Circular No. 06/CREPMF/2022 Relating to the Key Investor Information Document to be Provided to the Investor of a Collective Investment Undertaking

UNION MONETAIRE OUEST AFRICAINE CREPMF CONSEIL REGIONAL DE L'EPARGNE PUBLIQUE ET DES MARCHES FINANCIERS

CIRCULAIRE N°06/CREPMF/2022

RELATIVE AU DOCUMENT D'INFORMATIONS CLES A FOURNIR A L'INVESTISSEUR D'UN OPC

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The General Secretariat of the Regional Council for Public Savings and Financial Markets (CREPMF) reminds approved Collective Investment Undertakings (CIUs) and CIU Management Companies (MCs) on the regional financial market of the UMOA that, in accordance with current regulations, they must comply with the provisions of this Circular, which specifies the detailed content of the information to be provided to the Investor.

For the purposes of this Circular, the term Instruction refers to Instruction No. 66/CREPMF/2021 relating to Collective Investment Undertakings and their Management Companies on the regional financial market of the UMOA.

I. FORM AND PRESENTATION OF THE KEY INVESTOR INFORMATION DOCUMENT

1.1 Document Description

The Key Investor Information Document is presented as follows:

1. The title "KEY INVESTOR INFORMATION" appears prominently at the top of the first page of the Key Investor Information Document;
2. The following explanatory statement appears directly under the title: "This document provides essential information to investors in this CIU (specify the nature of the CIU). It is not a promotional document. The information it contains is provided to you in accordance with a legal obligation, to help you understand what an investment in this CIU entails and what risks are associated with it. You are advised to read it to decide whether to invest with full knowledge of the facts.";
3. The CIU, including the investment compartment or share class, as well as its classification if it is a UCITS, is clearly identified. In the case of an investment compartment, the name of the CIU follows the name of the investment compartment. When an identification code exists for the investment compartment

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investment compartment, it forms an integral part of the CIU's identification; 4. The name of the Management Company is indicated; 5. Furthermore, when the CIU Management Company is part of a group of companies for legal, administrative, or commercial purposes, the name of this group may be indicated. A corporate logo may be included, provided it does not prevent the investor from understanding the key elements of their investment or diminish their ability to compare investment products; 6. The section of the Key Investor Information Document titled "Investment Objectives and Policy" contains the information set out in point II of this Circular; 7. The section of the Key Investor Information Document titled "Risk and Return Profile" contains the information set out in point II of this Circular; 8. The section of the Key Investor Information Document titled "Fees" contains the information set out in point II of this Circular; 9. The section of the Key Investor Information Document titled "Past Performance" contains the information set out in point II of this Circular; 10. The section of the Key Investor Information Document titled "Practical Information" contains the information set out in point II of this Circular; 11. Approval is notified by the following statement: "This CIU is approved on [day/month/year] by the Regional Council for Public Savings and Financial Markets under number XXX"; 12. Information regarding the publication date is notified by the following statement: "The key investor information provided here is accurate and up to date as of [publication date]."

1.2 Presentation and Language

The Key Investor Information Document: a) is presented and laid out in a manner that makes it easy to read, notably by using characters of sufficient size; b) is clearly formulated and drafted in language that facilitates the investor's understanding of the communicated information, notably: i. by using clear, concise, and understandable language; ii. by avoiding jargon; iii. by avoiding the use of technical terms when everyday language can be used instead; c) focuses on the key information that investors need.

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When colors are used, they must not reduce the intelligibility of the communicated information if the Key Investor Information Document is printed or photocopied in black and white. When the logo of the CIU Management Company or the group to which it belongs is used, it must not distract the investor or obscure the text.

1.3 Length

The Key Investor Information Document does not exceed two (02) A-4 pages when printed.

II. MAIN SECTIONS OF THE KEY INVESTOR INFORMATION DOCUMENT

2.1 Investment Objectives and Policy

The description contained in the "Investment Objectives and Policy" section of the Key Investor Information Document covers, even if they are not part of the description of the objectives and investment policy contained in the prospectus, the essential characteristics of the CIU that the investor must be informed about, and notably: a) the main categories of financial instruments in which the CIU may invest; b) the option offered to the investor to obtain reimbursement of their CIU shares or units on demand, this statement being accompanied by an indication of the frequency at which share or unit redemption operations take place; c) whether the CIU pursues a particular objective regarding an industrial or geographical sector or another market sector, or regarding certain categories of assets; d) whether the CIU allows discretionary choices regarding investments to be made and, in this approach, whether it explicitly or implicitly uses a benchmark, and if so, which one; e) whether dividends are distributed or reinvested; f) when a minimum recommended holding period for CIU shares or units is indicated in the prospectus or another commercial document, or when it is indicated that a minimum holding period is an essential element of the investment strategy, a statement worded as follows: "Recommendation: this fund may not be suitable for investors who plan to withdraw their investment within [indicate period]."

In application of point d), when a benchmark is referenced, the existing margin of maneuver relative to this benchmark is indicated, and when the CIU has an index objective, that objective is also indicated.

