Business ethics and integrity

As a specialty investment manager, our mission is to provide access to attractive and innovative investment opportunities, thereby creating value for investors and shareholders. We commit to doing so in alignment with applicable legal requirements, in particular including counterterrorism and anti-corruption efforts.

Reputation and trust are the cornerstones of our business success as a specialty investment manager. Reputation and trust amongst stakeholders must be earned over the long haul. For a financial group with regulated asset management operations in Switzerland, Germany and the UK, compliance with all relevant laws and regulations, including best practice guidelines, is vital from both a regulatory and a business perspective.

We have built a solid reputation based on a history of transparency and respect towards our stakeholders. Integrity is part of our DNA, and our stakeholders expect it in everything we do. We place great importance on accountability and ethics in our business practices to maintain our good reputation. We adhere to the highest ethical and corporate governance standards, to which every Bellevue employee is contractually obligated. Infringements can lead to disciplinary measures. The existing whistleblower hotline gives internal and external stakeholders the opportunity to identify potential cases.

As an international financial services group headquartered in Switzerland and listed on the SIX Swiss Exchange, we meet the requirements of the Directive on Information Relating to Corporate Governance of the SIX Swiss Exchange as well as all of the national and local requirements wherever we do business.

Bellevue is committed to respecting, protecting and promoting the human rights enshrined in the Swiss Federal Constitution and the European Convention on Human Rights in all its activities.

Training everyone on our staff on relevant compliance topics (including anti-corruption) is an important part of adhering to our compliance requirements. New employees receive compliance training when they join the company. In addition, specific in-person training sessions are held periodically.

We communicate our corporate governance approach to our shareholders, potential investors and the public through our Corporate Governance Report and this Sustainability Report. The following important directives and regulations can also be downloaded from our website:

Bellevue has a directives system in place, and we disclose these directives to the public. These are reviewed semi-annually with the head of sales and supplemented as necessary or as requested by clients (in RFPs). All regulations and directives are scrutinized annually and adapted if necessary. Regulations are submitted to executive management and are subject to approval by Bellevue’s Board of Directors. Directives are approved by executive management case by case. Certification through an online tool provided by ComplySci is issued to employees annually, requiring each individual to understand and adhere to the content at all times. Violations of regulations and directives may have employment law consequences and possibly entail claims for damages.

New employees are informed about regulations and directives upon joining the organization and must confirm their understanding and compliance within one month.

Bellevue recognizes the importance of having and consistently upholding a robust human rights framework, both for Bellevue itself and the investee companies in its investment portfolios. Investments undergo systematic assessment for sustainability risks and human rights violations, with MSCI’s ESG data and ratings used for reference. In the event of issues, discussions are initiated with portfolio companies, and investments may be subject to review. Bellevue upholds human rights in its employment policies and practices. Bellevue does not invest in entities responsible for serious environmental damage or human rights violations, or in those subject to targeted sanctions. Due diligence is conducted before making any investment decisions. A Human Rights Directive is scheduled for development and publication in 2024.

Bellevue pledges to prevent incidents related to corporate ethics and integrity as far as possible. In addition, these aspects will be considered in management performance evaluations.

Activities carried out in 2023 to achieve set goals included the following:

• Data protection and market conduct training for all employees
• Team-specific training is mandatory in certain areas (e.g., ESG for all; cross-border for the sales team).
• Annual certification of compliance with all regulations and directives by all employees
• New employees undergo 1-to-1 training, including an explanation of the directives system, followed by confirmation of understanding and compliance.
• Annual reviews of all regulations and directives are conducted, and adjustments are made in-year in response to any changes.

Despite the absence of incidents or major violations in 2023 and 2022, vigilance remains high in this area because potential incidents can have serious consequences.

Anti-corruption

Bellevue is committed to complying with internationally recognized standards, with anti-corruption being a crucial part of our compliance requirements. Effective compliance is the basis for long-term business success and therefore a linchpin of our operations. Bellevue implements comprehensive measures to ensure consistent compliance with laws and regulatory requirements. As part of a Group-wide risk analysis and using appropriate compliance processes, all subsidiaries and business units are checked at least annually for compliance with the law.

