal holder of records) but via one or several nominees, including but not limited to distributors, platforms, depositaries and other financial intermediaries (“Nominees”), should inquire with such Nominees in regard to their FATCA compliance in order to avoid suffering from FATCA information reporting and/ or potentially withholding.

Additional information may be required by the Company, the Management Company or Nominees from investors in order to comply with their obligations under FATCA or under an applicable Intergovernmental Agreement with the US, e.g. to perform or refrain from information reporting and/ or potentially withholding, as applicable.

The Company reserves the right to refuse applications for the subscription of shares or to impose a compulsory redemption of shares if the information provided by the applicant or investor does not meet the requirements of the Company for the fulfilment of its obligations under the Lux IGA or the Lux IGA regulations.

The scope and application of FATCA Withholding and information reporting pursuant to the terms of FATCA and the applicable Intergovernmental Agreements may vary from country to country and is subject to review by the US, Luxembourg and other countries, and the applicable rules may change. Investors should contact their own tax or legal advisers regarding the application of FATCA to their particular circumstances.

24. GENERAL MEETING OF SHAREHOLDERS AND REPORTING

The annual general meeting of shareholders of the Company takes place in Luxembourg every year at 14:00 on October 20 of each year. If this day is not a bank business day in Luxembourg, the general meeting takes place on the following bank business day. Other extraordinary general meetings of shareholders of the Company or meetings of individual Subfunds or their Share Categories may be held in addition. Invitations to the general meeting of shareholders and other meetings are issued in accordance with Luxembourg law and the current Articles of Association. They contain information about the place and time of the general meeting, the requirements for attending, the agenda and, if necessary, the quorum requirements and majority requirements for resolutions.

Furthermore, the invitation to attend the meeting may provide that the quorum and majority requirements be established on the basis of the Shares which have been issued and are outstanding on the fifth day preceding the general meeting. In this case a shareholder’s rights to take part in and vote at a general meeting will be determined according to the number of shares he/she owns at that point in time.

The Company’s financial year begins on 1st July and ends on 30th June of the following year. The annual financial report, which contains the Company’s, respectively Subfund's, audited consolidated annual report, is available at the Company’s registered office no later than fifteen (15) days before the annual general meeting. Un-audited semi-annual reports are available at the same place no later than two (2) months after the end of the half year in question. Copies of these reports may be obtained from the national representatives and from SSB- LUX.

25. APPLICABLE LAW, JURISDICTION

Any legal disputes between the Company, the shareholders, the custodian bank, the Management Company, the principal paying and administrative agent, the registrar and transfer agent, the Investment Managers, the Investment Advisers, the national representatives and any distribution agents will be subject to the relevant jurisdiction of the Grand Duchy of Luxembourg. The applicable law is Luxembourg law. However, the above entities may, in relation to claims from shareholders from other countries, accept the jurisdiction of those countries in which Shares are offered and sold.

26. REMUNERATION POLICY

In accordance with Directive 2009/65/EC, as amended by Directive 2014/91/EU (together the „UCITS Directive“), the Management Company has implemented a remuneration policy pursuant to the principles laid down in Article 14(b) of the UCITS Directive. This remuneration policy shall be consistent with and shall promote sound and effective risk management and shall focus on the control of risk-taking behaviour of senior management, risk takers, employees with control functions and employees receiving total remuneration that falls within the remuneration bracket of senior management and risk takers whose professional activities have a material impact on the risk profiles of the Company and the Subfunds.

In line with the provisions of the UCITS Directive and the guidelines issued by ESMA, each of which may be amended from time to time, the Management Company applies its remuneration policy and practices in a manner which is proportionate to its size and that of the Company, its internal organisation and the nature, scope and complexity of its activities.

Entities to which investment management activities have been delegated in accordance with Article 13 of the UCITS Directive are also subject to the requirements on remuneration under the relevant ESMA guidelines unless such entities and their relevant staff are subject to regulatory requirements on remuneration that are equally as effective as those imposed under the relevant ESMA guidelines.

This remuneration system is established in a remuneration policy, which fulfils following requirements:

a) The remuneration policy is consistent with and promotes sound and effective risk management and discourages risk-taking behaviour.

b) The remuneration policy is in line with the Company’s strategy, objectives, values and interests of the GAM Group (including the Management Company and the UCITS which it manages, as well as the UCITS’ investors) and it comprises measures to prevent conflicts of interest.

c) The assessment of performance is set in a multi-year framework.

d) Fixed and variable components of total remuneration are appropriately balanced and the fixed component represents a sufficiently high proportion of the total remuneration to allow the operation of a fully flexible policy on variable remuneration components, including the possibility to pay no variable remuneration component.

Further details relating to the current remuneration policy of the Management Company are available on xxx.xxxxx.xxx.xxx. This includes a description of how remuneration and benefits are calculated and the identity of persons responsible for awarding the remuneration and benefits as well as the identification of the members of the remuneration committee. A paper copy will be made available upon request and free of charge by the Management Company.

27. GENERAL CONFLICTS ASSOCIATED WITH THE COMPANY

GAM (which, for purposes of this “Conflicts of Interest” section, shall mean, collectively, GAM Holding AG, the GAM Investment Managers within the GAM Group and its affiliates, directors, partners, trustees, managers, members, executives and employees) provides investment services to institutions, intermediaries, private clients and charities from financial centres around the world. As such, GAM provides a wide range of financial services to a substantial and diversified client base. In those and other capacities, GAM advises clients in a wide variety

of markets and transactions and purchases, sells, holds and recommends a broad array of investments (and may do so for its own accounts) and for the accounts of clients, through client accounts and the relationships and products it sponsors, manages and advises (such GAM or other client accounts (including the Company), relationships and products collectively, the “Accounts”). GAM’s activities and dealings may affect the Company in ways that may disadvantage or restrict the Subfund and/or benefit GAM or other Accounts.

The following are descriptions of certain conflicts of interest and potential conflicts of interest that may be associated with the financial or other interests that a GAM Investment Manager and GAM may have in transactions effected by, with, and on behalf of the Company.

The sale of shares and the allocation of investment opportunities, financial and other interests may incentivise GAM to promote the sale of shares

GAM and its personnel have interests in promoting sales of Shares in the Company, and the compensation from such sales may be greater than the compensation relating to sales of interests in other Accounts. Therefore, GAM and its personnel may have a financial interest in promoting Shares in the Subfund over interests in other Accounts.

The relevant GAM Investment Manager may simultaneously manage Accounts for which the GAM Investment Manager receives greater fees or other compensation (including performance-based fees or allocations) than they receive in respect of the Company. The simultaneous management of Accounts that pay greater fees or other compensation and the Company may create a conflict of interest as the GAM Investment Manager may have an incentive to favour Accounts with the potential to receive greater fees. For instance, the GAM Investment Manager may be faced with a conflict of interest when allocating scarce investment opportunities given the possibly greater fees from Accounts that pay performance-based fees. To address these types of conflicts, the GAM Investment Manager has adopted policies and procedures under which they will allocate investment opportunities in a manner that they believe is consistent with their regulatory and fiduciary obligations as a GAM Investment Manager.

Conflicts Arising from GAM’s Financial and Other Relationships with Intermediaries

GAM and the Company may make payments to financial intermediaries and to salespersons to promote the Company. These payments may be made out of GAM assets or amounts payable to GAM. These payments may create an incentive for such persons to highlight, feature or recommend the Company.

Allocation of Investment Opportunities Among the Company and Other Accounts

The relevant GAM Investment Manager may manage or advise multiple Accounts (including Accounts in which GAM and its personnel may have an interest) that have investment objectives that are similar to the Company and that may seek to make investments or sell investments in the same securities or other instruments, sectors or strategies as the Company. This may create potential conflicts, particularly in circumstances where the availability of such investment opportunities is limited (e.g., in local and emerging markets, high yield securities, fixed income securities, regulated industries, real estate assets, primary and secondary interests in alternative investment funds and initial public offerings/new issues) or where the liquidity of such investment opportunities is limited.

To address these potential conflicts, GAM has developed allocation policies and procedures that provide that GAM personnel making portfolio decisions for Accounts will make purchase and sale decisions for, and allocate investment opportunities among, Accounts consistent with the relevant GAM Investment Manager’s fiduciary obligations. These policies and procedures may result in the pro rata allocation (on a basis determined by the relevant GAM Investment Manager) of limited opportunities across eligible Accounts managed by a particular portfolio management team, but in other cases the allocations may reflect other factors as described below. Accounts managed by different portfolio management teams may be viewed separately for allocation purposes. There will be cases where certain Accounts receive an allocation of an investment opportunity when the Company does not.

Allocation-related decisions for the Company and other Accounts may be made by reference to one or more factors, including without limitation: the Account’s investment strategy or style, risk profile, objectives, guidelines and restrictions (including legal and regulatory restrictions affecting certain Accounts or affecting holdings across Accounts) and cash and liquidity considerations. The application of these considerations may cause

differences in the performance of Accounts that have strategies similar to those of the Company. In addition, in some cases the GAM Investment Manager may make investment recommendations to Accounts where the Accounts make investments independently of the GAM Investment Manager. In circumstances in which there is limited availability of an investment opportunity, if such Accounts invest in the investment opportunity prior to a Subfund, the availability of the investment opportunity for the relevant Subfund will be reduced irrespective of the GAM policies regarding allocation of investments.

The relevant GAM Investment Manager may, from time to time, develop and implement new trading strategies or seek to participate in new trading strategies and investment opportunities. These strategies and opportunities may not be employed in all Accounts or employed pro rata among Accounts where they are employed, even if the strategy or opportunity is consistent with the objectives of such Accounts.

GAM and the GAM Investment Manager’ Activities on Behalf of Other Accounts

The GAM Investment Manager’s decisions and actions on behalf of the relevant Subfund may differ from those on behalf of other Accounts. Advice given to, or investment or voting decisions made for, one or more Accounts may compete with, affect, differ from, conflict with, or involve timing different from, advice given to or investment decisions made for the Company.

Transactions by such Accounts may involve the same or related securities or other instruments as those in which the Company invests, and may negatively affect the Company or the prices or terms at which a Subfund’s transactions may be effected. A Subfund and Accounts may also vote differently on or take or refrain from taking different actions with respect to the same security, which may be disadvantageous to the Subfund.

GAM, on behalf of one or more Accounts and in accordance with its management of such Accounts, may implement an investment decision or strategy ahead of, or contemporaneously with, or behind similar investment decisions or strategies made for the relevant Subfund. The relative timing for the implementation of investment decisions or strategies for Accounts, on the one hand, and the Company, on the other hand, may disadvantage the relevant Subfund. Certain factors, for example, market impact, liquidity constraints, or other circumstances, could result in the relevant Subfund receiving less favourable trading results or incurring increased costs associated with implementing such investment decisions or strategies, or being otherwi se disadvantaged.

Subject to applicable law, the GAM Investment Manager may cause a Subfund to invest in securities or other obligations of companies affiliated with or advised by GAM or in which GAM or Accounts have an equity, debt or other interest, or to engage in investment transactions that may result in other Accounts being relieved of obligations or otherwise divested of investments, which may enhance the profitability of GAM’s or other Accounts’ investment in and activities with respect to such companies.

GAM May Act in a Capacity Other Than GAM Investment Manager to the Subfund Principal and Cross Transactions

When permitted by applicable law and the GAM Investment Manager’s policies, the GAM Investment Manager, acting on behalf of the relevant Subfund, may enter into transactions in securities and other instruments with or through GAM or in Accounts managed by the relevant GAM Investment Manager, and may cause the Subfund to engage in transactions in which GAM acts as principal on their own behalf (principal transactions) or advise both sides of a transaction (cross transactions). There may be potential conflicts of interest or regulatory issues relating to these transactions which could limit the GAM Investment Manager’s decision to engage in these transactions for the Company. GAM may have a potentially conflicting division of loyalties and responsibilities to the parties in such transactions, and has developed policies and procedures in relation to such transactions and conflicts. Any principal, or cross transactions will be effected in accordance with fiduciary requirements and applicable law.

Subject to applicable law, GAM or Accounts may also invest in or alongside the Company. Unless provided otherwise by agreement to the contrary, GAM or Accounts may redeem interests in the Company at any time without notice to Shareholders or regard to the effect on the relevant Subfund’s portfolio, which may be adverse.

Proxy Voting by the relevant GAM Investment Manager

The GAM Investment Manager has adopted policies and procedures designed to prevent conflicts of interest from influencing proxy voting decisions that it makes on behalf of advisory clients, including the Company, and

to help ensure that such decisions are made in accordance with its fiduciary obligations to its clients. Notwithstanding such proxy voting policies and procedures, proxy voting decisions made by the relevant GAM Investment Manager with respect to securities held by the Subfund may benefit the interests of GAM and Accounts other than the Subfund.

Potential Limitations and Restrictions on Investment Opportunities and Activities of GAM and the Company

The relevant GAM Investment Manager may restrict its investment decisions and activities on behalf of a Subfund in various circumstances, including as a result of applicable regulatory requirements, information held by GAM and GAM’s internal policies. In addition, the GAM Investment Manager is not permitted to obtain or use material non-public information in effecting purchases and sales in public securities transactions for the relevant Subfund.

Aggregation of Trades by the GAM Investment Manager

The GAM Investment Manager follows policies and procedures pursuant to which they may combine or aggregate purchase or sale orders for the same security for multiple Accounts (including Accounts in which GAM has an interest) (sometimes called “bunching”), so that the orders can be executed at the same time. The GAM Investment Manager aggregates orders when it considers doing so appropriate and in the interests of its clients generally. In addition, under certain circumstances trades for the relevant Subfund may be aggregated with Accounts in which GAM has an interest.

When an aggregated order is completely filled, the GAM Investment Manager generally will allocate the securities purchased or proceeds of sale pro rata among the participating Accounts, based on the purchase or sale order. If the order at a particular broker is filled at several different prices, through multiple trades, generally all participating Accounts will receive the average price and pay the average commission, subject to odd lots, rounding, and market practice. There may be instances in which not all Accounts are charged the same commission or commission equivalent rates in a bunched or aggregated order.

Although it may do so in certain circumstances, the GAM Investment Manager generally does not bunch or aggregate orders for different Accounts (including the Company), or net buy and sell orders for the Company, if portfolio management decisions relating to the orders are made by separate portfolio management teams, if aggregating or netting is not appropriate or practicable from the relevant GAM Investment Manager’s operational or other perspective, or if doing so would not be appropriate in light of applicable regulatory considerations.

The GAM Investment Manager may be able to negotiate a better price and lower commission rate on aggregated trades than on trades for Accounts that are not aggregated, and incur lower transaction costs on netted trades than trades that are not netted. Where transactions for the relevant Subfund are not aggregated with other orders, or not netted against orders for the Subfund, that Subfund may not benefit from a better price and lower commission rate or lower transaction cost.

Other Conflicts of Interests

Each of the Manager, any GAM Investment Manager and any Delegate Investment Manager may in the course of their business have conflicts of interest with the Company in circumstances other than those referred to above. The Manager, the relevant GAM Investment Manager and relevant Delegate Investment Manager will, however, have regard in such event to its obligations to act in the best interests of Shareholders when undertaking any investment where conflicts of interest may arise and will seek to resolve such conflicts fairly. In the event that a conflict arises in relation to the allocation of investment opportunities, the Manager, the relevant GAM Investment Manager or the relevant Delegate Investment Manager will ensure that it is resolved fairly.