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The "Investment Objectives and Policy" section of the Key Investor Information Document may contain other elements than those listed in paragraph 1 above, including a description of the CIU's investment strategy, when these elements are necessary to adequately describe the CIU's objectives and investment policy.

2.2 Risk and Return Profile: Explanation of Risks and Potential Returns, Including the Use of Indicators

The "Risk and Return Profile" section of the Key Investor Information Document contains a textual explanation covering the following risk categories, when they are material: a) credit risk, when a significant portion of investments is made in debt securities; b) liquidity risk, when a significant portion of investments is made in financial instruments that are sufficiently liquid by nature, but nevertheless may, under certain circumstances, have a relatively low level of liquidity, to the point of impacting the overall liquidity risk of the CIU; c) counterparty risk, when the CIU is backed by a third-party guarantee, or when the exposure of its investments results, to a large extent, from one or more contracts with a counterparty; d) operational risks and risks related to asset custody; e) the impact of financial techniques referred to in Article 40.2 of the Instruction, such as derivative instruments, on the CIU's risk profile, when these techniques are used to obtain, increase, or reduce exposure to underlying assets.

2.3 Fees

2.3.1 Presentation of Fees

The "Fees" section of the Key Investor Information Document contains a presentation of fees in the form of a table in accordance with Annex I.

The table referred to in paragraph 1 above is completed, in accordance with the following requirements: a) entry and exit fees each correspond to the maximum percentage that may be deducted from the capital committed by the investor in the CIU; b) a single figure, based on the previous year's figures, is indicated for fees charged to the CIU during the year, referred to as "ongoing charges", which represent all annual fees and other payments charged to the CIU's assets during the defined period; c) the table lists and provides an explanation of all fees charged to the CIU under specific conditions and indicates the basis on which these fees are calculated and when they apply.

Avenue Joseph ANOMA 01 B.P. 1878 Abidjan 01/Côte d'Ivoire Site web : http://www.crepmf.org 4 TEL.: (225) 27 20 21 57 42 /27 20 31 56 20 Fax: (225) 27 20 33 23 04 Email : sg@crepmf.org

2.3.2 Explanation of Fees and Statement on the Significance of Fees

The "Fees" section contains a textual explanation of each of the fees listed in the table, with the following information: a) regarding entry and exit fees: i. a clear indication that the figures provided are always maximums and that, in some cases, the investor pays less; ii. a statement specifying that the investor may obtain from their advisor the actual amount of entry and exit fees; b) regarding "ongoing charges", a statement specifying that the figure provided is based on the previous year's fees, closed in [indicate month and year], and that this figure may vary from one year to the next.

The "Fees" section contains a statement on the significance of fees, which clearly indicates that the fees paid by investors serve to cover the marketing and distribution costs of its shares or units, and that these fees reduce the potential growth of investments.

All elements of the fee structure are presented as clearly as possible, to allow investors to take into account the combined impact of all fees.

Performance fees are disclosed in accordance with point 2.3.1, paragraph 2, point c). The amount of the performance fee charged for the CIU's last financial year is indicated as a percentage.

2.3.3 Special Cases

When a new CIU cannot meet the requirements of point 2.3.1 paragraph 2, point b) and point 2.3.2, paragraph 1, point b), ongoing charges are subject to an estimate based on the expected total amount of fees.

Paragraph 1 does not apply in the following cases: a) CIUs that charge an all-inclusive fee, in which case that figure is communicated; b) CIUs that set a cap or maximum for the amount that may be charged, in which case that figure is communicated, provided that the CIU Management Company commits to respecting the published figure and to bearing the fees that would exceed that amount.

2.4 Past Performance

2.4.1 Presentation of Past Performance

Information regarding the CIU's past performance is presented in the form of a bar chart, covering the CIU's performance over the last five years.

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The bar chart referred to in the first paragraph is of sufficient size to be readable, but in no case occupies more than half a page in the Key Investor Information Document.

For any year for which no data is available, the chart is empty and includes no other indication than the date.

In the case of a CIU that does not yet have data on its past performance for a full calendar year, a statement is inserted indicating that there is too little data to provide investors with useful indications on past performance.

The bar chart is completed by statements, placed prominently, which: a) specify that it does not constitute a reliable indication of future performance; b) briefly indicate which fees and commissions were included or, conversely, excluded from the performance calculation; c) mention the year of the CIU's creation; d) indicate the currency in which past performance was calculated.

2.4.2 Method of Calculating Past Performance

The calculation of past performance is based on the CIU's net asset value and on the principle that any distributable income of the CIU has been reinvested.

When a significant change occurs in the CIU's objectives and investment policy during the period covered by the bar chart referred to in point 2.4.1, the past performance recorded by the CIU before this significant change continues to appear in the chart.

The period prior to the significant change referred to in paragraph 1 is marked in the bar chart and is accompanied by a clear warning that the displayed performance was achieved under circumstances that are no longer current.

The use of performance simulation for the period during which no data was yet available is not authorized.

2.4.3 Use of a Benchmark Alongside Past Performance

When the "Investment Objectives and Policy" section of the Key Investor Information Document refers to a benchmark, a bar showing the performance of this benchmark is included in the chart next to each bar showing the CIU's past performance.

