Complaint information Vive

Are you not satisfied with Vive's services? If so, we encourage you to contact customer service by emailing: support@viveapp.com, or send a chat message in the app (account/support/chat with us). The customer service staff will be happy to work with you to find an appropriate solution.

Are you unable to reach a solution with customer service and your complaint remains unresolved? In that case, make it clear that you are not satisfied with the solution offered. The customer service representative will initiate the complaint procedure for you so that your complaint can be formally addressed. 

Complaint Procedure

1. We receive your complaint.
This can be done through the communication channels used by Vive. It is unavoidable that messages are sometimes lost due to technical malfunctions, for example, or otherwise. Therefore, if you do not receive a response from us after 10 working days, please check with us whether the message has been received by us.

For the sake of completeness, please note that this complaints procedure does not prevent you from taking the normal legal action that is customary in the Netherlands.

We also note that you would be well advised to file a complaint with us as soon as possible to avoid the possibility that the complaint can no longer be dealt with because of the deadline that has already passed. As a general rule, the right to file a complaint expires in any case after five years after you are aware of what the complaint is about.

In addition to this complaints procedure, we have adopted a special procedure and measures for preventing and managing conflicts of interest. These also apply to complaints. If requested, you will receive a copy of this. ‍

2. The complaint will be registered upon receipt.
In any event, within five working days your complaint will be registered in at least the manner prescribed by the regulators and included in our complaints register. The Compliance Officer supervises this and, where necessary, will also ask for additional information in order to gain a complete picture of the complaint and to be able to record it. In this and in the entire handling of the complaint, the applicable privacy regulations will be respected at all times.

The Compliance Officer oversees business operations and therefore the entire complaint handling process.

It may be that your complaint holds us liable for damages you have suffered. In that case, we must also report your complaint to our professional liability insurer. This insurer will then take over the handling of the complaint from us. We will always inform you of this.

If the complaint relates to the actions of one of the members of the board of directors, the opinion of the director about whose actions the complaint is made, as well as at least one of the other members of the board of directors, will be requested in any case.

All complaints are registered using the complaint form. A complaint is any expression of dissatisfaction addressed to Vive by any person (whether a natural person or legal entity) relating to an investment service provided by Vive, through any channel through which Vive communicates with clients.

‍3. We aim to respond to your complaint within 10 working days.
Preferably, we will then handle your complaint immediately by resolving it. If this is not yet possible, you will in any case receive an acknowledgement of receipt of your complaint within this period, including the period within which you can expect a response and what steps we will take to deal with your complaint.

The assessment of the complaint will be sent to you only after approval by the Compliance Officer. If necessary, the Compliance Officer will also inform the Deposit Bank concerned, where your investments are held, about the complaint. In addition, Vive will provide timely information to the AFM regarding complaints and complaint handling.

4. At any time you will be given the opportunity to provide your response to the assessment of the complaint sent to you.
‍Ifthere is reason to do so we will send you a second assessment of the complaint taking into account your objections to the first assessment of the complaint. Where possible, the second assessment will involve a director who was not already involved in the assessment of the first complaint. In addition, the steps outlined in 1 through 5 will again apply.

5. If after handling the complaint you still do not agree with the first and/or any second or further assessments, you can turn to the KiFiD.
Below you will find the contact details of the KiFiD. To be sure, for up-to-date information, please visit www.kifid.nl.

Kifid
Postal address KiFiD: P.O. Box 93257, 2509 AG The Hague
Visiting address KiFiD: Kantoren Stichthage, Koningin Julianaplein 10, 2595 AA The Hague
Telephone number: +31(0)70 333 8 999
E-mail: consumenten@kifid.nl
Website: https://www.kifid.nl

Conflict of interest policy Vive

Under laws and regulations, financial firms are required to have procedures and measures in place to prevent and manage conflicts of interest. Below you can read how Vive has incorporated the conflict of interest policy into its operations and the measures taken by Vive to protect the client's interest. At all times, the applicable laws and regulations take precedence and are also the guiding principles in cases of conflicts of interest.

Principles of policy

Vive has established the policy pursuant to its license as an investment firm. The policy applies to all Vive Group affiliates.