28. DOCUMENTS FOR INSPECTION

Copies of the following documents may be inspected at the registered office of the Company in Luxembourg during normal business hours on business days in Luxembourg, and at the offices of the respective national representatives during their business days:

1a) the Investment Managers’ agreements, Investment Advisers’ agreements, the fund administration agreement, the agreements with the custodian bank, the administrator and principal paying agent as well as the registrar and transfer agent. These agreements may be amended with the approval of both parties;

1b) the articles of association of the Company.

The following documents may be obtained free of charge on request:

2a) the latest Key Investor Information Document and the full prospectus; 2b) the most recent annual and semi-annual reports.

The articles of association, the Key Investor Information Document, the full prospectus, the Remuneration Policy of the Management Company (“Remuneration Policy of GAM (Luxembourg) S.A“) and the full annual and semi- annual reports may also be obtained on the web site xxx.xxxxx.xxx.xxx .

In the event of contradictions between the above-mentioned German-language documents and any translations thereof, the German-language version shall be the authentic text. This is without prejudice to mandatory conflicting regulations governing sale and marketing in legal systems in which the Company’s Shares have been legally marketed and sold.

ANNEX I: OVERVIEW OF COMPARATIVE INDEX

In order to measure performance, the individual Subfund is compared with the corresponding reference index in the currency of the respective Share Category or the respective hedged Share Category, according to table below.

	GAM Multicash - Subfunds	Comparative index
1	MONEY MARKET DOLLAR	BofA Xxxxxxx Xxxxx USD LIBID Overnight TR
2	MONEY MARKET EURO	Eonia (Euro OverNight Index Average)
3	MONEY MARKET XXXXXXXX	XXXXX (Sterling OverNight Index Average)
4	MONEY MARKET SWISS FRANC	Citigroup CHF 1 Month Eurodeposit

GAM MULTISTOCK

A SICAV UNDER LUXEMBOURG LAW

PROSPECTUS

25 NOVEMBER 2017

Subscriptions are validly made only on the basis of this prospectus or the Key Investor Information Document in conjunction with the most recent annual report and the most recent semi-annual report where this is published after the annual report.

No information other than that contained in this prospectus or the Key Investor Information Document may be given.

TABLE OF CONTENTS

1. Introduction 5

2. Organisation and management 8

3. Investment objectives and policy 10

4. Investor profile 24

5. Investment limits 24

6. Special investment techniques and financial instruments 30

6.1. Options on securities 30

6.2. Financial futures, swaps and options on financial instruments 30

6.3. Efficient Portfolio management – other investment techniques and instruments 32

6.4. Securities lending 32

6.5. Securities repurchase agreements 34

6.6. Management of collateral for OTC derivatives and efficient portfolio management techniques 34

6.7. Techniques and instruments for hedging currency risks 35

6.8. Structured products 36

6.9. Swaps and other financial derivatives with comparable properties 36

6.10. Investments in financial indices pursuant to Article 9 of the Grand Ducal 37

Ordinance of 8 February 2008 37

6.11. Risks associated with the use of derivatives and other special investment techniques 38

and financial instruments 38

6.12. Leverage 40

6.13. Risks associated with investments in the People's Republic of China (PRC) 40

6.14. Specific provisions and risks relating to Master-Feeder Subfunds 44

7. The Company 47

8. Custodian 48

9. Management Company and Domiciliary Agent 50

10. Principal administrative and paying agent, agent, Registrar and transfer agent 50

11. General information on Investment Management and Investment Advice 50

11.1. Investment managers / Investment advisers 51

12. Paying agents and representatives 52

13. Distributors 52

14. Co-management 53

15. Description of Shares 54

16. Issue of Shares / Application procedure 58

16.1. Application and confirmation 61

16.2. General 61

17. Redemption of Shares 62

18. Switching of Shares 64

19. Dividends 65

20. Calculation of net asset value 65

21. Suspension of calculation of net asset value, and of the issue, redemption and switching of Shares 66

22. Fees and costs 66

23. Taxation 72

23.1 Company 73

23.2 Shareholders 73

23.3 Foreign Account Tax Compliance Act (“FATCA”) of the United States of America (“US”) 74

24. General meeting of shareholders and reporting 75

25. Applicable law, jurisdiction 75

26. Remuneration policy 76

27. General Conflicts Associated with the Company 76

28. Documents for inspection 79

Annex I: Overview of reference indices 81

1. INTRODUCTION

GAM Multistock (the “Company”, “GAM Multistock”) is established as a “société d'investissement à capital variable” (SICAV) in accordance with the current version of the law of the Grand Duchy of Luxembourg dated August 10, 1915 (“the 1915 Law“), and authorised as an undertaking for collective investments in transferable securities (UCITS) under Part I of the law dated December 17, 2010 (“the 2010 Law”).

The Company has an “umbrella structure”, which allows subfunds (“Subfunds”) to be established which correspond to different investment portfolios and which can be issued in different categories of shares.

The Board of Directors of the Company is authorised to issue shares (“Shares“) without par value in various investment portfolios (“Subfunds”) relating to the Subfunds described in the section ”Investment objectives and policy”, and, as noted in the section “Description of Shares“, share categories (“Share Category”) with different characteristics may be issued for each Subfund.

The price of the Shares is denominated in the same accounting currency of the Subfund or, as applicable, the currency of the Share Category in question. As described in the section “Issue of Shares / Application procedure”, a selling fee of up to 5% may be charged in addition to the Issue Price.

Overview of Subfunds: Denomination / Accounting Currency / Initial Subscription Period

Denomination of Subfund: GAM MULTISTOCK -	Accounting currency	Initial subscription period
ABSOLUTE RETURN EUROPE EQUITY	EUR	23 – 30 September 2010
ASIA FOCUS EQUITY (until 29.11.2013: CHINDONESIA FUND)	USD	23 – 30 September 2010
CHINA EVOLUTION EQUITY	USD	29 November 2013 – 02 December 2013
EMERGING MARKETS EQUITY (until 29.06.2017: EMERGING EQUITY FUND)	USD	25 February 2015
EUROLAND VALUE EQUITY (until 30.05.2001: EUROLAND STOCK FUND)	EUR	21 – 28 October 1999
EUROPE FOCUS EQUITY (until 29.11.2013: EUROPE STOCK FUND)	EUR	2 – 31 May 1990
GERMAN FOCUS EQUITY (until 30.06.2017 GERMAN VALUE STOCK FUND, prior to that : GERMAN STOCK FUND)	EUR	6 – 10 December 1993
GLOBAL EQUITY INCOME (until 01.04.2013: GLOBAL STOCK FUND, formerly GLOBAL MEGATREND STOCK FUND)	EUR	19 – 24 February 1999
HEALTH INNOVATION EQUITY (until 29.11.2013: BIOTECH FUND)	USD	21 – 31 January 2008
JAPAN EQUITY	JPY	17 – 25 May 1993
LUXURY BRANDS EQUITY	EUR	21 – 31 January 2008
SWISS SMALL & MID CAP EQUITY (until 30.01.2006: SPECIAL SWISS STOCK FUND)	CHF	6 – 15 April 1992
SWISS EQUITY	CHF	2 – 31 May 1990
US LEADING EQUITY (until 27.04.2000: US STOCK FUND)	USD	2 – 31 May 1990

Denomination of Subfund: GAM MULTISTOCK -	Accounting currency	Initial subscription period
US VALUE EQUITY	USD	22 – 29 April 2002

The Company may issue Shares in new, additional Subfunds at any time. In this case, this prospectus will be supplemented accordingly.

The Company currently issues Share Categories with different fee structures (see sections “Issue and sale of Shares / Application procedure” and “Fees and costs”).

Investors may purchase shares either directly from the Company or via an intermediary, acting in its own name but for the investor’s account. In the latter case an investor may not necessarily assert all his/her investor’s rights directly against the Company. For details reference is made to the chapter “Issue of Shares / Application procedure”, under “Nominee Service”.

Shares may be redeemed at a price described in the section “Redemption of Shares”. Shares may be switched using the formula described in the section “Switching of Shares“.

The individual Share Categories of the Company may be quoted on the Luxembourg Stock Exchange.

In addition to the prospectus, a key investor information document is produced for each Share Category and is handed to each purchaser before he/she subscribes to Shares (“Key Investor Information Document”). By subscribing to the Shares, each purchaser declares that he/she has received the Key Investor Information Document prior to effecting the subscription.

Under the 2010 Law, the Company is authorised to produce one or more special prospectuses for the distribution of Shares in one or more Subfunds or for one specific distribution country.

The information in this prospectus is in accordance with the current law and rules and regulations of the Grand Duchy of Luxembourg, and is thus subject to alterations.

In this prospectus, figures in ”AUD” refer to the currency of Australia; ”Swiss Francs” or ”CHF” to the currency of Switzerland; “DKK” to the currency of Denmark; ”US Dollars”, ”Dollars” or ”USD” to the currency of the United States of America; ”Euro” or ”EUR” to the currency of the European Economic and Monetary Union; ”£ Sterling” or ”GBP” to the currency of Great Britain; ”Japanese Yen” or ”JPY” to the currency of Japan; ”NOK” to the currency of Norway; ”SEK” to the currency of Sweden and “SGD“ or “Singapore Dollar“ to the currency of Singapore.

Potential purchasers of Shares are responsible for informing themselves on the relevant foreign exchange regulations and on the legal and tax regulations applicable to them.

Because Shares in the Company are not registered in the USA in accordance with the United States Securities Act of 1933, they may be neither offered nor sold in the USA including the dependent territories, unless such offer or such sale is permitted by way of an exemption from registration in accordance with United States Securities Act of 1933.

In general, the shares in the Company may neither be offered nor sold nor transferred to any US American defined benefit pension plan. Exceptions hereto are possible, provided the Board of Directors of the Company has issued a corresponding special authorization for it. In this sense, a “defined benefit pension plan” means any (i) “defined benefit pension plan for employees”, within the meaning of Section 3(3) of the US Employee Retirement Income Security Act of 1974, as amended (“ERISA”) that is subject to the provisions of Part 4 of Title I of ERISA, (ii) individual retirement account, Xxxxx Plan or other plan described in Section 4975(e)(1) of the US Internal Revenue Code of 1986, as amended, (iii) entity whose underlying assets include “plan assets” by

reason of 25% or more of any class of equity interest in the entity being held by plans described in (i) and (ii) above, or (iv) other entity (such as segregated or common accounts of an insurance company, a corporate group or a common trust) whose underlying assets include “plan assets” by reason of an investment in the entity by plans described in (i) and (ii) above. Should investors participating in a defined benefit pension plan hold more than 25% of a share category, the company’s assets shall be considered, in accordance with ERISA, "plan assets", which could have an adverse effect on the Company and its shareholders. In this case, the Company may, if appropriate, require the compulsory redemption of the shares affected.

The Shares of the Subfund ASIA FOCUS EQUITY may not be offered, sold or delivered, directly or indirectly, either in India, or to or for the account of “Indian Residents” or to non-resident Indians (NRIs).

“Indian Residents” within the meaning of this provision refers to persons domiciled in India; partnerships or corporations under Indian law; trusts in which a trustee is domiciled in India; India-domiciled agencies or branches of foreign entities; non-discretionary or similar accounts held in favour of or for the account of a person domiciled in India, and discretionary or similar accounts held by a broker under Indian law or who is domiciled in India.

NRI within the meaning of this provision refers to Indian nationals who do not live on Indian territory. Further information can be obtained at xxx.xxxxx.xxx.xxx.

2. ORGANISATION AND MANAGEMENT

The Company’s registered office is at 00, Xxxxx-Xxx, X-0000 Xxxxxxxxxx.

Board of Directors of the Company Chairman

Xxxxxx Xxxxx Member of the Group Management Board, GAM Group

Members

Xxxxxx Xxxxxx Region Head (U.K.) Limited, London

Me Xxxxxx Xxxxxxx Independent Director, Partner of Linklaters LLP, Luxembourg Xxxx-Xxxxxx Xxxxx Independent Director, Luxembourg

Xxxx Xxxxxxx Member of the Group Management Board, GAM Group

Management Company

GAM (Luxembourg) S.A., 00, Xxxxx-Xxx, X-0000 Xxxxxxxxxx

Board of Directors of the Management Company Chairman

Xxxxxx Xxxxx Member of the Group Management Board, GAM Group

Members

Xxxxxx Xxxxxx Member of the Group Management Board, GAM Group Xxxxxxx Xxxxxx Head of Operations and IT, GAM (U.K.) Limited, London Xxxxx Xxxxxxx Member of the Group Management Board, GAM Group Xxxx Xxxxxx Independent Director, Luxembourg

Managing directors of the Management Company

Xxxx Xxxxx Managing Director, GAM (Luxembourg) S.A., Luxembourg Xxxxx Xxxxxxx Managing Director, GAM (Luxembourg) S.A., Luxembourg

Investment Managers and Investment Advisers

The Company and the Management Company have appointed various investment managers or investment advisers and may make further appointments.

Custodian,

Central administration and principal paying agent Registrar and transfer agent

Xxxxx Xxxxxx Xxxx Xxxxxxxxxx X.X.X., 00, Xxxxxx X.X. Xxxxxxx, X-0000 Xxxxxxxxxx

Distributors

The Company, respectively the Management Company, has appointed Distributors and may appoint additional Distributors to sell Shares in various legal jurisdictions.

Auditor of annual report

PricewaterhouseCoopers Société coopérative, 0 xxx Xxxxxxx Xxxxxxxx, X-0000 Xxxxxxxxxx has been appointed auditor of the Company.

Legal adviser

Linklaters LLP, 00, Xxxxxx Xxxx X. Xxxxxxx, X-0000 Xxxxxxxxxx has been appointed legal adviser of the Company in Luxembourg.

Supervisory authority in Luxembourg

Commission de Surveillance du Secteur Financier (“CSSF”), 000, xxxxx x’Xxxxx, X-0000 Xxxxxxxxxx.

Further information and documents on the Company and the individual Subfunds may also be consulted on the website xxx.xxxxx.xxx.xxx, on which investors can also find a form for submitting complaints.

3. INVESTMENT OBJECTIVES AND POLICY

The investment objective of the Company is to achieve an appropriate return applying the principle of risk diversification, guaranteed through the active management, aimed at long term increases in value, of fund assets predominantly composed of equities (in accordance with the investment policy and investment restrictions). The securities selected are those which are traded on an official securities exchange in recognised countries or on other regulated markets in recognised countries. In this context, a “recognised country” is a member state of the Organisation for Economic Cooperation and Development (“OECD”), and all other countries in Europe, North and South America, Africa, Asia and the Pacific Rim (hereafter “recognised country”). A regulated market is a market which is recognised and open to the public, and whose operation is properly regulated (hereafter “regulated market”).

In addition to securities and the other assets permitted as described in the section “Investment limits“, it is also possible to hold liquid assets, these being in principle of an ancillary nature.

In order to pursue the investment objectives, the Subfunds may, in the context of the guidelines and limits established on the basis of Luxembourg law, use the investment techniques and financial instruments described below in the section “Special investment techniques and financial instruments”.

