Invesco Luxembourg Management Company

Invesco Management S.A. is required by Luxembourg Anti-money Laundering Regulations to maintain updated and valid records for all Clients invested in our funds. As such, please be advised that we perform periodic reviews of our client records and may need to contact you from time to time to request new ID documentation and other details. Similarly, we encourage all our Clients to notify us should your contact details change. Maintaining your account up-to-date will enable us to continue to operate your account and help prevent the risk of any fraudulent attempts on your account. 

We are sorry if you have had cause to complain to Invesco Management S.A. We strive to provide investors of the investment funds under our management (the “Funds”) with outstanding service. As part of this service, it is our policy to handle investor complaints in a fair and efficient manner. We will consider your complaint on its merits and we commit to treating you fairly and reasonably.

We recognise investor complaints as an invaluable source of feedback which helps us to understand what our investors need and expect from our service.

A person is an eligible complainant if:

• They are or have been a shareholder/ unitholder of our Funds and the complaint arises as a result of a matter relating to this relationship;
• The complaint arises out of our actions or failure to act for the complainant in his/her capacity as a shareholder/ unitholder of our Funds.

Complaints office
For all complaints except in relation to the Zodiac Fund

The Bank of New York Mellon SA/NV Luxembourg branch
C/o Invesco Transfer Agency
BP 648
L-2016 Luxembourg
Email: queries@invesco.com

Complaints office (Zodiac Fund)
International Financial Data Services
C/o Invesco Transfer Agency
47 Avenue J.F. Kennedy
L-1855 Luxembourg
Email: Luxembourg-IFDS-MgtCustomerServicesManagers@statestreet.com

Complaints Note
All complaints are recorded upon receipt. You will be informed of the name of the person responsible for investigating and responding to your complaint. This person shall have the authority to settle the complaint (including the offering of redress, where appropriate).

We will deal with your complaint according to the following procedures:

• Acknowledgement of your complaint will be made within 10 business days of our receipt of the written complaint. This acknowledgement may be combined with our final response if we are able to review and issue our response within that timescale. Acknowledgments will be made by phone, fax, post or email.
• We will provide you with a regular written update on the progress of the investigation of the complaint at intervals of not greater than 10 business days if not resolved within 10 business days.
• We aim to resolve all complaints within one month of their receipt. If we are unable to do so, we will inform you of the cause for the delay and the anticipated timeframe for resolution. We will also remind you of your right to refer your complaint to the Luxembourg regulator, the Commission de Surveillance du Secteur Financier (“CSSF”), as further noted below.
• Once the review of your complaint is completed, we will issue a written response which will include the conclusion of our review and if applicable the terms of any offer or settlement, as appropriate.  

Alternative Dispute Resolution
In case you might not receive an answer or you are not satisfied with the answer received, you may contact in writing Invesco Management S.A.’s Conducting Officer responsible for complaints handling:

Mr Peter Carroll
Conducting Officer responsible for complaints handling
37A Avenue JF Kennedy
1855 Luxembourg

If, after that and despite our best efforts, you find our response to be unsatisfactory, you will have the right to contact the CSSF directly at the address below. As per the regulations, this must be only after one (1) month from the date you submitted your complaint in writing to the Conducting Officer responsible for complaints handling and you have not received an answer or a satisfactory answer, but no later than one (1) year afterwards.

Commission de Surveillance du Secteur Financier
Département Juridique –Service JUR – CC
283, route d’Arlon
L-1150 Luxembourg
Email: reclamation@cssf.lu

The CSSF Regulation 16-07 relating to out-of-court complaint resolution and the admissibility criteria for the CSSF to consider a complaint can be found on the CSSF website (www.cssf.lu)

• View the Statement
• Principal adverse impact statement summary

Disclosure related to Investment advice
Invesco manages its investment advice service and advisory mandates in line with client requirements. Thus far, our clients have not requested that we consider PAIs when providing them with financial advice. As we expand our business to offer this service more widely, we will develop a process to consider PAIs when providing financial advice akin to the process we follow when making investment decisions as a financial market participant. Any such process will involve consideration of PAIs by reference to the indicators listed in Table 1 of Annex I of the SFDR Delegated Regulation, provided that such indicators are relevant to the strategy or one-off advice being given and subject to the availability of reliable data. Nonetheless, where Invesco recommends financial products manufactured by Invesco entities in scope of this policy, consideration of PAIs will apply in accordance with this policy for such financial products.

EMT costs and charges: Costs and charges for our Luxembourg domiciled funds that you may require under MiFID II. 

Please note
Kindly note that not all share classes are suitable for all investors and investors should ensure that they comply with the restrictions applicable to the share classes as disclosed in the relevant legal documentation of the fund. Availability of a share class could vary from jurisdiction to jurisdiction. To obtain further information on the availability of share classes in your jurisdiction, please refer to the appropriate internet site or your local Invesco office.

As of April 2023, FinDatEx introduced the European MiFID Template (EMT) v4.2 with an additional UK specific section linked to PRIN 2A.4 regulation.

If you have any questions or require any further assistance, please reach out to your usual Invesco contact or alternatively EMEA-GDS Regulatory Reporting.

Download: EMT V4.2 covering Invesco’s SICAV, ICVC, Investment Trust, Markets III plc, Liquidity, Zodiac, GRAF and Global Property Plus product ranges.

ESG data that you may require under MiFID II and IDD:

Download