The policy

Vive recognizes that, as with any other investment firm, there may be potential or actual conflicts of interest. Vive's policy is to protect the client's interest so that a client cannot be materially harmed as a result. Vive has defined in this policy the circumstances that may lead to a conflict and the measures taken to manage and/or prevent these conflicts.

Potential conflicts of interest

Conflicts of interest may arise in the following (non-exhaustively) listed situations, among others:

• Having an interest in the outcome of a service or transaction performed on behalf of the client that is different from the client's interest in that outcome;
• A conflict of interest among clients.
• Having a financial or other incentive to put the interests of one client or group of clients ahead of the interests of other clients;
• The provision of services by affiliates; The structure and (financing of) business activities
  

Because Vive's services are highly automated, the likelihood that Vive, or an employee of Vive, will have an improper influence on the manner in which asset management is conducted on behalf of a single client, or a group of clients is considered extremely low. Where clients may have a conflict of interest among themselves, or otherwise have differing interests, this is reported to the Compliance Officer. Although the likelihood of this conflict of interest, given the services provided and the far-reaching method of automation, is considered low, the Compliance Officer will designate persons to represent the interests of these potentially conflicting clients. The Compliance Officer shall, in case of conflicting interests, together with the board member who is not responsible for commercial matters, weigh up the interests.
With regard to the provision of services by affiliated parties, the decision-making process is set up in such a way that, in case of a conflicting interest, the interest of the affiliated party is subordinate to the interest of (the clients of) Vive. To ensure this, the Compliance Officer will decide, together with the management of Vive, that the person in whom the related party is or may be represented does not participate in the decision-making.
Vive has established various measures, procedures and policy guidelines to recognize, prevent and manage a conflict of interest. Below is a non-exhaustive list of some of the measures taken by Vive to safeguard the client's material interest.

Internal supervision

Vive has a board member who is ultimately responsible for compliance matters. In addition, the Compliance Officer oversees compliance with the conflict of interest policy. Agreements with related parties will be assessed by the Management Board in conjunction with the Compliance Officer on the "at arms length" principle, with the final decision-making authority resting with the Management Board member who is not involved with the related party. Periodically, at least annually, the effectiveness of the anti-conflict of interest policy is evaluated and if necessary updated. In the event that a conflict of interest arises for which the policy does not provide, the Compliance Officer will immediately update the policy accordingly.

Compensation Policy

A specific remuneration policy has been established whereby the service model and the manner in which the fees charged to clients are not based on service that does not serve the client's interest.

Private investment transaction

The personnel policy states that if an employee, wishes to make a private investment transaction it must be reported in advance to the Compliance Officer.

Donations

In addition to the regulation of private investment transactions, the personnel policy includes the regulation of gifts and regulation of ancillary activities to manage conflicts of interest.

Provision

Vive receives no commissions, fees or monetary or non-monetary concessions paid or provided by any third party.

Market abuse

To prevent employees of Vive from using (price) sensitive information for their own gain, Vive has established a regulation on private investment transactions. The regulation should ensure that (the appearance of) insider trading and mixing of business and private interests is prevented.

Separation of functions

To ensure that persons cannot abuse the system, segregation of duties is ensured. A separation is made between functions in which investment services are provided and functions in which the operational processes are handled for the purpose of operations.

Communications

Any (possible) conflict of interest within Vive will be reported to the Compliance Officer, who will inform the Management Board. Compliance will investigate the reports in consultation with the Management Board. Each report will be assessed against the conflict of interest policy. A written record will be made of each relevant report in which Vive indicates how the conflict of interest was handled. Given the specific nature of conflicts of interest, Vive will assess each report on an individual basis. If the organizational and administrative arrangements put in place by the investment firm to prevent or manage a specific conflict of interest are not sufficient, this will be disclosed at least to the, in this case, affected clients.

Investor guarantee scheme

Asset segregation law and investor compensation

Firms providing investment services are required by law to keep their own assets separate from clients' invested assets. If things then go wrong, their clients' investments are safe in a separate pot. Vive complies with the rules of asset segregation. The Financial Markets Authority checks Vive's compliance with asset segregation rules. These rules ensure that should Vive go bankrupt, our customers' investments are separated from Vive's assets. As a result, customers' investments do not fall into the bankruptcy estate.