A major focus of our risk analysis is identifying risks related to money laundering or funding terrorism, with the aim of avoiding business relationships susceptible to these and other such risks. Additionally, Bellevue avoids establishing relationships with politically exposed persons (PEPs). Any PEP relationships established by way of exception are closely monitored. Compliance adherence is reported to management monthly. Significant cases are presented to Bellevue’s Audit and Risk Committee.

In addition to compliance, our Group-wide risk management also covers fraud and cyber risks, encompassing all our locations in the reporting year and the previous year.

The Anti-Money Laundering Unit is part of the Compliance Office. New employees are told about the compliance obligations applicable to them and how they are implemented in day-to-day operations. The Compliance Office keeps employees informed about new rules and their consequences. All Bellevue employees, including the Board of Directors, are regularly required to complete e-learning modules in the area of cyber security, including anti-corruption and data privacy.

There were no cases of corruption or suspicious activity reports to the Money Laundering Reporting Office Switzerland ( «MROS») in the 2023 and 2022 fiscal years. Despite no incidents being recorded in either fiscal year, this is still a pivotal issue as a potential incident can have serious consequences.

Corporate Governance

Bellevue Group AG acknowledges that robust corporate governance practices and a clear management structure with clearly defined roles and responsibilities are critical to the company’s long-term success. The corporate governance practices of Bellevue Group AG comply with the rules and regulations of SIX Swiss Exchange. We disclose transparent information about our governance practices. This enables our stakeholders to analyze qualitative aspects of the company and supports investors in their investment decisions.

Corporate Governance Directive: As a listed company, we disclose transparent information on corporate governance matters in our annual report in accordance with the Directive on Information relating to Corporate Governance (DCG).

Compensation: A compensation report that is audited by independent auditors contains information on compensation paid to members of the Board of Directors and the Group Executive Board.

Competence: The four-member Board of Directors is an international and interdisciplinary body of experts with profound knowledge in various subjects. A clearly defined, balanced separation of roles and responsibilities between the Board of Directors and the Group Executive Board is an important element of corporate governance. All country-specific legal requirements are adhered to. The issue of sustainability is addressed at every regular meeting.

Please consult the Corporate Governance section for further information on the leadership structure, the composition, the nomination and selection process for the highest governance body, the chair of the highest governance body, the aggregate knowledge of the highest governance body, and the measurement and evaluation of the performance of the highest governance body.

Compliance with laws and regulations

Responsibilities for compliance with laws and regulations are clearly assigned at Bellevue. Our employees are informed about their individual duties and responsibilities and receive regular training on legal requirements at least once a year to ensure they possess the knowledge they need to act correctly. There were no significant breaches of laws or regulations in the reporting year or the previous year and no fines were paid or non-monetary sanctions imposed on Bellevue.

If there are critical concerns or cases of suspected violations of legal or regulatory provisions, internal guidelines or ethical standards, employees and third parties have the opportunity to report these incidents anonymously via the external Bellevue whistleblowing platform. Employees can access the whistleblowing tool straight from the start menu of their PCs. Third parties can access it directly via the Bellevue website (using the link in the Whistleblowing Directive). If an incident is reported, the HR department will be notified. The HR department, CFO and/or Head of Compliance agree on how to proceed and which governing body should be involved, depending on the severity. Bellevue investigates every incident brought to its attention. In the last two fiscal years, no incidents were reported by internal employees or third parties via the whistleblowing platform.

If Bellevue receives a customer complaint in writing or by telephone, Compliance ensures that it is dealt with appropriately. Compliance responds to and documents complaints in writing within three working days of receipt. In addition, a «complaints register» log is maintained for all complaints, recording the type and reason for the complaint, date of receipt of the complaint, and complainant’s name. If any irregularity is discovered, the necessary steps and optimizations are initiated to prevent a recurrence. If a complaint cannot be resolved to the satisfaction of the complainant, the customer is referred to Bellevue’s ombudsman's office, FINOS. Information about the ombudsman’s office is provided in the «Legal information» section of the Bellevue website. The Compliance Department always informs the Group Executive Board. The Board of Directors is notified if necessary. The «Complaints» directive is not made public but can be provided at any time at a client's request.