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2.4.4 Practical Information

The "Practical Information" section of the Key Investor Information Document contains the following information, which concerns investors in any member state where the CIU is marketed: a. the name of the Depositary; b. where and how to obtain further information on the CIU and a copy of its prospectus, its latest annual report, and any subsequent semi-annual report, with mention of the language(s) in which these documents are available and the fact that they can be obtained free of charge; c. where and how to obtain other practical information, and notably where to find the latest price of the shares or units; d. a statement noting that the tax legislation of the CIU's home member state may affect the investor's personal tax situation; e. the following statement: "The liability of [insert name of the Investment Company or CIU Management Company] can only be invoked on the basis of statements contained in this document that would be misleading, inaccurate, or inconsistent with the corresponding parts of the CIU's prospectus."

2.4.5 Use of References to Other Information Sources

References to other information sources, and notably to the prospectus and annual and semi-annual reports, may be included in the Key Investor Information Document, provided that all information that investors fundamentally need to understand the essential elements of their investment is provided in the Key Investor Information Document itself.

References to the CIU's or Management Company's website, including to parts of this website where the prospectus and periodic reports are located, are authorized.

The references referred to in paragraph 1 direct the investor to the relevant section of the concerned information source. Several different references may be used in the Key Investor Information Document, but their number must remain as limited as possible.

2.4.6 Review of Key Investor Information

The CIU Management Company or Investment Company ensures that a review of the key investor information is carried out at least every twelve months.

A review is carried out before any modification proposed to the Prospectus, the Fund Regulations, or the constitutional documents of the Investment Company, when these modifications have not been taken into account in the review referred to in paragraph 1.

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A review is carried out before or after any change considered significant affecting the information contained in the Key Investor Information Document.

2.4.7 Publication of the Revised Version

When, following a review as referred to in point 2.4.6, it appears that modifications must be made to the Key Investor Information Document, the revised version of the Key Investor Information Document is published promptly.

When a modification to the Key Investor Information Document is planned as a result of a decision by the CIU Management Company, including the introduction of modifications to the Prospectus, the Fund Regulations, or the constitutional documents of the Investment Company, the revised version of the Key Investor Information Document is published before the relevant modification takes effect.

A Key Investor Information Document, containing a duly revised presentation of the CIU's past performance, is published no later than thirty-five business days after December 31 of each year.

III. STRUCTURES OF SPECIAL CIUS

3.1 Share and Unit Classes

When a CIU consists of several classes of shares or units, a Key Investor Information Document is produced for each of these classes of shares or units.

The key investor information relating to several classes of the same CIU may be grouped into a single Key Investor Information Document, provided that the final information document fully satisfies all the requirements of points 1.1 and 1.2.

The CIU Management Company may choose one class to represent one or more other classes of the CIU, provided that this choice is correct, clear, and not misleading for potential investors in these other categories. In this case, the "Risk and Return Profile" section of the Key Investor Information Document contains the explanation of material risks that apply to each of the other represented classes. The document based on the representative class may be provided to investors in the other classes.

Different categories cannot be combined to form a composite representative class within the meaning of paragraph 3.

The "Practical Information" section of the Key Investor Information Document is supplemented by an indication of the class that has been selected as the representative class, using the term by which this class is designated in the CIU's prospectus. This section also informs investors where to obtain information on the other classes of the CIU that are marketed in the member states.

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3.2 Fund of Funds

3.2.1 "Investment Objectives and Policy" Section

When a CIU invests a significant proportion of its assets in other CIUs, the description of the objectives and investment policy of this CIU in the Key Investor Information Document contains a brief explanation of how these other Collective Investment Undertakings will be selected as part of the CIU's day-to-day management.

3.2.2 Risk and Return Profile

The textual explanation of risk factors referred to in point 2.2.1 of this Circular takes into account the risks inherent to each underlying CIU, to the extent that these risk factors are likely to be material to the CIU as a whole.

3.2.3 "Fees" Section

The description of fees takes into account any fees borne by the CIU itself as an investor in the underlying CIUs. In particular, the CIU takes into account the entry and exit fees and ongoing charges levied by the underlying CIUs in the calculation of its own fees.

3.3 Master-Feeder CIUs

3.3.1 "Investment Objectives and Policy" Section

The Key Investor Information Document relating to a feeder CIU contains, in the description of the objectives and investment policy, information on the proportion of this feeder CIU's assets that is invested in the master CIU.

The Key Investor Information Document also contains a description of the objectives and investment policy of the master CIU, supplemented, as appropriate, by one of the following two elements:

• an indication that the returns offered by the feeder CIU will be very similar to those offered by the master CIU; or
• an explanation indicating in what way and why the returns respectively offered by the feeder CIU and the master CIU might differ.

3.3.2 "Risk and Return Profile" Section

When the risk and return profile of the feeder CIU differs, in any material respect, from that of the master CIU, this fact and the reason for this fact are explained in the "Risk and Return Profile" section of the Key Investor Information Document.

Any liquidity risk and