Although the Company makes every effort to achieve the investment objectives of the individual Subfunds, no guarantee can be given of the extent to which the investment objectives will be achieved. As a result, the net asset values of the Shares may become greater or smaller, and different levels of positive as well as negative income may be earned. Consequently, a Shareholder runs the risk that he/she may not recover the amount originally invested. Depending on the orientation of the individual Subfunds this risk may differ from Subfund to Subfund. It is also noted that there are increased risks in relation to the settlement of the Company’s securities transactions, in particular with regard to securities that are kept in regions or countries that do not yet have an established securities market, and above all the risk that the securities may be delivered late or not at all. Currency risks may also arise for shareholders, whose reference currency differs from the investment currency of a Subfund. The following description of the Subfunds shall not be construed as a recommendation to acquire Shares in a particular Subfund. Rather, each shareholder should consult his/her financial adviser regarding the acquisition of Shares in the Company and the selection among the Subfunds and their Share Categories.

The performance of the individual Subfunds is set out in the Key Investor Information Document.

The Board of Directors of the Company (“Board of Directors”) has determined the following investment objectives and investment policy for the individual Subfunds:

GAM Multistock – ABSOLUTE RETURN EUROPE EQUITY

The investment objective of the Company in relation to GAM Multistock – ABSOLUTE RETURN EUROPE EQUITY (“ABSOLUTE RETURN EUROPE EQUITY“) is to achieve a positive long-term return in both rising and falling financial markets.

To this end, ABSOLUTE RETURN EUROPE EQUITY invests - mainly by using derivative financial instruments - in equities or equity-related securities of companies having their registered office or the major part of their business activities in recognised countries of Europe, and in European share indices. The exposure to such equities or to equity-related securities or share indices shall amount to at least two thirds of the assets of ABSOLUTE RETURN EUROPE EQUITY.

In order to pursue the generally intended market-neutral strategy, the ABSOLUTE RETURN EUROPE EQUITY will take long positions in equities, equity-related securities and share indices that appear attractive, and short positions in equities, equity-related securities and share indices that appear unattractive, in each case mainly by using cash-settled swap agreements. In order to implement the strategy, a combination of individual swap agreements is generally used in which the performance of a share (or, as applicable, equity-related securities or share indices) is swapped in each case for the financing, in principle on the basis of a recognised money-market rate.

Furthermore ABSOLUTE RETURN EUROPE EQUITY may depart, opportunistically under market circumstances that appear suitable, from the above-mentioned market-neutral strategy and take directional long and synthetic short positions, mainly by using direct investments in equities or equity-related securities and swaps, futures, options or other derivative financial instruments on equities or equity-related securities or share indices.

The ABSOLUTE RETURN EUROPE EQUITY will hold long positions of up to 150% of its net assets by means of derivative financial instruments and short positions of up to 150% of its net assets by means of cash-settled derivative financial instruments.

In order to implement its absolute return strategies, ABSOLUTE RETURN EUROPE EQUITY intends to make full use of the possibility of investing in derivative financial instruments or of using special investment techniques as set out in the section “Special investment techniques and financial instruments“, while complying with the restrictions laid down in said section. The derivative financial instruments traded on or off a securities exchange and used by ABSOLUTE RETURN EUROPE EQUITY may comprise swap contracts, (index) futures, (index) options, forward contracts on financial instruments and options on such contracts, inter alia.

The commitments entered into through the use of derivatives are covered by liquid investments such as fixed - income or floating-rate securities, debt instruments and rights (including zero-coupon bonds) with a good credit rating, money-market paper, cash and cash-equivalent instruments in order to be able to cover at all times the commitments of ABSOLUTE RETURN EUROPE EQUITY resulting from its positions in derivative financial instruments (including short positions). For this purpose, cash, cash-equivalent instruments and other liquid investments can amount up to 100% of the assets of ABSOLUTE RETURN EUROPE EQUITY.

Up to a maximum of one third of the assets of ABSOLUTE RETURN EUROPE EQUITY may be invested in other assets permissible under Article 41 paragraph 1 of the 2010 Law and under the relevant ordinances and supervisory circulars issued, including derivative financial instruments.

Furthermore derivative financial instruments and special investment techniques can also be used for efficient portfolio management and hedging purposes.

ABSOLUTE RETURN EUROPE EQUITY is denominated in Euro. The investments of ABSOLUTE RETURN EUROPE EQUITY may be denominated in Euro or other currencies. Foreign currency risks may be fully or partially hedged. A depreciation caused by exchange-rate fluctuations cannot be ruled out.

The aggregate risk of the ABSOLUTE RETURN EUROPE EQUITY is monitored using the absolute Value-at- Risk (VaR) method. As part of risk management, a maximum monthly (20-day) VaR limit of 10% is set, with a 99% confidence interval.

In order to achieve its investment objectives, ABSOLUTE RETURN EUROPE EQUITY uses mainly derivative and other special investment techniques and financial instruments instead of direct investments to build up and maintain exposure to the European equity markets. The risk characteristics of derivatives and other investment techniques and instruments should therefore also be taken into account, in addition to the risk characteristics of securities. In general, they are exposed to the risks of their underlying markets or basic instruments and often involve higher risks than direct investments in securities. Potential risks of such instruments may, for example, result from the complexity, non-linearity, high volatility, low liquidity, restricted ability to be valued, risk of a loss of earnings or even a total loss of the invested capital, or from the counterparty risk.

There is a possibility that the strategies used by ABSOLUTE RETURN EUROPE EQUITY may not achieve the intended investment objective. In particular, there is no guarantee that the use of appropriate long and short positions will successfully limit the risks of ABSOLUTE RETURN EUROPE EQUITY, for example in the event of stock market fluctuations, capitalisation, takeovers, mergers and restructuring operations of companies as well as changes of sector and other risk factors.

GAM Multistock –ASIA FOCUS EQUITY

The Company’s investment objective for the GAM Multistock – ASIA FOCUS EQUITY (“ASIA FOCUS EQUITY”) is to achieve long-term capital growth by investing at least two thirds of the assets in a portfolio of carefully selected stocks, other equities and equity rights of companies having their domicile or the predominant part of their economic activity in the recognised countries of Asia (excluding Japan).

Moreover, the Company may invest up to a maximum of one third of the assets of ASIA FOCUS EQUITY in other assets such as carefully selected stocks, other equities and equity rights of companies having their domicile or the predominant part of their economic activity in recognised countries, or in fixed- or floating-rate securities as well as in convertible and warrant bonds (up to a maximum of 25% of the assets) of issuers from recognised countries. Up to a maximum of 15% of the assets of the ASIA FOCUS EQUITY may be invested in warrants on shares or other equities and equity rights. Purchases of warrants involve increased risks due to the higher volatility of such investments.

In addition, liquid assets may be held which under certain circumstances, and by derogation from the aforementioned 2/3 rule, may account for up to 49% of the assets of the ASIA FOCUS EQUITY.

Direct investments in China are made in what are referred to as “China-A“-, “China-B“, “China H” shares or shares of Chinese companies that are quoted on another foreign exchange outside the People’s Republic of China (PRC). “China A” and “China B” shares are securities quoted on the stock exchanges of Shanghai and/or Shenzhen. “China A” shares are denominated in Renminbi and can be bought through the Shanghai Hong Kong Stock Connect Programme or the Shenzhen Hong Kong Stock Connect Programme. Investments in “China A” shares comply with the conditions imposed by article 41 paragraph 1 of the 2010 Law. “China B” shares are quoted on the stock exchanges of Shanghai or Shenzhen and represent equity of companies traded in foreign currency. The face value of “China B” shares is determined in Renminbi. In Shanghai, “China B” shares are traded in US dollars and in Shenzhen, in Hong Kong dollars. “China H” shares are shares of companies which have their registered office in the PRC, are listed on the Hong Kong Stock Exchange and are denominated in Hong Kong dollars.

Investments in China may also be made indirectly by purchasing share-based products, in particular ADRs (American depositary receipts) and GDRs (global depositary receipts), which comply with the provisions of article 41 of the 2010 Law and which do not invest in derivatives, or Exchange Traded Funds (ETFs) and other investment funds.

Indirect investments in India may also be made through purchases of so-called share-based products, in particular ADRs (American depositary receipts) and GDRs (global depositary receipts), Participatory Notes (P- Notes), Exchange Traded Funds (ETF) and other investment funds and derivatives on equities or equity indices, which qualify as eligible assets in accordance with Article 44 of the Law of 2010. P-Notes are instruments issued by financial institutions that provide exposure to the underlying securities. These are eligible for investment by the Subfund, provided that they meet all legal and contractual criteria. Depending on the type of investment, the P-Notes are classified as a certificate or warrant / options.

The ASIA FOCUS EQUITY is denominated in US dollars. The investments of the ASIA FOCUS EQUITY may be denominated in US dollars or other currencies. Currency risks may be entirely or partially hedged. Losses due to currency variations cannot be ruled out.

Potential investors are advised that investments in the ASIA FOCUS EQUITY are associated with increased risk. Stock markets and economies of Asian countries that are in the process of developing into modern industrialised countries (such as China, India, Indonesia, Taiwan, Malaysia, Thailand, or Korea) are generally volatile and entail a greater degree of risk. In particular, the investments are subject to the following risks:

a) trading volumes in relation to the securities may be low or non-existent on the securities market involved, which can lead to liquidity problems and considerable price fluctuations;

b) uncertainties surrounding political, economic and social circumstances, with the associated dangers of expropriation or seizure, of unusually high inflation rates, prohibitive tax measures and other negative developments;

c) potentially considerable fluctuations in the foreign exchange rate, different legal frameworks, existing or potential foreign exchange export restrictions, customs or other restrictions, and any laws and other restrictions applicable to investments;

d) political or other circumstances which restrict the investment opportunities of the Subfund, for example restrictions with regard to issuers or industries deemed sensitive to relevant national interests;

e) the absence of sufficiently developed legal structures governing private or foreign investments and potentially inadequate safeguards with respect to private ownership, and

f) the purchase and the sale of equity interests in certain investments can be subject to considerable delays, and in certain circumstances the transactions may be performed at unfavourable prices because the clearing, settlement and government systems are not as well developed as in more developed markets.

g) under exceptional circumstances, because of limited investment opportunities, the Subfund may suffer losses or may not be in a position to fully achieve its investment objectives or follow its investment strategy, due to investment restrictions in China, illiquidity of the Chinese market for A- shares or due to a delay or interruption in the execution or settlement of transactions.

Foreign exchange export restrictions and other related regulations in these countries may also lead to the delayed repatriation of all or some of the investments or may prevent them being repatriated in full or in part, with the result that there may be a delay in the payment of the redemption price.

Furthermore, investors should be aware of the increased risk associated with investments in “China A” shares, which is described in the section 6.13, “Risks associated with investments in the People's Republic of China".

GAM Multistock – CHINA EVOLUTION EQUITY

The Company’s investment objective in relation to GAM Multistock – CHINA EVOLUTION EQUITY (”CHINA EVOLUTION EQUITY“) is to achieve long-term capital growth by investing at least two thirds of the fund’s assets in a portfolio of carefully selected shares of companies with their registered office or the major part of their business activities in China.

Moreover, the Company may invest up to a maximum of one third of the assets of CHINA EVOLUTION EQUITY in other assets such as carefully selected stocks, other equities and equity rights of companies having their domicile or the predominant part of their economic activity in recognised countries, or in fixed- or floating-rate securities as well as in convertible and warrant bonds (up to a maximum of 25% of the assets) of issuers from recognised countries. Up to a maximum of 15% of the assets of the CHINA EVOLUTION EQUITY may be invested in warrants on shares or other equities and equity rights. Purchases of warrants involve increased risks due to the higher volatility of such investments.

In addition, liquid instruments may be held and may, under certain circumstances, account for up to 49% of the assets of the CHINA EVOLUTION EQUITY, by derogation from the two-thirds rule mentioned above.

Investments in China may also be made indirectly by purchasing share-based products, in particular ADRs (American depositary receipts), GDRs (global depositary receipts), which comply with the provisions of article 41 of the 2010 Law and which do not invest in derivatives, or Exchange Traded Funds (ETFs) and other investment funds.

CHINA EVOLUTION EQUITY is denominated in US dollars. The investments of the CHINA EVOLUTION EQUITY may be denominated in US Dollars or other currencies. Foreign currency risks may be fully or partially hedged. A depreciation caused by exchange–rate fluctuations cannot be ruled out.

The attention of potential investors is drawn to the fact that investments in the CHINA EVOLUTION EQUITY are associated with increased risk. Stock markets and economies in so-called emerging market countries or frontier market countries are generally volatile and may bear a higher risk. In particular, the investments are subject to the following risks:

a) the volumes of the securities traded may be low or non-existent on the securities market concerned, which may lead to liquidity shortages and relatively large price fluctuations;

b) uncertainties surrounding political, economic and social conditions and the associated dangers of expropriation or seizure, the risk of unusually high inflation rates, prohibitive fiscal measures and other negative developments;

c) potentially considerable fluctuations in the foreign-exchange rate, different legal frameworks, existing or potential foreign-exchange transfer restrictions, customs or other restrictions and any laws or other restrictions applicable to investments;

d) political or other circumstances which restrict the investment opportunities of the Subfund, such as for example restrictions with regard to issuers or industries deemed sensitive to relevant national interests, and

e) the absence of sufficiently developed legal structures governing private or foreign investments and potentially inadequate safeguards with respect to private ownership.

GAM Multistock – EMERGING MARKETS EQUITY

The investment objective of the Company in relation to GAM Multistock – EMERGING MARKETS EQUITY (“EMERGING MARKETS EQUITY“) is to achieve long-term capital growth by investing at least two thirds of the assets in a portfolio of carefully selected shares and other equity securities of companies with their registered office or the major part of their business activities in emerging market countries.

The term “emerging markets“ is generally understood to refer to the markets of countries that are in the process of developing into modern industrialised states and thus display a high degree of potential but also entail a greater degree of risk. In particular, it applies to those countries included in the S&P Emerging Broad Market Index or in the MSCI Emerging Markets Index.

In addition, the Company may invest up to a maximum of one third of the assets of EMERGING MARKETS EQUITY in a portfolio of carefully selected shares and other equity securities of companies with their registered office or the major part of their business activities in other recognised countries, or in fixed-interest or floating- rate securities as well as in convertible and warrant bonds (up to a maximum of 25% of the assets) from issuers from recognised countries. Up to a maximum of 20% of the assets of EMERGING MARKETS EQUITY may be invested in warrants on shares or other equity securities. Purchases of warrants involve increased risks due to the higher volatility of such investments.

In addition, liquid instruments may be held and may, under certain circumstances, account for up to 49% of the assets of the EMERGING MARKETS EQUITY, by derogation from the two-thirds rule mentioned above.

Direct investments in China are made in what are referred to as “China A” shares, “China B” shares, “China H” shares or shares of Chinese companies that are quoted on another foreign exchange outside the People’s Republic of China (PRC). “China A” shares and “China B” shares are securities that are quoted on the Shanghai and/or Shenzhen Stock Exchanges. “China A” shares are denominated in Renminbi and may be purchased via the Shanghai - Hong Kong Stock Connect Programme or the Shenzhen Hong Kong Stock Connect Programme. Furthermore, the Subfund may use the Renminbi Qualified Foreign Institutional Investor ("RQFII") quota of the Investment Manager to invest directly in “China A” shares, which are traded in Renminbi on the Shanghai and Shenzhen Stock Exchanges by companies established in Chinese mainland. Investments in “China A” shares comply with the conditions imposed by article 41 paragraph 1 of the 2010 Law. “China B” shares are quoted on the stock exchanges of Shanghai or Shenzhen and represent equity of companies traded in foreign currency. The face value of “China B” shares is determined in Renminbi. In Shanghai, “China B” shares are traded in US dollars and in Shenzhen, in Hong Kong dollars. “China H” shares are shares of companies which have their registered office in the People’s Republic of China, are listed on the Hong Kong Stock Exchange and are denominated in Hong Kong dollars.