Should an unexpected case of fraud and/or mismanagement occur at Vive and Vive cannot ensure the rules of asset segregation, there is the investor compensation scheme for aggrieved investors. The investor compensation offers protection up to a maximum of EUR 20,000 per person and per company. Do you have a joint and/or investment account with your partner? If so, you are guaranteed to receive up to EUR 40,000 back together. More information on the investor compensation scheme can be found on DNB's site.

ThisDisclaimer was last updated on January 13 2022.

General

VIVE Invest B.V. (Chamber of Commerce 62098896), in the rest of this document referred to as Vive Invest, hereby grants you access to www.viveapp.com and all of our VIVE Invest B.V. websites where it publishes texts, images and other materials which have been supplied by Vive Invest and others.

Vive Invest retains the right to alter the contents of the Website and mobile application or remove material without having to notify you at any point in time about such changes. The information and materials on the Website and mobile application are provided "as is" and cannot be considered an offer of services or a contract proposal. Contracts and services are only established by the acceptance of duly indicated quotations or offers by Vive Invest.

Liability

Although for the content of this Website and our mobile application great care has been taken, Vive Invest shall never be liable for losses or other damages that may result from inaccuracy or incompleteness of information on this Website and/or its mobile application. The materials on the Website and our mobile application are offered without any warranties, expressed or implied, and without any claims as to their accuracy. These materials can be subject to change at any given time without prior notification from Vive Invest. Especially all sums, prices and fees on the Website and mobile application are provided with reservation of type-, conversion-, and programming errors.

For the consequences of such errors no liability is acknowledged or accepted by Vive Invest. No agreement or contract with Vive Invest is established based on such errors. Studying the contents of this Website and/or our mobile application, signing up for newsletters or to send information requests can not cause any kind of relationship between Vive Invest and the receiver of the information.

This website may contain links to other websites. Vive Invest has no control over the content of those other sites and is not responsible for the content of those websites or other links to other websites. Transmission of web forms or other communications to Vive Invest without encryption or other secure means of communication and shall always be for the risk of the sender.

Intellectual Property Rights

This website contains information, data, software, photos, graphics and other materials protected by copyright, trademark or other proprietary rights. The content on this Website and our mobile application may not be reproduced, republished, distributed, transmitted, displayed, broadcasted or exploited in any manner without the express prior written consent of Vive Invest. All intellectual property rights with regards to these materials offered and available on the Website and our mobile application are the property of Vive Invest and its licensors. All intellectual property rights relating to this Website, including software, text, photographs, images and / or sounds are owned by us and / or the person from whom we have obtained a license.

Privacy policy Vive Invest B.V.

This Policy was last updated on 17 of November 2023.

At Vive Invest, we care about the protection of your data and privacy and how it applies to you, as a user of our website(s). In this Privacy Policy ('Policy'), you can find information about how, whether, and why we collect and use your personal information on our Vive Invest website www.viveapp.com and on our mobile application Vive App. This Policy applies to any personal information that is gathered when you use our services, visit our Website, or otherwise interact with us. We have divided this Policy into different sections. The processing of your personal data complies with the General Data Protection Regulation (GDPR), the Dutch GDPR Execution Act and the Dutch Telecommunications Act.

About us

The data controller for the processing of your personal data is VIVE Invest B.V., registered at the Dutch Chamber of Commerce with registration number 62098896. Our address is Keizersgracht 268, 1016 EV Amsterdam, the Netherlands.

If you have any questions about the processing of personal data resulting after reading our Privacy Statement, you can contact us at privacy@viveapp.com.

Types of personal data we collect

To assess and open Vive Website and Mobile Application accounts, we can collect and use the following personal data:

• First and last name
  
• Date, country and place of birth
  
• Nationality
  
• Gender
  
• Residential address
  
• Telephone number
  
• Email address
  
• Social security numbers and/or other tax identification numbers
  
• Counter IBAN
  
• Device data (such as type of device, operating system, IP-addresses and advertising IDs)
  
• Location data via GPS
  
• Uploaded images/content
  
• Device data of added devices and API-keys
  
• Financial and banking data, product subscriptions and transaction history
  
• Cookies and usage date on how you use our products and services
  
• Correspondence with Vive Invest and support data (telephone, chat conversations and email)
  
• Additional information related to opening an account and creating your personalized investment
  
• Plans such as your knowledge and experience of financial markets, your financial situation, investment situation and preferences and your risk preferences
  
• Marketing data (statistics related to our marketing campaigns and data to measure this)
  

Information about our communication

• When you send us an email, or chat with us online or via social media, we save your correspondence with us if you are already a customer or in the process of becoming one or contacting us to find more about our products and/or services.
  