Conflicts of interest

Bellevue commits to the transparent disclosure of potential or existing conflicts of interest to ensure that reporting and decision-making are objective and responsible. We have established mechanisms to identify potential conflicts of interest. All employees and members of the Board of Directors are obligated to report conflicts of interest as soon as they become aware of them. This includes personal interests, financial interests, family relationships or other relevant connections that could cause a conflict of interest. Bellevue has issued a «Conflicts of Interest Directive» outlining the company's guidelines for managing conflicts of interest, with the aim of protecting Bellevue’s reputation as an honest and fair manager of collective assets and pension fund assets, complying with regulatory requirements and maintaining the trust of clients and business partners. Transactions with related entities or individuals are disclosed in Annex 9 to the consolidated financial statements.

Client data confidentiality

The trust our clients place in us is the basis for long-term and successful collaboration and a valuable asset that we prize and prioritize at Bellevue. Protection of client identifying data and compliance with all applicable legal provisions are therefore paramount in our organization. Any privacy breach could have major implications for our business, reputation and client relationships.

We mitigate this threat with the following measures:

• Policy: Our privacy policy can be accessed via the following link, last updated 01.10.2023
• Training: Our employees receive regular training on cybersecurity and the importance of protecting client data. All new employees must successfully complete privacy training within three months. Everyone on staff has been trained or retrained within the last two years.
• Technology: We use state-of-the-art security technology and procedures to ensure integrity and confidentiality.
• Risk assessment: We conduct regular, at least annual, risk assessments to identify and proactively address potential vulnerabilities. We identified no losses of client data in fiscal years 2023 and 2022, and no sanctions were imposed by any authorities for breaches of client privacy or client data losses.
• Compliance: Adherence to legal provisions governing protection of client data (including the various data protection regulations and laws) is imposed and monitored by the cross-functional Legal & Compliance and IT departments. Checks conducted in 2023 revealed no significant vulnerabilities in terms of privacy breaches.

Consult our website for more details on how we collect and process personal data.

ESG reporting

Bellevue Asset Management AG became a signatory to the United Nations Principles for Responsible Investment (UN PRI) on August 19, 2019. PRI reporting is the world's largest responsible investment reporting project. It was developed with investors for investors. Reporting on our sustainability efforts and our goal progress is one of the UN’s six Principles for Responsible Investment (PRI) and such disclosures are a high priority.

We fulfill our ESG reporting responsibilities as follows in the interests of our stakeholders:

Investment fund fact sheets

Monthly updates are published for the various investment funds containing information on key ESG data, in addition to information on portfolio activity and performance. As of the year under review, we have also published ESG-specific fact sheets for our investment funds. These contain information on ESG research coverage, ESG rating ranges, ESG rating trend, CO₂ intensity, and contributions to the UN Sustainable Development Goals at the portfolio level of each fund. The ESG fact sheets are published on a quarterly basis and have been well received by our clients.

Bellevue website

On our website www.bellevue.ch we have created a sustainability section that details our ESG approach at both the corporate and portfolio level. Progress toward our ESG goals and other news concerning our sustainability efforts are updated on a continual basis. Information about the latest regulatory requirements (EU SFDR / MiFID II sustainability preferences) is also available in this section.

UN Principles for Responsible Investment (PRI) reporting

The UN PRI reporting must be completed every year. This reporting ensures accountability and transparency regarding the responsible investment activities of the UN PRI signatories and supports dialog among and within the signatories' organizations as well as with their clients and other stakeholders. The latest report can be viewed on our website or directly on the UN’s PRI website.

Internal ESG reporting

ESG reporting on every investment strategy is presented to executive management and the Board of Directors on at least a quarterly basis for review and the aforementioned bodies may formulate specific measures based on the information reported.