Investments in China may also be made indirectly by purchasing share-based products, in particular ADRs (American depositary receipts), GDRs (global depositary receipts), which comply with the provisions of article 41 of the 2010 Law and which do not invest in derivatives, or so-called open or closed Exchange Traded Funds (ETFs) and other investment funds.

The EMERGING MARKETS EQUITY may also invest in Total Return Swaps (including Equity Swaps and Contracts for difference (CFD)), as well as in participatory notes (“P-Notes”) issued by a Qualified Foreign Institutional Investor (“QFIIs”) or a Renminbi Qualified Foreign Institutional Investor (“RQFII’s”). P-Notes are instruments issued by financial institutions that provide exposure to the underlying securities. These are eligible for investment by the Subfund, provided that they meet all legal and contractual criteria. Depending on the type of investment, the P-Notes are classified as a certificate or warrant / options.

EMERGING MARKETS EQUITY is denominated in US dollars. The investments of the EMERGING MARKETS EQUITY may be denominated in US Dollars or other currencies. Foreign currency risks may be fully or partially hedged. A depreciation caused by exchange–rate fluctuations cannot be ruled out.

Investments in emerging market countries are associated with increased risk. Stock markets and economies are generally volatile. In particular, the investments are subject to the following risks:

a) trading volumes in relation to the securities may be low or absent on the securities market involved, which can lead to liquidity problems and serious price fluctuations;

c) potentially serious fluctuations in the foreign exchange rate, different legal frameworks, existing or potential foreign exchange export restrictions, customs or other restrictions, and any laws and other restrictions applicable to investments;

e) the absence of sufficiently developed legal structures governing private or foreign investments and potentially inadequate safeguards with respect to private ownership.

Derivative and other special investment techniques and financial instruments may be used in the Subfund in order to achieve the investment objective. Generally, such investments often involve higher risks than direct investments in securities and currencies. Potential risks may for example result from complexity, non- linearity, leverage effect, high volatility, low liquidity, restricted possibility to valuate, risk of a loss of earnings or even a total loss of the invested capital, or counterparty risk.

Furthermore investments of the Subfund may in certain countries be impaired by political developments and/or changes in the legislation, fiscal arrangements and currency controls of the countries concerned. There are further risks in relation to the settlement of securities transactions, namely the risk that the corresponding securities may be delivered late or not at all in spite of payment having been made by the EMERGING MARKETS EQUITY. In addition, it is not possible to exclude the risk of securities being forged or stolen.

With regard to investments in Russia, your attention is drawn to certain risks relating to the ownership and safe custody of securities:

In Russia, evidence of ownership of securities consists of entries in the registers of the company issuing the securities or of its Registrar (which is neither an agent of the custodian bank nor accountable to the latter). In this respect the custodian's duty of supervision is restricted to supervision according to its best efforts within the scope of what is reasonably possible.

Share certificates representing shareholdings in companies in Russia are not held in safe custody by the custodian or sub-custodian or an effective central safe custody system. As a consequence of this system and owing to the absence of effective government regulation and enforcement, the Company might lose its registration and ownership of Russian securities as a result of fraud, negligence or simply due to oversight. It is also noted that such share certificates are generally available only in the form of photocopies, and as a result their legal value is open to challenge.

GAM Multistock – EUROLAND VALUE EQUITY

The investment objective of the Company in relation to GAM Multistock – EUROLAND VALUE EQUITY (”EUROLAND VALUE EQUITY “) is to achieve long-term capital growth by investing at least two thirds of the fund’s assets in a portfolio of carefully selected shares and other equity securities of companies with their registered office or the major part of their business activities in a recognised country in the Euro area. The Company may also invest up to one third of the assets in a portfolio of carefully selected shares and other equity securities of companies with their registered office or the major part of their business activities in another recognised country. In addition, the Company may invest in fixed-interest or floating-rate securities as well as in convertible or warrant bonds from issuers from recognised countries. Up to a total of 15% of the assets of the Subfund may be invested in warrants on shares and other equity securities. Purchases of warrants involve increased risks due to the higher volatility of such investments. The style of investment is centred on intrinsic values (so-called value titles).

EUROLAND VALUE EQUITY is denominated in Euro.

GAM Multistock – EUROPE FOCUS EQUITY

Pursuant to Section 9 of the Law of 2010 , GAM Multistock – EUROPE FOCUS EQUITY (“EUROPE FOCUS EQUITY“) is a UCITS feeder and invests at least 85% of its assets in shares of the GAM Star European Equity (“Master Subfund“). EUROPE FOCUS EQUITY may invest up to 15% of its assets in one or more of the following assets: (i) ancillary liquid assets within the meaning article 41 (2) (a) subparagraph 2 of the Law of 2010, (ii) derivative financial instruments (derivatives) eligible exclusively for hedging purposes within the meaning article 41 (1) g) and article 42 (a) and (3) of the Law of 2010.

GAM Star Fund p.l.c. is an open-ended umbrella investment company with variable capital incorporated with limited liability under the laws of Ireland and authorised by the Central Bank pursuant to the European Communities (Undertakings for Collective Investment in Transferable Securities) Regulations 1989 (the “1989 UCITS Regulations”) and is subject to the European Communities (Undertakings for Collective Investment in Transferable Securities) Regulations 2011.

The investment objective of the Master Subfund is to achieve long-term capital appreciation through investing primarily in quoted equity securities issued by companies with principal offices in Europe, including Austria, Belgium, Denmark, Finland, France, Germany, Greece, Iceland, Ireland, Italy, Luxembourg, the Xxxxxxxxxxx, Xxxxxx, Xxxxxxxx, Xxxxxx, Xxxxx, Xxxxxx, Xxxxxxxxxxx, Xxxxxx xxx xxx Xxxxxx Xxxxxxx. It will be the policy of the Subfund to invest primarily in equities.

However up to 15% of the Net Asset Value of the Master Subfund may be invested on a short term basis in fixed income securities and preferred stock, if the fund manager considers this course of action appropriate to the goal of maximising capital growth. Such Fixed Income Securities will include government and /or corporate bonds or other debt securities (such as certificates of deposit, treasury bills and commercial paper) which may have fixed or floating rates of interest, need not be of investment grade, as defined by Standard and Poor’s.

Not more than 10% of the Net Asset Value of the Master Subfund may be invested in the Russian market. With respect to Russia the Company will invest in any securities listed on the Moscow Interbank Currency Exchange (MICEX), any securities listed on RTS Stock Exchange.

The Master Subfund may not apply more than 10% of its Net Asset Value for investment in securities listed in Turkey.

The Master Subfund may also invest in deposits, money market instruments and collective investment schemes. Any investment in collective investment schemes shall not exceed in aggregate 10% of the Net Asset Value of the Master Subfund.

It is not intended that the Master Subfund will use derivatives for investment purposes. Subject to the 2011 Regulations and as more fully described under the heading “Investment Restrictions”, in the Prospectus the Fund may however use the following derivatives for investment and/or efficient portfolio management purposes (i.e. (i) reduction of risk, (ii) reduction of cost, and (iii) generation of additional capital or revenue for the Fund, associated with a risk that is compatible with the risk profile of the Fund.

The Master Subfund may hold the following derivative instruments: options (put/call), index futures, currency forwards and contracts for difference (CFDs). The Subfund may (but is not obliged to) enter into certain currency related transactions in order to hedge the currency exposure of the classes denominated in a currency other than the base currency. Such derivatives may be traded over-the-counter or on a recognised market.

Options (Put/Call): Put options may be purchased to protect the value of the Master Subfund or a portion of the Fund from expected sharp downside movements in equity markets or major industry groups. It is less cumbersome than selling out large positions and trying to buy them back. It avoids slippage and friction and keeps turnover low. Single stock call options may be used to enhance an existing position if short term strength is expected. Call Options can be purchased or sold to either gain upside exposure to an appropriate index or major industry group or be sold (covered sale only) to add income from premium dollars received as an investment overlay to an existing long position in the broad market, industry or specific stock holding, respectively.

Index Futures: Index Futures will be used mainly for tactical asset allocation to manage substantial cash flows received into the Master Subfund in order to minimise the risk of the Master Subfund underperforming due to larger than desired cash balances. A large inflow of cash may result in the Master Subfund being underexposed

to the market. Entering into an Index Future contract in place of immediate purchase of underlying stocks in such circumstances may be deemed more cost effective and expedient. This substitution will be temporary in nature until a more optimal time to purchase underlying stocks is ascertained.

Currency Forwards: These may be used to: (a) hedge the designated currency of the assets of the Master Subfund to the Base Currency of the Master Subfund; (b) mitigate the exchange rate risk between the Base Currency of the Master Subfund and the currency in which Shares in a class in the Master Subfund are designated where that designated currency is different to the Base Currency of the Master Subfund; or (c) hedge the currency of denomination of the assets of the Master Subfund attributable to a particular class into the designated currency of that class where the currency of denomination is different to the designated currency of the class.

Contracts for Difference (CFD): Contracts for difference may be used by the Master Subfund as, unlike traditional share trading, no stamp duty is payable on the purchase of a contract for difference in addition to providing an opportunity for short term trading strategies. Contracts for difference allow the fund manager to speculate on share price movements and to benefit from trading shares or indices without the need for ownership of the shares or indices at a small percentage to the cost of owning the shares or indices. As contracts for difference are directly linked to the value of the underlying assets, they will fluctuate depending on the market of the assets represented in the contract.

Financial Indices

As outlined above, the Master Subfund may use certain derivative instruments to invest in financial indices which provide exposure to the asset classes listed above. Further information relating to same is contained at the section of the Prospectus entitled “Investment in Financial Indices through the use of Financial Derivative Instruments”.

The use of derivative instruments for the purposes outlined above may expose the Master Subfund to the risks disclosed under the heading “Introduction – Risk Factors”.

The Master Subfund may also use the following techniques and instruments for efficient portfolio management purposes such as hedging and performance enhancement (i.e. reduction of cost, generation of additional capital or income, etc.) in accordance with the terms and conditions set out by the Central Bank from time to time in relation to any such techniques and instruments:

Repurchase Agreements and Reverse Repurchase Agreements: These agreements are the sale and subsequent repurchase of a security. For the party selling the security (and agreeing to repurchase it in the future at a specified time and price) it is a repurchase agreement and will generally be used as a means of raising short‑ term finance and its economic effect is that of a secured loan as the party purchasing the security makes funds available to the seller and holds the security as collateral; for the party purchasing the security (and agreeing to sell the security in the future at a specified time and price) it is a reverse repurchase agreement and will generally be used as a short-term and secure investment through which additional income is generated through finance charges, as the difference between the sale and repurchase prices paid for the security represent interest on the loan.

Stocklending Agreements: Stocklending is the temporary transfer of securities by a lender to a borrower, with agreement by the borrower to return equivalent securities to the lender at pre-agreed time. These agreements will generally be used to increase and enhance overall returns to the Master Subfund through finance charges.

Sub-underwriting Agreements: The Master Subfund may from time to time enter into sub-underwriting agreements in order to acquire securities in which the Master Subfund is permitted to invest in and/or to generate additional income for the Fund.

Participation Notes: The Master Subfund may use participation notes for performance enhancement purposes by gaining short exposure to a basket of equities with the added benefit of capital protection.

The Central Bank’s current terms and conditions in relation to repurchase agreements, reverse repurchase agreements and stocklending agreements and information relating to the operational costs and/or fees which shall be deducted from the revenue delivered to the Master Subfund as a result of these techniques are set out in Appendix V of the Master Subfund ‘s Prospectus together with general terms and conditions for use of participation notes and sub-underwriting agreements.

The Master Subfund will use a limited number of simple derivative instruments for non‑ complex efficient portfolio management. The use of financial derivative instruments by the Master Subfund will create leverage. To the extent that leverage is employed, leverage will be measured using the Commitment Approach of measuring risk, whereby such leverage cannot exceed 100% of the Net Asset Value of the Master Subfund.

Further details regarding global exposure and Commitment Approach is set out in paragraph 6.1 of the Master Subfund’s Prospectus under the heading “Investment Restrictions” and the subheading “Financial Derivative Instruments”.

The Master Subfund has a higher risk profile.

Since the EUROPE FOCUS EQUITY does not have to invest all of its assets in shares of the Master Subfund, its performance may differ substantially from that of the Master Subfund.

Additional information as regards Master Feeder structure can be found under Section 6.14 “Special regulations and risks associated with Master Feeder Subfunds”.

GAM Multistock – GERMAN FOCUS EQUITY

The investment objective of the Company in relation to GAM Multistock – GERMAN FOCUS EQUITY (“GERMAN FOCUS EQUITY“) is to achieve long-term capital growth by investing at least two thirds of the Subfund’s assets in a portfolio of carefully selected shares and other equity securities, and in warrants on shares and other equity securities (up to a maximum of 15% of the assets of the Subfund), of companies with their registered office or the major part of their business activities in the Federal Republic of Germany. In addition, the Company may invest up to a maximum of one third of the assets of GERMAN FOCUS EQUITY in shares or other equity securities of companies with their registered office or the major part of their business activities in recognised countries, or in fixed-interest or floating-rate securities as well as in convertible or warrant bonds from issuers from recognised countries. Purchases of warrants involve increased risks due to the higher volatility of such investments. The style of investment is centred on intrinsic values (so-called value titles). GERMAN FOCUS EQUITY is denominated in Euro.

GAM Multistock – GLOBAL EQUITY INCOME

The investment objective of the Company in relation to GAM Multistock – GLOBAL EQUITY INCOME (“GLOBAL EQUITY INCOME”) is to achieve long-term capital growth and steady income by investing at least two thirds of the assets in a portfolio of carefully selected shares and other equity securities of companies with their registered office or the major part of their business activities in recognised countries and from which either a sustainable and above-average dividend yield (dividend as a percentage of the share price) or increasing dividend payments can be expected.

Up to a maximum of one third of the assets of GLOBAL EQUITY INCOME may be invested in other assets permissible under Article 41 paragraph 1 of the 2010 Law and under the relevant ordinances and supervisory circulars issued, including derivative financial instruments.

In addition, liquid assets may be held which under certain circumstances, and by derogation from the aforementioned 2/3 rule, may account for up to 49% of the assets of the GLOBAL EQUITY INCOME.

Furthermore derivative financial instruments and special investment techniques can also be used for efficient portfolio management and hedging purposes.

GLOBAL EQUITY INCOME is denominated in Euro. The investments of GLOBAL EQUITY INCOME may be denominated in Euro or other currencies. Foreign currency risks may be fully or partially hedged. A depreciation caused by exchange-rate fluctuations cannot be ruled out.