• Information we collect when you use our Website and/or our mobile application.
  
• When you visit our Website and mobile application or use our services, we may register your IP address, browser type, operating system, referring website, web-browsing behaviour.
  
• We may receive an automatic notification when you open (or open a link from) newsletters from us.
  

Information in relation to social media

Depending on your social network settings, we may receive information from your social network provider. For example, when you sign in for our services using a social network account, we may gather publicly available information you give us access to from your social network profile, including your contact details, interests, and social network.

For more information on the personal data that we receive from your social network provider, and how to change your privacy settings, please refer to the website and the privacy policy given by your social network provider.

Information you choose to share with us

You may also choose to share information with us. For example, when you leave a comment for us on Facebook, fill out a survey, submit a contact or application form, leave a review or submit an entry for a contest or scholarship, you have opted to share personal information with us.

You may also choose to share information with us. For example, when you leave a comment for us on Facebook, fill out a survey, submit a contact or application form, leave a review or submit an entry for a contest or scholarship, you have opted to share personal information with us.

Purposes of processing your data

Vive Invest processes your personal data in accordance with the laws and regulations based on several legal grounds. Vive Invest processes personal data to provide our services. For example, personal data is processed to:

• Comply with legal obligations
  
• To preserve our agreement and to provide our services in a secure manner, we process your personal data. For example, we need your contact information to keep you informed about relevant developments, and we store correspondence data to improve our customer services.
  
• To make your user experience easier and more effective, we may assess how you use our services, and combine this data with information collected via your personal account, registration details, cookies, and similar technologies. This combination enables us to, for example, optimize our search algorithms and offer a better customer experience.
  
• To create better and personalized investment strategies
  
• To process personal information for (direct) marketing purposes. This means we may use your personal information to send you newsletters, emails, promotions, or other marketing communications. We use the results of our analysis to tailor our marketing communications to your specific interests and preferences. For example, if our analysis shows that you may be interested in certain services, we may customize our newsletters and Website with content that is relevant to you. We may use different channels for our marketing communications, such as emails, social media, and your personal online account during different time frames and in recurrent manner.
  
• To initiate and evaluate business relationships. Your personal data will be processed for the entering into agreements and the performance thereof to the point of commercial services and the managing of the business relations which emerge from them, including the performance of activities aimed at the expansion of our client database.
  

Vive Invest is allowed to process personal data for this purpose because you gave consent or because Vive Invest has a legitimate interest. The consent can be withdrawn at any moment, and you can object at any moment to the processing of your personal data for direct marketing purposes. The withdrawal of consent or exercise of your right to object does not affect the lawfulness of the processing prior to the moment of withdrawal or exercise of the right to object.

You may object or revoke your consent for receiving marketing communications at any time, by following the instructions in the relevant marketing communication or by sending an email to privacy@viveapp.com.

Legitimate and legal interests

In many cases, we are legally required to store certain data about you, for example to verify your identity, for research and to create personalized investment plans.

We can also process certain data when we have a legitimate interest to do so. For example, to prevent and combat misuse, to research and analyze the use of our products and services for marketing purposes, for information and system security or to share certain data with governmental institutions.

Disclosing or sharing data with third parties

General

We reserve the right to release personal information without your consent or without consulting you, when we deem it necessary to comply with our legal obligations, to enforce our terms and conditions, to protect the security of our Website and application, or to prevent fraud.

To be able to provide our services, we share certain personal data with third parties. We keep the sharing to a minimum and ensure these third parties will handle your personal data with the same care as we do. This means, among other things, we sign Data Processing Agreements. The third parties or categories of third parties with whom we share data are: Onfido Limited, VWD, Auth0 and Northern Trust.

Governmental institutions

To comply with laws and regulations we can share data with the concerned institutions. For example, the Tax Authorities can request financial data and we can share data with the Dutch Central Bank for participating in the Deposit Guarantee Scheme. Next to this, Vive Invest can have a statutory or legal obligation to share personal data with investigating authorities to prevent and combat misuse, fraud and crimes.

Security and retention

Vive Invest takes the safeguarding of your information very seriously. Vive Invest will take appropriate technical and organizational measures to protect your personal data against loss or unlawful use. These measures include but are not limited to: facilities protected by appropriate security measures, encryption of devices, version tracking and access to our databases is limited to key personnel and IP addresses and use of it is logged. Personal identifiable information and account activity are also protected through the use of user names and passwords. In order to help maintain the security of your information, you should protect the confidentiality of your user name and password.

How long we keep your personal data

We will hold all the data for so long as we have an obligation to the Customer to provide the Services, and thereafter until such time as we delete the Customer's account in accordance with our Customer Terms and Conditions.

Your personal information will be deleted on one of the following occurrences: - deletion of your personal information by you (or by another person engaged by the Customer); or - receipt of a written request by you (or another person engaged by the Customer) to us

For a large amount of data, we are legally obliged to retain this for a minimum of 5 to 7 years after ending the customer relationship. After this period, we don't store your personal data longer than legally allowed and no longer than necessary for the purposes the data was collected for.

We are able to store personal data for longer periods with a valid legal ground, or when the data is sufficiently (for example) pseudonymised or anonymised.

Your Rights

You can request access to or a copy of your personal data collected by us. You may also request the rectification and removal of personal data or the restriction of the processing of your personal data, if there is a reason for doing so. You also have the right to data portability. You also have the right to object to a processing on grounds relating to your particular situation or against the processing of your personal data for direct marketing purposes. More information on your rights is available at: https://autoriteitpersoonsgegevens.nl.

To exercise your right(s), please send us an email at privacy@viveapp.com or mail us: VIVE Invest B.V., Keizersgracht 203, 1016 DS Amsterdam, The Netherlands.

Revoking & limiting consent

When you have provided us with permission to process personal data, or when we process your personal data based on legitimate interests, you are able to revoke this permission in an easy manner or ask us to limit the use of your data. Revoking your permissions does not mean that stored data is deleted.

Direct marketing & usage data

If you do not want your data to be used for direct marketing activities and analysis of the usage of our products and services, you can let us know via the VIVE app anytime. Next to this, our communication via email contains the possibility to unsubscribe from these messages.

GPS and image and content access

While using the VIVE app, you can provide permission to process location data. If you no longer want us to use location data, you can revoke these permissions easily. This permission is also offering the possibility to protect your account, sending, for example, notifications when there is a login from an unknown location. You'll find these settings in the VIVE app. You can revoke provided permissions at any given moment.

Images and content that you use to personalise your VIVE account can be easily changed in the VIVE app.

Cookies

For more information on how to delete cookies, please see our Cookie Statement.

Modifications to this Policy

This Policy is effective as of 23 of October 2018. We reserve the right to alter or otherwise make changes to this Policy. Notices may be by email to the last email address you provided us, by posting notice of such change on our Site or the Optimizely Service, or by other communication channels. You consent to receiving notices in these ways. We reserve the right to determine the form and means of providing notifications to you, consistent with applicable law. Changes take effect as soon as the Policy is posted.

Questions or complaints

If you have any question or complaints about the processing, please send an email to us at privacy@viveapp.com. If you feel that your rights have been violated, you may also make a complaint with the Autoriteit Persoonsgegevens, the Dutch Data Protection Authority(www.autoriteitpersoonsgegevens.nl). For more information on the protection of personal data, please consult the website of the Autoriteit Persoonsgegevens.

Contact Us

If you have any questions about this Privacy Policy or our privacy practices, please contact us at privacy@viveapp.com.

What are Vive's investment beliefs?

VIVE wants you to achieve your goals by means of your investments. The investments and investment portfolios serve the realisation of your financial goals. VIVE's asset management for private clients provides the desired investments with an efficient return-risk ratio, at low costs, in a transparent manner and taking into account widely accepted ESG criteria (i.e. in the areas of environment, social relations and good corporate governance).