The GLOBAL EQUITY INCOME may acquire on a considerable scale securities which are issued either by issuers from so-called emerging market countries and/or which are denominated in, or economically linked to, currencies of emerging market countries. The term "emerging markets” is generally taken to mean the markets of countries that are in the process of developing into modern industrialised countries and thus display a high degree of potential but also involve a greater degree of risk. They include in particular the countries included in the S&P Emerging Broad Market Index or in the MSCI

Emerging Markets Index. In general, investments in emerging market countries are associated with increased risk. In particular, investments are subject to the following risks:

a) the volumes of the securities traded may be low or non-existent on the securities market concerned, which may lead to liquidity shortages and relatively large price fluctuations;

b) uncertainties surrounding political, economic, legal and social conditions and the associated dangers of expropriation or seizure, the risk of unusually high inflation rates, prohibitive tax measures and other negative developments;

c) potentially considerable fluctuations in the foreign exchange rate, different legal frameworks, existing or potential foreign-exchange transfer restrictions, customs or other restrictions and any laws or other restrictions applicable to investments;

e) the absence of sufficiently developed legal structures governing private or foreign investments and potentially inadequate safeguards with respect to private ownership.

Furthermore, in certain investment countries, there are risks in relation to the settlement of securities transactions, namely the risk that the corresponding securities may be delivered late or not at all in spite of payment having been made by GLOBAL EQUITY INCOME. In addition, it is not possible to exclude the risk of securities being forged or stolen.

With regard to investments in certain countries, your attention is drawn to certain risks relating to the ownership and safe custody of securities. In certain investment countries, evidence of ownership of securities consists of entries in the registers of the Company issuing the securities or of its Registrar (which is neither an agent of the custodian bank nor accountable to the latter). In this respect the custodian's duty of supervision is restricted to supervision according to its best efforts within the scope of what is reasonably possible. Share certificates representing shareholdings in companies in certain investment countries are not held in safe custody by the custodian or sub-custodian or an effective central safe custody system. As a consequence of this system and owing to the absence of effective government regulation and enforcement, the Company might lose its registration and ownership of securities of certain investment countries as a result of fraud, negligence or simply due to oversight. It is also noted that such share certificates are generally available only in the form of photocopies, and as a result their legal value is open to challenge.

GAM Multistock – HEALTH INNOVATION EQUITY

The investment objective in relation to GAM Multistock – HEALTH INNOVATION EQUITY (”HEALTH INNOVATION EQUITY“) is to achieve long-term capital growth by investing at least 70% of the assets of HEALTH INNOVATION EQUITY in a portfolio of carefully-selected shares and other equity securities of companies that develop, produce or sell products, technologies, methods, procedures and/or services in the sectors of health care, pharmaceuticals, medical technology, biotechnology or biological sciences world -wide, which generate the best part of their profit through financing of these sectors, most of their shares are invested in these companies and/or most of their products and services offered are in these sectors. Further, their registered office or the major part of the business activity is in recognised countries.

In addition, the Company may invest up to a maximum of 30% of the assets of HEALTH INNOVATION EQUITY in a portfolio of carefully selected shares and other equity securities of companies with their registered office or the major part of their business activities in recognised countries, or in fixed-interest or floating-rate securities as well as in convertible and warrant bonds (up to a maximum of 25% of the assets of HEALTH INNOVATION EQUITY) from issuers from recognised countries. Up to a maximum of 15% of the assets of HEALTH INNOVATION EQUITY may be invested in warrants on shares or other equity securities. Purchases of warrants involve increased risks due to the higher volatility of such investments.

In addition, liquid instruments may be held and may, under certain circumstances account for up to 49% of the assets of the HEALTH INNOVATION EQUITY, by derogation from the 70% rule mentioned above. HEALTH

INNOVATION EQUITY is denominated in US dollars. The investments of the HEALTH INNOVATION EQUITY may be denominated in US Dollars or other currencies. Foreign currency risks may be fully or partially hedged. A depreciation caused by exchange–rate fluctuations cannot be ruled out.

On behalf of HEALTH INNOVATION EQUITY equities which are either issued by issuers from so-called emerging market countries and/or which are denominated in, or economically linked to, currencies of emerging market countries may be acquired. The term “emerging markets” generally means markets in countries currently developing into modern industrialised countries, and which therefore exhibit high potential but also increased risk. In particular, these include the countries included in the S&P Emerging Broad Market Index or the MSCI Emerging Markets Index.

The attention of potential investors is drawn to the fact that investments in emerging market countries are associated with increased risk. In particular, the investments are subject to the following risks

a) trading volumes in relation to the securities may be low or absent on the securities market involved, which can lead to liquidity problems and serious price fluctuations;

e) the absence of sufficiently developed legal structures governing private or foreign investments and potentially inadequate safeguards with respect to private ownership.

GAM Multistock – JAPAN EQUITY

The investment objective of the Company in relation to GAM Multistock – JAPAN EQUITY (“JAPAN EQUITY“) is to achieve long-term capital growth by investing at least two thirds of the assets in a portfolio of carefully selected shares and other equity securities of companies with their registered office or the major part of their business activities in Japan. In addition, the Company may invest up to a maximum of one third of the assets of JAPAN EQUITY in a portfolio of carefully selected shares and other equity securities of companies with their registered office or the major part of their business activities in other recognised countries, or in fixed-interest or floating-rate securities as well as convertible or warrant bonds (up to a maximum of 25% of the assets), from issuers from recognised countries. Up to a maximum of 15% of the assets of JAPAN EQUITY may be invested in warrants on shares or other equity securities. Purchases of warrants involve increased risks due to the higher volatility of such investments. JAPAN EQUITY is denominated in Japanese Yen.

GAM Multistock – LUXURY BRANDS EQUITY

The investment objective of the Company in relation to GAM Multistock – LUXURY BRANDS EQUITY (“LUXURY BRANDS EQUITY”) is to achieve long-term capital growth by investing at least 70% of the assets of LUXURY BRANDS EQUITY in a portfolio of carefully-selected shares and other equity securities of companies which own established brands and offer products and services in the luxury goods sector, or whose main activity is to own equity interests in such companies or to finance such companies, and which have their registered office or the major part of their business activities in recognised countries.

Owing to their quality and/or price, products and services of the luxury goods industry generally differ from other comparable products and services available and offered for sale on the market and can thus be sustainably

differentiated from such products from the perspective of relevant target groups. Brands are defined as marks which are suitable for differentiating the goods and services of one company from those of another company and which enjoy a high degree of brand awareness and recognition effect among the public at large.

In addition, the Company may invest up to a maximum of 30% of the assets of LUXURY BRANDS EQUITY in a portfolio of carefully selected shares and other equity securities of companies with their registered office or the major part of their business activities in recognised countries, or in fixed-interest or floating-rate securities as well as in convertible and warrant bonds (up to a maximum of 25% of the assets of LUXURY BRANDS EQUITY) from issuers from recognised countries. Up to a maximum of 15% of the assets of LUXURY BRANDS EQUITY may be invested in warrants on shares or other equity securities. Purchases of warrants involve increased risks due to the higher volatility of such investments.

LUXURY BRANDS EQUITY is denominated in Euro.

On behalf of LUXURY BRANDS EQUITY equities which are either issued by issuers from so-called emerging market countries and/or which are denominated in, or economically linked to, currencies of emerging market countries may be acquired. The term "emerging markets” is generally taken to mean the markets of countries that are in the process of developing into modern industrialised countries and thus display a high degree of potential but also involve a greater degree of risk. In particular, these include the countries included in the S&P Emerging Broad Market Index or the MSCI Emerging Markets Index.

Potential investors are advised that investments in emerging market countries are associated with increased risk. In particular, the investments are subject to the following risks:

a) trading volumes in relation to the securities may be low or absent on the securities market involved, which can lead to liquidity problems and serious price fluctuations;

e) the absence of sufficiently developed legal structures governing private or foreign investments and potentially inadequate safeguards with respect to private ownership.

GAM Multistock – SWISS SMALL & MID CAP EQUITY

The investment objective of the Company in relation to GAM Multistock – SWISS SMALL & MID CAP EQUITY (“SWISS SMALL & MID CAP EQUITY“) is to achieve long-term capital growth by investing at least two thirds of the fund’s assets in a portfolio of carefully selected shares, other equity securities and warrants on shares and equity securities (up to a maximum of 15% of the assets of the Subfund), of companies with their registered office or the major part of their business activities in Switzerland, whose capitalisation at the time of investment represents less than 1% of the total capitalisation of the Swiss equity market. It is also possible to purchase securities from issuers not having good credit standing according to market assessments. Compared with securities from issuers with higher capitalisation, these securities must be expected to show higher-than- average volatility, and even the complete loss of some investments cannot be ruled out.

Furthermore the Company may invest up to a maximum of one third of the assets of SWISS SMALL & MID CAP EQUITY in other assets such as carefully selected shares or other equity securities and equity rights of companies with their registered office or the major part of their business activities in recognised countries, or in

fixed-interest or floating-rate securities, convertible and warrant bonds, in warrants on shares or other equities and equity rights of issuers from recognised countries. Purchases of warrants involve increased risks due to the higher volatility of such investments.

SWISS SMALL & MID CAP EQUITY is denominated in Swiss Francs. The investments of SWISS SMALL & MID CAP EQUITY may be denominated in Swiss francs or other currencies. Foreign currency risks may be fully or partially hedged. A depreciation caused by exchange-rate fluctuations cannot be ruled out.

GAM Multistock – SWISS EQUITY

The investment objective of the Company in relation to GAM Multistock – SWISS EQUITY (“SWISS EQUITY“) is to achieve long-term capital growth by investing at least two thirds of the fund’s assets in a portfolio of carefully selected shares, other equity securities and warrants on shares and equity securities (up to a maximum of 15% of the assets of the Subfund) of companies with their registered office or the major part of their business activities in Switzerland.

Furthermore the Company may invest up to a maximum of one third of the assets of SWISS EQUITY in other assets such as carefully selected shares or other equity securities and equity rights of companies with their registered office or the major part of their business activities in recognised countries, or in fixed-interest or floating-rate securities, convertible and warrant bonds, in warrants on shares or other equities and equity rights of issuers from recognised countries. Purchases of warrants involve increased risks due to the higher volatility of such investments. Within the framework of the permitted use of derivatives, warrants attached to securities and similar financial instruments may also be held.

SWISS EQUITY is denominated in Swiss Francs. The investments of SWISS EQUITY may be denominated in Swiss francs or other currencies. Foreign currency risks may be fully or partially hedged. A depreciation caused by exchange-rate fluctuations cannot be ruled out.

GAM Multistock – US LEADING EQUITY

The investment objective of the Company in relation to GAM Multistock - US LEADING EQUITY (“US LEADING EQUITY“) is to achieve long-term capital growth by investing at least two thirds of the fund’s assets in a portfolio of carefully selected shares and other equity securities of companies with their registered office or the major part of their business activities in the United States of America. When investing in such equity securities the focus shall be on companies considered to be leading companies according to the portfolio manager’s estimation. In addition, the Company may invest up to a maximum of one third of the assets of US LEADING EQUITY in carefully selected shares and other equity securities of companies with their registered office or the major part of their business activities in recognised countries, and also in fixed-interest or floating-rate securities as well as in convertible and warrant bonds from issuers from recognised countries. Up to a maximum of 15% of the assets of US LEADING EQUITY may be invested in warrants on shares or other equity securities. Purchases of warrants involve increased risks due to the higher volatility of such investments. US LEADING EQUITY is denominated in US dollars.

GAM Multistock – US VALUE EQUITY

The investment objective of the Company in relation to GAM Multistock - US VALUE EQUITY (“US VALUE EQUITY “) is to achieve long-term capital growth by investing at least two thirds of the fund’s assets in a portfolio of carefully selected shares and other equity securities of companies with their registered office or the major part of their business activities in the United States of America. In addition, the Company may invest up to one third of the assets of US VALUE EQUITY in carefully selected shares and other equity securities of companies with their registered office or the major part of their business activities in recognised countries or also in fixed-interest or floating-rate securities as well as in convertible and warrant bonds from issuers from recognised countries. Up to a maximum of 15% of the assets of US VALUE EQUITY may be invested in warrants on shares or other equity securities. Purchases of warrants involve increased risks due to the higher volatility of such investments. The style of investment is centred on intrinsic values (so-called value shares). US VALUE EQUITY is denominated in US dollars.

4. INVESTOR PROFILE

EUROPE FOCUS EQUITY, GLOBAL EQUITY INCOME, JAPAN EQUITY, SWISS EQUITY and US LEADING EQUITY

Each of these Subfunds is suitable for investors who have experience with volatile investments, have sound knowledge of the capital markets and wish to participate in the performance of the capital markets so as to pursue their specific investment objectives. Investors must expect fluctuations in the value of the investments, which may temporarily even lead to substantial loss of value. Each of these Subfunds may be used as a basic investment within the portfolio.

LUXURY BRANDS EQUITY

This Subfund is suitable for investors who have experience with volatile investments, have sound knowledge of the capital markets and wish to participate in the performance of the capital markets so as to pursue their specific investment objectives. Investors must expect fluctuations in the value of the investments, which may temporarily even lead to substantial loss of value. This Subfund may be used as a supplementary investment within a portfolio.

EUROLAND VALUE EQUITY , GERMAN FOCUS EQUITY and US VALUE EQUITY

ASIA FOCUS EQUITY, CHINA EVOLUTION EQUITY, EMERGING MARKETS EQUITY, HEALTH INNOVATION EQUITY and SWISS SMALL & MID CAP EQUITY

Each of these Subfunds is suitable only for experienced investors who have experience with volatile investments, have in-depth knowledge of the capital markets and wish to target their investments so as to benefit from developments in specialised markets and are familiar with the opportunities and risks specific to these market segments. Investors must expect fluctuations in the value of the investments, which may temporarily even lead to very substantial loss of value. Each of these Subfunds may be used as a supplementary investment within a widely diversified portfolio.

ABSOLUTE RETURN EUROPE EQUITY

This Subfund is suitable for experienced investors who have experience with volatile investments, have in-depth knowledge of the capital markets and who wish to participate in the performance of a share portfolio with long and short positions on international capital markets so as to pursue an absolute long-term target return. Investors must expect fluctuations in the value of the investments, which may temporarily even lead to substantial loss of value. The expected maximum loss of value is determined by the Value at Risk limit (see “Investment objectives and policy”). This Subfund may be used as a basic investment or supplementary investment within a widely diversified portfolio.

5. INVESTMENT LIMITS

1. Investments in securities, money market instruments, deposits and derivatives

These investments comprise:

(a) Transferable securities and money market instruments:

- which are admitted to or dealt in on a regulated market within the meaning of Directive 2004/39/EC;

- which are dealt in on another regulated market in a member state of the European Union ("EU") which is recognised, open to the public and operates regularly;

- which are admitted to official listing on a stock exchange in a non-EU state1 or are traded on another regulated market of a non-EU state which is recognised, open to the public and operates regularly;

- resulting from new issues, provided the terms of issue contain an undertaking to apply for official listing on a stock exchange or another regulated market which is recognised, open to the public and operates regularly, and that the admission will be obtained within one year of the issue.

(b) Sight deposits or deposits repayable on demand maturing in no more than twelve (12) months with qualified credit institutions whose registered office is located in a member state of the EU or in a member state of the OECD or in a country that has ratified the resolutions of the Financial Action Task Force ("FATF" or Groupe d’Action Financière Internationale "GAFI") ("qualified credit institutions").