Socially responsible investing

VIVE believes that investing entails a responsibility that is broader than just a financial fiduciary duty; the effects on the environment, social relationships and good corporate governance (ESG) should therefore be an integral part of the investment strategy.

Integrating ESG criteria has added value from a risk/return perspective. Responsible investment includes a combination of:

• Exclusion policy;
• Best in class selection policy;
• Exercise of voting rights and active engagement strategy.

In principle, VIVE only wants to select funds with an ESG policy that contains the above-mentioned policy components.

To evaluate the ESG integration in the funds, we look at the fund classification under the EU Sustainable Finance Disclosure Regulation (SFDR). The EU Sustainable Finance Disclosure Regulation (SFDR) is a set of EU rules aimed at making the sustainability profile of funds more comparable and easier to understand for end investors.

Spreading risk and keeping costs low are important

VIVE believes that investing is best done through broadly diversified portfolios. VIVE strives to spread its investments as much as possible across investment categories, and within these categories across geographical regions and sectors. Avoidable risk that is not rewarded with a positive expected risk premium (excess return over the risk-free interest rate) should in principle be avoided.

VIVE does not believe that market timing and tactical asset allocation add value to the client after expenses. VIVE does not believe that trying to beat the market structurally adds value to the client after expenses. With active management, it is very difficult to outperform the market average. Therefore, the policy is to select funds on a 'passive where possible' basis. VIVE believes that active management makes sense for less efficient or inefficient markets if it leads to better risk management. VIVE's focus within portfolio management is on constructing portfolios by risk level as well as possible on the basis of realistic and plausible (long-term) economic scenarios. The investment horizon of clients runs from short to long term. By outsourcing to external asset managers, i.e. the suppliers of unlisted investment funds in which VIVE invests for its clients, VIVE can focus on the added value for you as a client. VIVE can select the investment funds itself. VIVE only invests via unlisted UCITS in the selected investment categories.

Focus on risk management

Risk management is crucial for sustainable asset management. This means that risk is measured frequently and the portfolio is adjusted if necessary. VIVE applies the principle that the downside risk value of the optimal portfolios is updated quarterly and that the composition of the optimal portfolios can be adjusted accordingly to achieve the best ratio between expected return and downside risk. To ensure that clients' investment plans remain close to the intended risk profile, VIVE monitors your investment portfolios on a daily basis and applies a rebalancing of the portfolios if they deviate too much from that risk profile. The actual composition is then brought in line with the strategic portfolio belonging to the investment plan at the moment of rebalancing.

In which investment categories will the money be invested?

The asset classes that qualify for the optimal portfolio should have a positive expected risk premium that is scientifically substantiated.

VIVE can fill the portfolios with the following investment categories on the basis of the investment convictions:

• Money market investments in euro;
• Government bonds denominated in euro or hedged to the euro;
• Investment grade corporate bonds denominated in euro or hedged to the euro;
• Global equities, in mature markets and emerging markets;
• High Yield corporate bonds, i.e. corporate bonds of lower credit quality than Investment Grade.

VIVE determines a representative index series for each category, which is used to determine the statistical characteristics in VIVE Technology's Economic Scenario Generator model. These characteristics determine the degree of risk diversification across categories.

How does VIVE select the funds for each asset class?

VIVE offers asset management by means of investments in unlisted investment funds ('funds'). VIVE does not invest in own funds but uses funds of third parties; this prevents undesired conflicts of interest.

VIVE selects third party funds on the basis of the following criteria:

Liquid:
The portfolio is composed of unlisted open-ended mutual funds that are traded daily.

High degree of risk diversification:
There is a wide spread within the fund: there are sufficient names in each investment fund and it is ensured that no individual investment has an excessive allocation within the fund, both in terms of Euro weighting and risk weighting. This is tested by applying a 5% worst case scenario to the two largest positions in the portfolio and checking that they do not exceed the Value at Risk of the relevant asset class. If this is exceeded, the fund does not meet the risk diversification criterion and does not qualify for selection.

Low costs:
The ongoing cost factor (OCF) must be low. This is tested by comparing the OCF of a fund to be selected with the median OCF of comparable funds. The level of any entry or exit charge must be in line with the market.

The level of ESG:
VIVE believes that investing entails a responsibility that is broader than just a financial fiduciary duty; the effects on the environment, social relationships and good corporate governance (ESG) should therefore be an integral part of the investment strategy. Integrating ESG criteria has added value from a risk/return perspective. In principle, VIVE only selects funds with an ESG policy. If no fund with such an ESG policy is available for a specific investment category, VIVE may consider adding a fund that does not meet VIVE's ESG selection criteria if the improvement in the return-risk ratio for the client is significant. In this case, it will be specifically recorded and communicated to clients how VIVE's ESG policy starting point is deviated from and why VIVE considers it in the clients' interest that the fund in question can be part of clients' portfolios.

Appropriate Mandate of the Instrument:
The benchmark of the fund is in reasonable agreement with the representative index series on which the statistical characteristics are based; the tracking error between the two indices is not expected to exceed 1%. This concerns two index series. The index series on which the statistical characteristics are based refers to the index series used to determine the parameters in the Economic Scenario Generator model. The other index series, from the benchmark, refers to the fund's benchmark. The investment universe and risk limits contribute to sufficient risk diversification. In the case of an index tracker, the replication method ensures a good connection to the benchmark (e.g. full replication). The management style of the fund is passive and responsible where possible.

Good quality asset manager:
The asset manager has a proven track record (i.e. has demonstrated reliable asset management in the asset class concerned), has its own risk management in order and has a stable organisation. VIVE specifically states an ISAE 3402 certificate as a criterion. The stability of the organisation is checked, among other things, by looking at the staff turnover both of the organisation as a whole and within the group of policymakers.

Suitable and authorised for retail investors within the European Union:
The fund has UCITS status and the Key Investor Information Document (KIID) for the fund is available in English and in the language of the country where VIVE offers the app. This means that the EBI is available in the Dutch language for the funds that are used for clients in the Netherlands.

Funds with securities lending and unnecessary use of derivatives should be avoided:
VIVE has a strong preference for funds without securities lending and without the use of derivatives (such as total return swaps). VIVE considers the addition of counterparty risk by securities lending undesirable, as this is not a transparent source of risk for the client. The use of derivatives in a fund introduces additional risks that cannot be clearly understood by non-professional investors. If a fund without securities lending or derivatives use is not available for a specific asset class, but the improvement in the risk/return ratio for VIVE's clients is significant, VIVE may still consider adding this fund. In that case, it will be specifically recorded and communicated to clients in which way it deviates from VIVE's principle for securities and derivatives lending, and why VIVE considers it in the clients' interest that the fund in question can be part of clients' portfolios. Excluded are funds that use so-called exotics (custom derivatives).

How are investment plans made?

VIVE helps clients set investment goals based on preferences specified by clients and within the client's risk tolerance profile. Through a software-defined process, an optimal investment strategy is then derived for each target plan. This strategy is a so-called lifecycle strategy: the 'investment risk decreases as the end date approaches'.

VIVE determines an optimal investment portfolio within the client's risk profile. VIVE provides portfolio optimisation and rebalancing after adjusting the risk/return characteristics of the underlying asset classes. The optimal portfolios and forecasts for the median scenario and the adverse scenario are based on an economic scenario set generated quarterly by the Economic Scenario Generator model.

The investment plans are implemented by investing, for each investment plan, in an optimal portfolio corresponding to the level of risk accepted by the client when creating the plan (or last revision of the plan). VIVE uses the same consistent portfolio optimisation to implement the investment mix in the different types of investment plans.

The portfolio optimisation with eligible asset classes is performed by selecting the portfolio with the highest expected return (median scenario) at each Value-at-Risk (VaR) level based on a realistic 1-year scenario. VIVE uses a robust optimisation technique to minimise the impact of outliers. The VaR level is determined as the 5% percentile of the probability distribution of portfolio returns.

Part of VIVE's services is the rebalancing of the portfolios in the investment plans created by the client. Differences between the actual portfolio and the strategic portfolio for the client's investment plan can arise due to price developments and changes in the strategic portfolio. The goal of rebalancing is to align the actual portfolio with the strategic portfolio that belongs to the specific investment plan at that time.