- the underlying securities are instruments as defined by Article 41 paragraph 1 of the 2010 Law or are financial indices, interest rates, foreign exchange rates or currencies in which the Subfund may invest according to its investment objectives;

- the OTC derivatives are subject to reliable and verifiable valuation on a daily basis and can be sold, liquidated or closed by an offsetting transaction at any time at the initiative of the Company at their fair value.

(d) Shares in UCITS authorised in accordance with Directive 2009/65/EC and/or other UCIs within the meaning of Article 1 (2), first and second indent of Directive 2009/65/EC having their registered office in a member state of the EU or a non-EU state, provided that:

- such other UCIs are authorised in accordance with legal requirements which subject them to prudential supervision considered by the CSSF to be equivalent to that under the EU Community law and that there is sufficient guarantee of cooperation between the authorities;

- the level of protection for unitholders of such other UCIs is equivalent to the level of protection for the unitholders of a UCITS and in particular that the requirements for segregation of the fund’s assets, borrowing, lending and uncovered sales of transferable securities and money market instruments are equivalent to the requirements of Directive 2009/65/EC;

- the business activities of the other UCIs are subject to semi-annual and annual reports which enable an assessment of the assets and liabilities, income and transactions over the reporting period;

If the Company purchases units in other UCITS and/or other UCIs which are managed directly or indirectly by the same Management Company or by another company to which the Management Company is linked by common administration or control or by a significant direct or indirect shareholding, the Management Company or the other company may not charge the Company any fees for subscription or redemption of shares in other UCITS and/or UCI.

A Subfund may invest in other Subfunds of the Company, subject to the prerequisites laid down in Article 181 paragraph 8 of the 2010 Law.

1 As used in the Directive 2009/65/EC, a non-EU state is a country which is not a member of the EU.

(e) Money market instruments which are not traded on a regulated market and fall under the definition of Article 1 of the 2010 Law, provided the issue or issuer of these instruments is itself subject to regulations concerning the protection of savings and investors, and provided:

- they are issued or guaranteed by a central governmental, regional or local authority or the central bank of an EU member state, the European Central Bank, the EU or the European Investment Bank, a non-EU state or, in the case of a federal state, one of the members making up the federation, or by a public international institution to which at least one EU member state belongs; or

- they are issued by an undertaking whose securities are traded on the regulated markets designated in 1. (a); or

- they are issued by other issuers belonging to a category approved by the CSSF provided such instruments are subject to investor protection regulations which are equivalent to those of the first, second or third indent and provided the issuer is either a company with own funds of at least ten (10) million Euro which presents and publishes its annual accounts in accordance with the provisions of the 4th Directive 78/660/EEC, or an entity within a group comprising one or more companies listed on an official stock exchange which is dedicated to the financing of that group, or is an entity which is dedicated to the financing of the securitisation vehicles which benefit from a banking liquidity line.

(f) However:

- the Company may invest no more than 10% of the net asset value per Subfund in transferable securities and money market instruments other than those referred to in (a) to (e);

- the Company may not acquire precious metals or certificates representing them.

(g) The Company may hold ancillary liquid assets.

2. Investment restrictions

(a) The Company may invest no more than 10% of the net asset value per Subfund in transferable securities or money market instruments of one and the same issuer. The Company may invest no more than 20% of the net asset value per Subfund in deposits made with one and the same institution.

The risk exposure to a counterparty in OTC-derivatives transactions by the Company must not exceed the following percentages:

- 10% of the net asset value of each Subfund when the counterparty is a qualified credit institution;

- and otherwise 5% of the net asset value of each Subfund.

In the case of UCITS, the aggregate risk exposure is determined either by using the Commitment Approach or by means of a model approach (Value-at-risk model), which takes into account all general and specific market risks that may lead to a significant change in the value of the portfolio. If the Commitment Approach is used, the aggregate risk associated with derivatives (market risk) of each Subfund must not exceed the net asset value of the Subfund concerned. If a Subfund uses a value-at- risk (VaR) method to calculate its aggregate risk, the calculation of the VaR is based on a 99% confidence interval. The holding period corresponds to one month (20 days) for the purpose of calculating the aggregate risk.

Subfunds	Relative VaR / Absolute VaR/ Commitment Approach	Benchmark used to calculate the risk exposure (only in the case of relative VaR)
ABSOLUTE RETURN EUROPE EQUITY	Absolute VaR	/
ASIA FOCUS EQUITY	Commitment Approach	/
CHINA EVOLUTION EQUITY	Commitment Approach	/
EMERGING MARKETS EQUITY	Commitment Approach	/
EUROLAND VALUE EQUITY	Commitment Approach	/
EUROPE FOCUS EQUITY	Commitment Approach	/
GERMAN FOCUS EQUITY	Commitment Approach	/
GLOBAL EQUITY INCOME	Commitment Approach	/
HEALTH INNOVATION EQUITY	Commitment Approach	/
JAPAN EQUITY	Commitment Approach	/
LUXURY BRANDS Equity	Commitment Approach	/
SWISS SMALL & MID CAP Equity	Commitment Approach	/
SWISS EQUITY	Commitment Approach	/
US LEADING EQUITY	Commitment Approach	/
US VALUE EQUITY	Commitment Approach	/

(c) Irrespective of the individual maximum limits under (a), a Subfund may invest not more than 20% of its net asset value with a single institution in a combination of:

- transferable securities or money market instruments issued by this institution and/or

- deposits made with this institution and/or

- OTC derivatives transactions undertaken with this institution.

(d) The limit stated in (a), first sentence, is raised to 35% if the transferable securities or money market instruments are issued or guaranteed by an EU member state or by its public local authorities, by a non- EU state or by public international institutions of which at least one EU member state is a member.

If a Subfund invests more than 5% of its net asset value in the debt securities referred to in the above paragraph and which are issued by a single issuer, the total value of such investments may not exceed 80% of the net asset value of the Subfund concerned.

(f) The transferable securities and money market instruments mentioned in (d) and (e) are not taken into account in the calculation of the limit of 40% referred to in (b).

The limits stated in (a) to (e) may not be combined, and thus investments in accordance with (a) to (e) in transferable securities or money market instruments of one and the same issuer or in deposits with the said issuer or in derivatives made with that issuer may not exceed a total of 35% of the net asset value of a Subfund.

Companies which are included in the same group for the purpose of consolidated accounts as defined in the Directive 83/349/EEC or in accordance with recognised international accounting rules are regarded as a single issuer for the purpose of calculating the aforementioned limits.

The investments by a Subfund in transferable securities and money market instruments within the same group may cumulatively not exceed 20% of its net asset value, without prejudice to paragraph (e) above.

(g) Notwithstanding points (a) to (f), the Company is authorised in accordance with the principle of risk diversification to invest up to 100% of the net asset value of a Subfund in securities and money market instruments from different issues, which are issued or guaranteed by an EU member state or by its local authorities, by a member state of the OECD or by public international organisations of which at least one EU member state is a member, provided, however, that the Subfund must hold securities and money market instruments of at least six different issues, whereby the securities and money market instruments of each single issue may not account for more than 30% of the net asset value of the Subfund concerned.

(h) Without prejudice to the limits laid down in (j), the limits laid down in (a) for investments in shares and/or debt securities issued by the same issuer may be raised to a maximum of 20% if the investment strategy of the Subfund is to replicate the composition of a certain stock or debt securities index recognised by CSSF. This depends on the following conditions:

- that the composition of the index is sufficiently diversified;

- that the index represents an adequate benchmark for the market to which it refers;

- that the index is published in an appropriate manner.

The limit laid down in the previous paragraph is raised to 35% where that proves to be justified by exceptional market conditions, in particular in regulated markets where certain transferable securities or money market instruments are highly dominant. The investment up to this limit is only permitted for a single issuer.

(i) A Subfund may acquire units of target funds as defined in 5.1. (d) above, for a maximum of 10% of its net asset value if no investments in target funds beyond this limit are permitted in the section “Investment objectives and policy”. However, if the section “Investment objectives and policy” permits investments in target funds in an amount greater than 10 % of the net asset value of a Subfund, the Subfund may not

- invest more than 20% of its net asset value in one and the same target fund; and

- invest more than 30% of its net asset value in units of target funds that are not UCITS.

When applying these investment limits, each Subfund of a target fund is to be regarded as an independent issuer.

(j)

(B) Moreover, for the respective Subfund the Company may acquire no more than:

- 10% of the non-voting shares from the same issuer;

- 10% of debt securities from the same issuer;

- 25% of the units of the same target fund;

- 10% of the money market instruments of any single issuer.

Paragraphs (A) and (B) shall not apply:

- to transferable securities and money market instruments issued or guaranteed by a EU member state or its local authorities;

- to transferable securities and money market instruments issued or guaranteed by a non-EU state;

- to transferable securities and money market instruments issued by public international institutions of which one or more EU member states are members;

- to shares held by the Company in the capital of a company incorporated in a non-EU state which invests its assets mainly in the securities of issuers having their registered office in that state, where under the legislation of that state, such a holding represents the only way in which the Company can invest in the securities of issuers of that state. This derogation, however, shall only apply if in its investment policy the company from the non-EU state complies with the limits laid down in (a) to (f) and (i) and (j) (A) and (B). Where the limits set in (a) to (f) and (i) are exceeded, (k) shall mutatis mutandis apply;

- to shares held by the Company alone or together with other UCIs in the capital of subsidiary companies which, exclusively on its own or their behalf carry on only the business of management, advice or marketing in the country where the subsidiary is located, in regard to the redemption of shares at the request of shareholders.

(k)

(A) The Company need not comply with the limits laid down herein when exercising subscription rights attaching to transferable securities and money market instruments which form part of its assets. While ensuring observance of the principle of risk diversification, each Subfund may derogate from the rules set out in (a) to (h) for a period of six months following the date of its launch.

(l)

(A) The Company may not borrow. However, the Company may acquire foreign currencies by means of a "back-to-back" loan.

(B) By way of derogation from paragraph (A), the Company may (i) borrow up to 10% of its net asset value per Subfund provided that the borrowing is on a temporary basis, and (ii) borrow up to 10% of its net asset value provided that the borrowing is to make possible the acquisition of immovable property essential for the direct pursuit of its business; in no case may such borrowings and those referred to in (i) together exceed 15% of the net asset value concerned.

(m) The Company or the custodian bank may not grant loans or act as guarantor for third parties for the account of the Subfund, without prejudice to points (a) to (e) under point 1. This shall not prevent the Company from acquiring transferable securities or money market instruments or shares in target funds or financial instruments referred to in (c) and (e) under point 1 which are not fully paid.

(n) The Company or the custodian bank may not carry out uncovered sales of transferable securities, money market instruments, shares in target funds or financial instruments referred to in (c) and (e) under point 1.

(o) The Company may hold liquid assets, which under certain circumstances can be increased to up to 49% of the assets of the relevant Subfund.

3. Further investment guidelines / Investment conditions

(a) The Company will not acquire securities which entail unlimited liability.

(b) The fund’s assets must not be invested in real estate, precious metals, precious metal contracts, commodities or commodity contracts.

(c) The Company can implement further investment restrictions in order to comply with the requirements in countries in which Shares shall be offered for sale.

(d) As a consequence of the registration of the Subfunds GAM Multistock – HEALTH INNOVATION EQUITY and GAM Multistock – LUXURY BRANDS EQUITY for public distribution in Taiwan, the use of derivatives for hedging purposes is only allowed up to a maximum of 100% of the value of the hedged investment and the use of derivatives for efficient management is only allowed up to a maximum 40% of the assets of the Subfunds. Furthermore, at least 70% of the assets of the Subfund must be invested in shares.

(e) The Company invests continually at least 51% of the net assets of the Subfunds EUROLAND VALUE EQUITY, GERMAN FOCUS EQUITY, GLOBAL EQUITY INCOME, HEALTH INNOVATION EQUITY, JAPAN EQUITY, LUXURY BRANDS EQUITY, SWISS SMALL & MID CAP EQUITY, SWISS EQUITY, US LEADING EQUITY and US VALUE EQUITY, respectively, or, as of January 1, 2018, at least 25% of the net assets of the Subfunds CHINA EVOLUTION EQUITY, ASIA FOCUS EQUITY and EMERGING MARKETS EQUITY, respectively, in shares which are admitted to trading on a stock exchange or admitted to another organised market or included therein and which are not units of investment funds or REITs.

6. SPECIAL INVESTMENT TECHNIQUES AND FINANCIAL INSTRUMENTS

In the interests of efficient management or for hedging purposes, the Company may make use of the following investment techniques and financial instruments for each Subfund. It may also use derivative financial instruments for investment purposes if appropriate provision is made for this in the investment policy. It must at all times comply with the investment restrictions stated in Part I of the 2010 Law and in the section "Investment limits" in this prospectus, and must in particular be aware of the fact that the underlying of derivative financial instruments and structured products used by each Subfunds have to be taken into account in the calculation of the investment limits stated in the previous section. The Company will at all times observe the requirements of CSSF Order 10-04 and of the Luxembourg and European regulations issued periodically when using special investment techniques and financial instruments.

In respect of each Subfund, the Company will also take into account the requirement to maintain an appropriate level of liquidity when employing special investment techniques and financial instruments (particularly in the case of derivatives and structured products).

6.1. OPTIONS ON SECURITIES

The Company may, for each Subfund and regarding the permitted investments, buy and sell call or put options as long as they are traded on a regulated market or freely traded options (OTC options), provided the counterparties of such transactions are first class financial institutions specialising in transactions of this kind.

6.2. FINANCIAL FUTURES, SWAPS AND OPTIONS ON FINANCIAL INSTRUMENTS

Subject to the exceptions listed below, futures and options on financial instruments are, as a matter of principle, limited to contracts traded on regulated markets. OTC derivatives may only be concluded if the counterparties are first class financial institutions which specialise in transactions of this kind.

a) Xxxxxx against market risks and risks associated with stock market performance

b) Xxxxxx against interest rate risks

For the purpose of hedging against the risks associated with changes in interest rates the Company may sell interest rate futures and call options on interest rates, buy put options on interest rates and enter into interest rate swaps, forward rate agreements and options on interest rate swaps (swaptions) with first class financial institutions specialising in transactions of this kind as part of OTC transactions for each Subfund.

c) Xxxxxx against inflation risks

For the purpose of hedging against risks resulting from an unexpected acceleration of inflation, the Company may conclude so-called inflation swaps with first class financial institutions specialising in this type of transaction as part of OTC transactions or make use of other instruments to hedge against inflation for each Subfund.

d) Xxxxxx against credit default risk and the risk of a deterioration in a borrower's credit standing

For the purpose of hedging against credit default risk and the risk of losses owing to a deterioration in the borrower's credit standing, the Company may engage in credit options, credit spread swaps ("CSS"), credit default swaps ("CDS"), CDS (index) baskets, credit-linked total return swaps and similar credit derivatives with first class financial institutions specialising in transactions of this kind as part of OTC transactions for each Subfund.

e) Non-hedging transactions ("active management")

The Company may use financial derivatives for the purposes of efficient portfolio management for each Subfund. For instance, the Company may buy and sell forward contracts and options on all types of financial instruments and use derivatives with a view to managing currency fluctuations.

The Company can also enter into interest and credit swaps (interest rate swaps, credit spread swaps ("CSS"), credit default swaps ("CDS"), CDS (index) baskets, etc.), inflation swaps, options on interest rate and credit swaps (swaptions), but also swaps, options or other transactions in financial derivatives in which the Company and the counterparty agree to swap performance and/or income (total return swaps, etc.) for each Subfund. This also comprises Contracts for difference – (“CFD”). A contract for difference is a contract between two parties - the buyer and the seller - which stipulates that the seller will pay the buyer the difference between the current value of an asset (a security, instrument, basket of securities or index) and its value at the time the contract is concluded. If the difference is negative, the buyer owes the seller the (corresponding) payment. Contracts for difference allow Subfunds to take synthetic long or short positions with a variable collateral provision, where - unlike with futures contracts - the maturity date and the size of the contract are not fixed. The counterparties must be first-class financial institutions which specialise in such transactions.

f) Securities forward settlement transactions

In the interests of efficient management or for hedging purposes, the Company may conclude forward transactions with broker/dealers acting as market makers in such transactions, provided they are first class financial institutions specialising in this type of transaction and participate in the OTC markets. The transactions in question include the purchase or sale of securities at their current price; delivery and settlement then take place on a later date that is fixed in advance.

losses from the transaction being paid to the broker/dealer or paid by it to the Company. However, the Company concludes purchase transactions with the intention of acquiring the securities in question.

The Company can pay the normal charges contained in the price of the securities to the broker/dealer in order to finance the costs incurred by the broker/dealer because of the later settlement.

6.3. EFFICIENT PORTFOLIO MANAGEMENT – OTHER INVESTMENT TECHNIQUES AND INSTRUMENTS

In addition to investments in derivative financial instruments, the Company may also make use of other investment techniques and instruments based on securities and money market instruments such as repurchase agreements (repurchase or reverse repurchase transactions) and securities lending transactions pursuant to the terms of the CSSF Circular 08/356 (as last amended and any replacement circular) and the Guidelines of the European Securities and Markets Authority ESMA/2012/832 (as implemented in Luxembourg by the CSSF Circular 13/559 (as last amended by the CSSF Circular 14/592), as well as any other guidelines introduced in this regard. Investment techniques and instruments based on securities and money market instruments that are used for the purposes of efficient portfolio management, including financial derivatives that are not used for direct investment purposes, shall fulfil the following criteria:

a) they are economically appropriate in that they are used cost-effectively;

b) they are used with one or more of the following specific aims:

i. To reduce risk;

ii. To cut costs;

c) their risks are appropriately captured by the Company's risk management process; and

Potential techniques and instruments for efficient portfolio management are detailed below and are subject to the conditions described below.

Efficient portfolio management may possibly have a negative impact on the return for shareholders.

Efficient portfolio management may lead to direct and indirect operational costs that are deducted from the revenue. These costs shall not include hidden charges.

Care shall also be taken to ensure that no conflicts of interest are created to the detriment of investors as a result of efficient portfolio management techniques being applied.

6.4. SECURITIES LENDING

General information

transactions may only be carried out by recognised clearing houses such as Euroclear or Clearstream SA or other recognised national clearing houses or using highly rated financial institutions specialised in this type of transaction, and according to their terms of business. The counterparty to the securities lending agreement must be subject to prudential supervision rules considered by the CSSF to be equivalent to those prescribed by EU Community law. The rights to refund must in principle be protected by collateral security at a value which at the time the contract is entered into and throughout the lending term at least corresponds to the estimated total value of the relevant lent securities; this can be done through the provision of collateral security in the form of fixed-term deposits or securities which are issued or guaranteed by OECD member states, their local authorities or institutions of a supranational or regional character, or by other highly rated issuers, or else through the provision of collateral security in the form of shares in highly rated companies (on condition that hedging is provided against any fall in price between the time the collateral security is created and the time the lent security in question is returned), with such collateral security remaining blocked, on behalf of the Company, until expiry of the applicable securities lending transaction. The collateral received is not re-invested.

The Company must have the right to terminate at any time any securities lending agreement into which it has entered or to recall any security that has been lent.

All revenues arising from efficient portfolio management techniques, net of direct and indirect operational costs/fees, shall be returned to the respective Subfund.

Non-cash collateral received may not be sold, re-invested or pledged during the term of the transaction. Cash collateral received should only be:

- placed on deposit with credit institutions described in Article 50(f) of the UCITS Directive;

- invested in high-quality government bonds;

- invested in short-term money market funds as defined in the CESR's Guidelines on a Common Definition of European Money Market Funds.

Re-invested cash collateral must be diversified in accordance with the diversification requirements applicable to non-cash collateral.

The Section "Risks in conjunction with the use of derivatives and other special investment techniques and financial instruments" contains further risk information in this regard.

Regulation (EU) 2015 / 2365 on transparency of securities financing transactions and reuse and amending Regulation (EU) No 648 / 2012

Unless otherwise stated, the maximum proportion of a Subfund’s assets that can be subject to Securities Lending is maximum 60% of that Subfund’s Net Asset Value. However, the Investment Manager does anticipate that between 0 % and a maximum of 60% of the Net Asset Value of a Subfund will be subject to Securities Lending.

The types of assets that can be subject to Securities Lending transactions are those where such use is consistent with the investment policy of the relevant Subfund.

The revenue received by the respective Subfund arising from Securities Lending transactions is specified in the company’s semi-annual and annual reports.

6.5. SECURITIES REPURCHASE AGREEMENTS

In accordance with the provisions of the CSSF Circular 08/356 and the investment policy of the relevant Subfund the Company may engage in repurchase agreements (“Repurchase Agreements”) and reverse repurchase agreements (“Reverse Repurchase Agreements”) involving the purchase and sale of securities where the seller has the right or obligation to repurchase the securities sold from the buyer at a fixed price and within a certain period stipulated by both parties upon conclusion of the agreement.

The Company may effect repurchase transactions either as a buyer or a seller. However, any transactions of this kind are subject to the following guidelines:

- Securities may only be purchased or sold under a repurchase agreement if the counterparty is a first class financial institution specialising in this kind of transaction and which is subject to prudential supervision rules considered by the CSSF to be equivalent to those prescribed by EU Community law.

- As long as the repurchase agreement is valid, the securities bought cannot be sold before the right to repurchase the securities has been exercised or the repurchase period has expired.

At the time of preparation of this Prospectus, none of the Company’s Subfunds were invested in repurchase agreements, in accordance with Regulation (EU) 2015/2365 on the transparency of securities financing transactions and with Regulation (EU) No 648/2012 in its original and subsequent amended versions. Should this change in future, the Prospectus will be amended accordingly at the time of the next submission.

6.6. MANAGEMENT OF COLLATERAL FOR OTC DERIVATIVES AND EFFICIENT PORTFOLIO MANAGEMENT TECHNIQUES

The following provisions are in line with the requirements of the Guidelines of the European Securities and Markets Authority ESMA/2012/832, which may be amended in future.

(d) Correlation: The collateral must be issued by an entity that is independent from the counterparty and is expected not to display a high correlation with the performance of the counterparty.

(e) Diversification: Collateral should be sufficiently diversified in terms of countries, markets and issuers. The criteria of sufficient diversification in terms of the concentration of the issuers is deemed to be fulfilled when a Subfund receives from the counterparty a collateral basket, in which the maximum exposure towards a particular issuer does not exceed 20%. When a Subfund is exposed to different counterparties, the different baskets of collateral should be aggregated to calculate the 20% limit of exposure to a single issuer.

By way of derogation from this sub-paragraph, a Subfund may be fully collateralised in different transferable securities and money market instruments issued or guaranteed by a Member State, one or more of its local authorities, a third country, or a public international body to which one or more Member States belong. Such a Subfund should receive securities from at least six different issues, but securities from any single issue should not account for more than 30% of the Subfund’s net asset value. Subfunds that intend to be fully collateralised in securities issued or guaranteed by a Member State should disclose this fact in the Special Part of the Prospectus. Subfunds should also identify the Member States, local authorities, or public international bodies issuing or guaranteeing securities which they are able to accept as collateral for more than 20% of their net asset value.

(f) Immediate availability: The Company must be able to realise the collateral at any time without reference to the counterparty or requiring the counterparty's approval.

2. Subject to the above criteria, collateral admissible for any Subfund must meet the following requirements:

(b) Bonds issued or guaranteed by a member state of the OECD.

4. The Company has introduced a haircut strategy for each class of assets received as collateral. A haircut is a deduction from the value of collateral to take account of a deterioration in the valuation or in the liquidity profile of the collateral over time. The haircut strategy takes into account the characteristics of the respective assets, including the credit standing of the issuer, price volatility and the outcome of stress tests performed as part of collateral management. Subject to existing transactions with the counterparty concerned, which may include minimum amounts for the transfer of collateral, the Company intends applying a haircut of 2% to collateral received (as defined in No. 2b), at least corresponding to the counterparty risk.

5.Risks and potential conflicts of interest in conjunction with OTC derivatives and efficient portfolio management

6.7. TECHNIQUES AND INSTRUMENTS FOR HEDGING CURRENCY RISKS

or to completely eliminate such risk and to shift into the reference currency or into another of the permissible currencies that is deemed to present less risk for each Subfund.

Currency futures and swaps may be executed by the Company in the open market with first class financial institutions specialising in this kind of transaction.

6.8. STRUCTURED PRODUCTS

The Company may use structured products in the interests of efficient management or for hedging purposes for any Subfund. The range of structured products includes in particular credit-linked notes, equity-linked notes, performance-linked notes, index-linked notes and other notes whose performance is linked to basic instruments which are permitted in accordance with Part I of the 2010 Law and the associated implementing regulations. For this, the counterparty must be a first class financial institution specialising in this type of transaction. Structured products are combinations of other products. Derivatives and/or other investment techniques and instruments may be embedded in structured products. In addition to the risk features of securities, those of derivatives and other investment techniques and instruments therefore also have to be noted. In general, they are exposed to the risks of the markets or basic instruments underlying them. Depending on the structure, they may be more volatile and thus entail greater risks than direct investments, and there may be a risk of a loss of earnings or even the total loss of the invested capital as a result of price movements on the underlying ma rket or in the basic instrument.

6.9. SWAPS AND OTHER FINANCIAL DERIVATIVES WITH COMPARABLE PROPERTIES

General Information

The Subfunds may invest in total return swaps or other derivatives with comparable properties, which can be defined as follows:

- The underlyings of the total return swaps or other derivatives with comparable properties include in particular individual equities or bonds, baskets of equities or bonds, or financial indices that are permitted in accordance with paragraphs 48-61 of ESMA Guidelines 2012/832. The components of the financial indices include, among others, equities, bonds, derivatives on commodities. The investment policy of the various Subfunds includes further details on the deployment of total return swaps or other derivatives with comparable properties, which may have different underlyings and strategies compared with those described above.

- The counterparties of such transactions are regulated financial institutions with a good credit rating and that specialise in such transactions.

- The failure of a counterparty may have a negative impact on the return for shareholders. The asset manager intends to minimise counterparty performance risk by only selecting counterparties with a good credit rating and by monitoring any changes in those counterparties' ratings. Additionally, these transactions are only concluded on the basis of standardised framework agreements (ISDA with Credit Support Annex; Deutscher Rahmenvertrag with Besicherungsanhang, or similar). The Credit Support Annex or Besicherungsanhang defines the conditions under which collateral is transferred to or received from the counterparty in order to reduce the default risk associated with derivative positions and thus the negative impact on the return for shareholders should a counterparty fail.

-Total return swaps or derivatives with comparable properties will be included in the calculation of the investment restrictions.

Regulation (EU) 2015 / 2365 on transparency of securities financing transactions and reuse and amending Regulation (EU) No 648 / 2012

At the time of the preparation of this prospectus the following Subfunds employed total return swaps (included equity swaps and contracts for difference). The following table sets out the maximum and the expected proportion of the Subfunds’ assets under management that could be subject to these instruments. Should this change in future, the Prospectus will be amended accordingly at the time of the next submission.

Subfunds	Total Return Swaps (including Equity Swaps and CFD)
Subfunds	Maximum value	Expected value
ABSOLUTE RETURN EUROPE EQUITY	300%	100%
ASIA FOCUS EQUITY	10%	0%
CHINA EVOLUTION EQUITY	10%	0%
EMERGING MARKETS EQUITY	100%	20%
US LEADING EQUITY	10%	0%

The types of assets that can be subject to total return swaps are those where such use is consistent with the investment policy of the relevant Subfund.

All revenues from total return swaps entered into by a Subfund, net of direct and indirect operational costs, will be returned to the relevant Subfund. The identities of the entities to which any direct and indirect costs and fees are paid shall be disclosed in the annual financial statements of the Company and such entities may include the Management Company, the Depositary or entities related to the Depositary. In selecting counterparties to these arrangements, the Investment Manager may take into account whether such costs and fees will be at normal commercial rates. Further information regarding transactions with related parties are available in Chapter 27.

6.10. INVESTMENTS IN FINANCIAL INDICES PURSUANT TO ARTICLE 9 OF THE GRAND DUCAL ORDINANCE OF 8 FEBRUARY 2008‌

The Company may invest in Derivatives with indices as their underlying, and may increase the diversification limits for an index component pursuant to Article 44 of the 2010 Law.

- In the case of derivatives that are traded on a stock market, the rebalancing merely changes the calculation but has no direct or indirect impact on the costs of the corresponding Subfund.

In the case of investments in commodity indices, the following rules also apply:

6.11. RISKS ASSOCIATED WITH THE USE OF DERIVATIVES AND OTHER SPECIAL INVESTMENT TECHNIQUES AND FINANCIAL INSTRUMENTS‌

Prudent use of these derivative and other special investment techniques and financial instruments may bring advantages, but does also entail risks which differ from those of the more conventional forms of investment and in some cases may be even greater. The following general outline covers important risk factors and other aspects relating to the use of derivative and other special investment techniques and financial instruments and on which the shareholders should be informed before investing in a Subfund.

- Monitoring and control: Derivatives and other special investment techniques and financial instruments are specialised products which require different investment techniques and risk analyses than equities or bonds. The use of derivatives requires not just knowledge of the underlying instrument, but also of the derivative itself, although the performance of the derivative cannot be monitored under all the possible market conditions. The complexity of such products and their use in particular require suitable control mechanisms to be set up for monitoring the transactions and the ability to assess the risks of such products for a Subfund and estimate the developments of prices, interest rates and exchange rates.

- Counterparty risks: There is a risk that a counterparty will not be able to fulfil its obligations (performance risk)and/or that a contract will be cancelled, e.g. due to bankruptcy, subsequent illegality or a change in the tax or accounting regulations since the conclusion of the OTC derivative contract and/or that the counterparty will fail to meet one of its financial obligations or liabilities towards the Subfund (credit risk). This relates to all counterparties with which derivative, repurchase, reverse repurchase or securities lending transactions are entered into. A direct counterparty risk is associated with trading in non-collateralised derivatives. The respective Subfund can reduce a large proportion of the counterparty risk arising from derivative transactions by demanding that collateral at least in the amount of the commitment be provided by the respective counterparty. If, however, derivatives are not fully collateralised, the failure of the counterparty may cause the Subfund's value to fall. New counterparties are subject to a formal review and all of the approved counterparties are subsequently monitored and reviewed on an ongoing basis. The Company ensures that its counterparty risk and collateral management are actively managed.

A Subfund may invest in markets in which the deposit and/or settlement systems are not yet fully developed. The assets of the Subfunds traded on these markets and entrusted to these sub-depositaries may possibly be exposed to risk in cases in which the depositary is not liable.

- Risks associated with credit default ("CDS") transactions: The purchase of CDS protection allows the Company, on payment of a premium, to protect itself against the risk of default by an issuer. In the event of default by an issuer, settlement can be effected in cash or in kind. In the case of a cash settlement, the

Aside from the general counterparty risk (see "Counterparty risks", above), upon the conclusion of credit default swap transactions there is also in particular a risk of the counterparty being unable to establish one of the payment obligations which it must fulfil. The different Subfunds which use credit default swaps will ensure that the counterparties involved in these transactions are selected carefully and that the risk associated with the counterparty is limited and closely monitored.

- Risks associated with credit spread swap ("CSS") transactions: Concluding a CSS allows the Company, on payment of a premium, to share the risk of default by an issuer with the counterparty of the transaction concerned. A CSS is based on two different securities with differently rated default risks and normally a different interest rate structure. At maturity, the payment obligations of one or another party to the transaction depend on the differing interest rate structures of the underlying securities.

Aside from the general counterparty risk (see "Counterparty risks", above), upon the conclusion of CSS transactions there is also in particular a risk of the counterparty being unable to establish one of the payment obligations which it must fulfil.

On the sale of an inflation swap protection the Subfund enters into an inflation risk which is comparable to the purchase of a normal nominal bond in relation to an inflation-indexed bond: If actual inflation is lower than that expected at the time the transaction was entered into and accounted for in the price of the contract, the sale of the inflation swap protection results in higher performance; in the opposite instance it results in lower performance than if the protection had not been sold.

Aside from the general counterparty risk (see "Counterparty risks", above), upon the conclusion of inflation swap transactions there is also in particular a risk of the counterparty being unable to establish one of the payment obligations which it must fulfil.

- Risks involved in contracts for difference (“CFD”): Unlike with direct investments, in the case of CFDs the buyer may be liable for a considerably higher amount than the amount paid as collateral. The Company will therefore use risk management techniques to ensure that the respective Subfund can sell the necessary assets at any time, so that the resulting payments in connection with redemption applications can be made from redemption proceeds and the Subfund can meet its obligations arising from contracts for difference and other techniques and instruments.

- Other risks/derivatives: The use of derivative and other special investment techniques and financial instruments also entails the risk that the valuations of financial products will differ as a result of different

6.12. LEVERAGE

For the Subfund(s) listed below, the market risk which is taken by using derivative financial instruments is monitored and limited by means of the absolute Value at Risk method (“VaR method”) (see section 5 “Investment limits”, under point 2. (a)), as provided for in CSSF circular 11/512.

The CSSF permits two methods of calculating leverage: a) the sum of notional approach with no consideration of any netting and hedging arrangements, and b) the Commitment Approach, as outlined in more detail below.

With regard to a) the sum of notional approach

Under normal market conditions, it is expected that the level of leverage, in terms of fund volume, shall range between the following values. These values are to be understood as providing a rough indication and the higher values should not be taken as maximum limits:

GAM Multistock	Target value
ABSOLUTE RETURN EUROPE EQUITY	0% - 300%

The leverage refers to the ratio between (i) the market exposure – generated by the use of derivative financial instruments – that exceeds the assets of the Subfund and (ii) the Subfund’s assets.

With regard to b) Commitment-Approach

With this approach, which is permitted by the CSSF as an additional method of calculation in which netting and hedging may be taken into account, it is expected that the level of leverage shall range between the following values:

GAM Multistock	Target value
ABSOLUTE RETURN EUROPE EQUITY	0% - 300%

In addition, the Subfund(s) listed above may not borrow for investment purposes – an exception to this rule is temporary borrowing of up to 10% of the Subfund’s net asset value, as described in section 5 “Investment limits” (under 2. (l) (B)).

6.13. RISKS ASSOCIATED WITH INVESTMENTS IN THE PEOPLE'S REPUBLIC OF CHINA (PRC)

Where indicated in the relevant investment policy, the respective Subfund may invest directly in so-called “China- A” shares. “China-A” shares are quoted in Renminbi on the stock exchanges of Shanghai and Shenzhen, of companies founded on mainland China and can be purchased within the possibilities described below:

Renminbi Qualified Foreign Institutional Investor ("RQFII")

In the PRC's markets for domestic securities, foreign investors may invest via an approved foreign institutional investor or an investment manager which has been granted the status of qualified foreign institutional investor ("QFII") or Renminbi qualified foreign institutional investor ("RQFII") by the China Securities Regulatory

Commission (CSRC) and which has been allocated a quota or quota's by the the State Administration of Foreign Exchange ("SAFE") of the PRC.

Subject to the requirement that GAM International Management Limited (the "Investment Manager") obtains the necessary RQFII license, it is intended that the Subfunds, where indicated in the relevant investment policy, may invest in securities issued in the PRC as part of the RQFII quotas of the investment manager. According to the guidelines of the RQFII quota management of SAFE, the Investment Manager may allocate its RQFII quotas flexibly to various open-ended fund products or, subject to the approval of SAFE, to products and/or accounts that are not open-ended Subfunds. The Investment Manager may therefore allocate additional RQFII quotas to each relevant Subfund or allocate RQFII quotas which would otherwise have been accorded to the Subfund to other products and/or accounts. The Investment Manager may also request additional RQFII quotas from SAFE, which it can use for the relevant Subfund, other clients or other products it manages. However, no assurance can be given that the Investment Manager will provide RQFII quotas to the relevant fund at all times that are sufficient for its investments.

The current RQFII regulations impose strict restrictions on investments (including rules on investment restrictions, the minimum holding period for assets and for the repatriation of capital and profits). These apply to the Investment Manager and not only to the investments made by the Subfund. Investors should thus be aware that violations of the RQFII regulations for investments that result from actions of the Investment Manager could lead to the withdrawal of the quota or other supervisory measures in relation to the quota, including of another portion that is used by the Subfund for investments in RQFII-eligible securities.

Special risks

 Investments in the PRC are subject to the risks of investments in emerging markets (please see the comments in the respective investment policy of the relevant Subfund) and, in addition, to risks specific to the market in the PRC. The economy in the PRC is in transition from a planned economy to a more market- oriented economy. Investments could react sensitively to changes in laws and regulations, as well as in political, social or economic conditions, including possible government intervention. In exceptional circumstances, due to limited investment opportunities a Subfund may suffer losses or not be able to fully implement or pursue its investment objectives or strategy due to local investment restrictions, the illiquidity of the Chinese market for domestic securities and/or delays or interruptions in the execution and settlement of transactions.

 The yuan renminbi ("CNY") is currently not a freely convertible currency, as it is subject to exchange control regulations and repatriation restrictions imposed by the PRC. Future changes to these regulations could have a negative impact on the situation of the Subfund. There is no guarantee that there will not be a devaluation of the CNY, which may negatively impact the value of investments.

 Although the onshore and offshore Renminbi (CNY and CNH) are the same currency, they are traded on several separate markets. CNY and CNH are traded at different prices and sometimes move in different directions. Although more and more Renminbi are held abroad (i.e. outside of China), the CNH cannot be used freely in the local market and is subject to certain restrictions (the same applies conversely). Investors should note that subscriptions and redemptions of the Subfund are made in EUR and/or the alternative unit class currency and are converted into CNH for investment in local securities. Investors shall bear for the resulting conversion charges and the risk of potential differences in the exchange rate between the CNY and the CNH. The price and liquidity of and the trading in shares of the relevant Subfund may also be influenced by the exchange rate and the liquidity of the Renminbi in the global market.

 Investors should note that the RQFII status could be suspended, reduced or withdrawn, which may adversely affect the performance of the Subfund, as debt instruments denominated in CNY would have to be liquidated in this case.

Shanghai or Shenzhen Hong Kong Stock Connect Programme

The respective Subfund may invest directly in certain permissible China A shares through the Shanghai or Shenzhen Hong Kong Stock Connect Programme (the “Stock Connect Programme”). The Stock Connect Programme is a securities trading and clearing programme developed by Hong Kong Exchanges and Clearing

Limited (“HKEx”), the Shanghai Stock Exchange (“SSE”) or the Shenzhen Stock Exchange (“SZSE”) and China Securities Depository and Clearing Corporation Limited (“ChinaClear”), whose objective is to provide mutual access to the stock markets of Hong Kong and the PRC.

Under the Stock Connect Programme, foreign investors (including the Subfunds) can trade certain China A shares listed on the SSE and SZSE (the “SSE securities” or “SZSE securities”, collectively the “SSE/SZSE securities”) (known as Northbound Trading), subject to the currently applicable regulations governing the Northbound Trading Link. Conversely, investors in Mainland China have an opportunity to participate through the SSE or SZSE and clearing houses in Shanghai or Shenzhen (Southbound Trading) in trading in selected securities listed on the HKEx.

The SSE securities comprise the scope of all shares contained at the relevant time in the SSE 180 Index and in the SSE 380 Index, as well as all China A shares listed on the SSE. The SZSE securities contain all shares included in the SZSE Component index and the SZSE Small/Mid Cap Innovation Index at the respective time, which show a market capitalization of at least RMB 6 billion and all A shares traded on the SZSE that have a respective H-Share, and are listed on the Stock Exchange of Hong Kong Limited ("SEHK") except for (i) SZSE shares that are not traded in RMB and (ii) SZSE shares that are under risk monitoring.

Furthermore, shareholders’ attention is drawn to the fact that under the applicable ordinances, a security may be removed from the scope of the Stock Connect Programme. This may impair the ability of the Subfund concerned to achieve its investment objective, for example, if the investment manager would like to buy a security tha t has been removed from the scope of the Stock Connect Programme.

Further information as well as the types of shares traded on the Stock Connect Programme can be obtained and reviewed on the HKEx website.

Apart from risks connected with investments in international markets and emerging countries, and other general investment risks, which are described above and also apply to investments in China, investors should also consider the additional specific risks related to Shanghai-Hong-Kong Stock Connect, which are set out below:

Quota Risk

Trading is also subject to a cross-border maximum quota (“Aggregate Quota”) and to a daily quota (“Daily Quota”). The Aggregate Quota relates to the restriction on the absolute funds flows to Mainland China through the Northbound trading link. The Daily Quota restricts the maximum net buying trades that may be conducted in cross-border trading on a daily basis under the Stock Connect Programme. As soon as the remaining balance of the Northbound Daily Quota reaches zero or is exceeded at the beginning of a session, new buying orders may be rejected.

In addition, there are restrictions on the aggregate holdings of foreign investments that apply to all investors from Hong Kong and abroad, as well as restrictions on the holdings of individual investors from abroad. On account of this quota restriction, impairments may occur if a pending investment in China A shares is not possible through the Stock Connect Programme and, as a result, the investment strategy cannot be efficiently implemented.

Restriction of Foreign Share Ownership

The PRC requires that the existing buying restrictions for foreign investors also be applied in conjunction with the Stock Connect Programme. Hong Kong and foreign investors come within the scope of this restrictions on share ownership. The limits may be altered at any time and are currently as follows:

- Shareholdings of foreign individual investors (including the Subfund), of each Hong Kong or foreign investor in China A shares, may not exceed 10% of the shares issued.

- Shareholdings of all foreign investors, of all Hong Kong and foreign investors in China A shares may not exceed 30% of the shares issued.

SSE Price Limit

SSE securities are subject to a general price limit, which is calculated on the basis of the closing price of the previous day. The price limit for shares and investment funds is currently between +/-10% and for shares under special treatment +/-5%. All orders must be within this price limit, which may change from time to time.

Exposure Risk

Both the SEHK and the SSE or SZSE reserve the right to suspend trading if it is necessary to ensure an orderly and fair market, and to control the risks prudentially. This may have a negative influence on the ability of the Subfund concerned to gain access to the market of the PRC.

Different Trading Days

The Stock Connect Programme is only available when both the markets in the PRC and those in Hong Kong are open for trading, and when the banks in both markets are also open on the settlement days concerned.

It may therefore happen that it is a usual trading day for the market in the PRC, whereas the market in Hong Kong is closed and investors from Hong Kong (such as, for example, the Subfunds) cannot trade China A shares. During this period, the Subfund concerned may be exposed to the risk of price fluctuations on China A shares owing to the fact that the Stock Connect Programme is not available for trading.

Short Selling

The legal regulations of the PRC provide that sufficient shares must be available on the account before an investor may sell shares. If this is not the case, the SSE or SZSE rejects the sales orders concerned. Before trading, the SEHK checks the sales orders of its exchange participants (i.e. share brokers) in relation to China A shares in order to make sure that no short selling is taking place.

Clearing and Settlement Risks

The Hong Kong Securities Clearing Company Limited (“HKSCC”) and ChinaClear provide the clearing connection by entering into mutual shareholdings in order to facilitate the clearing and settlement of cross-border transactions. As the national central counterparty for the PRC’s securities market, ChinaClear operates a comprehensive network with clearing, settlement and share depository infrastructure. ChinaClear has established a risk management concept and measures that are approved and monitored by the China Securities Regulatory Commission (“CSRC”).

In the unlikely event of a payment default by ChinaClear and the latter being unable to meet its payment obligations, HKSCC shall only be liable in its clearing contracts with the market participants of the Northbound trading link to the extent that these market participants will receive support in enforcing their claims against ChinaClear. The HKSCC will attempt in good faith to settle and obtain the outstanding securities and funds through the available legal channels or apply for liquidation of ChinaClear. In this case, the Subfunds may only be able to call in their losses resulting from transactions with ChinaClear late or not in their entirety. On the other hand, an omission or a delay on the part of HKSCC in fulfilling its obligations may lead to a settlement failure or the loss of Stock Connect securities or related funds, which may subsequently cause losses to the Subfunds and their shareholders.

Nominee Arrangements for the Holding of China A Shares

If the Subfund concerned acquires SSE/SZSE securities through the Stock Connect programme, HKSCC is the “nominee holder”. HKSCC for its part holds the Stock Connect shares of all participants as a single nominee through a collective securities account (single nominee omnibus Securities account), which is held in its name with ChinaClear. HKSCC acts only as the nominee holder, whereas the Subfunds remain the beneficial owners of the Stock Connect shares.

The Stock Connect rules laid down by the CSRC expressly provide that investors who acquire SSE / SZSE securities through the Stock Connect Programme can enforce their rights, which are in accordance with currently applicable Chinese law. However, it is uncertain whether the Chinese courts would recognize the ownership rights of Stock Connect investors and would give them the opportunity to take legal action against Chinese companies, if this were necessary.

Therefore the Subfund concerned and the Custodian Bank cannot ensure that the ownership of these securities by the Subfund concerned is guaranteed under all circumstances.

Furthermore, according to the HKSCC Clearing rules for securities listed or traded on the SEHK, HKSCC as the nominee holder is not under any obligation to take legal action or to conduct judicial proceedings to enforce rights for investors in relation to SSE / SZSE securities in the PRC or elsewhere. Therefore problems or delays may occur for the Subfund concerned in enforcing its rights in relation to China A shares, even if the ownership of the corresponding Subfund is ultimately recognized.

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