# Fund Factsheet: [Fund name], [share class], as at [YYYY-MM-DD]

> Monthly factsheet for one fund share class: key facts, objective and
> strategy, performance (cumulative, annualised and calendar-year),
> risk indicators, portfolio composition, fees and costs,
> sustainability classification, manager commentary and the warnings
> and disclosures that marketing rules require, plus the production and
> approval workflow behind it. Based on the EU rules for fund marketing
> communications (Regulation (EU) 2019/1156 Article 4, Delegated
> Regulation (EU) 2017/565 Article 44, Regulation (EU) 2019/2088
> Article 13) and the US rules for adviser and fund advertising (17 CFR
> 275.206(4)-1 and 17 CFR 230.482), as in force in 2026-10. The worked
> example is a fictional fund of the fictional manager Kestrel Bay
> Capital. Replace every `[bracketed]` value and every row marked
> *Example*. This is a document format, not investment, legal, tax or
> accounting advice, and not an offer of any security. Obtain the
> rules for the normative text.

<!--
Guidance: How to use this template
- The published factsheet is usually two pages: sections 1 to 9. Keep
  this full file as the controlled source, with section 10 as the
  record of data sources, checks and approval.
- A factsheet is a marketing communication. Every figure must match the
  official net asset value (NAV) and performance records, and the
  warnings in section 9 must be at least as visible as the
  performance. Route each monthly edition through Marketing Review
  Checklist (`compliance/marketing-review-checklist`).
- Pick the jurisdiction rows in section 9 that apply to where the
  factsheet is distributed. A factsheet for retail investors in the EU
  must not contradict the prospectus or the key information document.
- Show performance net of the share class's fees. Never show a
  composite or model return as if it were the fund's own return; refer
  readers to the Performance Composite Report
  (`finance/performance-composite-report`) for the strategy record.
- Related documents: Performance Attribution Report
  (`finance/performance-attribution-report`), Client Portfolio Review
  (`finance/client-portfolio-review`), Responsible Investment Policy
  (`finance/responsible-investment-policy`), SFDR PAI Statement
  (`compliance/sfdr-pai-statement`), Valuation Policy
  (`compliance/valuation-policy`).
-->

## Document control

<!-- Guidance: Identify the fund, share class, data date and approvers for this edition. Each monthly edition is a new version; keep every published edition for the record-keeping period. -->

| Field | Value |
|---|---|
| Document ID | [FS-KBGQE-IUSD-2026-09] |
| Version | [1.0] |
| Status | [Draft / Approved / Published / Withdrawn] |
| Owner | [@product-marketing-manager] |
| Approvers/reviewers | [@portfolio-manager], [@head-of-performance], [@compliance-officer] |
| Last updated | YYYY-MM-DD |
| Classification | [Public, for the audiences in section 9 / Professional investors only] |
| Fund and share class | [Fund name], [share class] |
| Data as at | [YYYY-MM-DD, month end] |
| Audience | [Retail / Professional / Institutional] in [countries] |
| Languages | [Languages of publication] |
| Distribution channels | [Website, platforms, sales team] |

### Approvals

| Role | Name | Decision | Date |
|---|---|---|---|
| Portfolio manager (commentary) | [@name] | [Approve] | YYYY-MM-DD |
| Performance team (figures) | [@name] | [Approve / Return] | YYYY-MM-DD |
| Compliance (marketing review) | [@name] | [Approve / Approve with changes / Reject] | YYYY-MM-DD |
| Legal (new jurisdiction or new template only) | [@name] | [Approve / Not required] | YYYY-MM-DD |

### Revision history

| Version | Date | Author | Change summary |
|---|---|---|---|
| 0.1 | YYYY-MM-DD | [@name] | First draft for data as at [YYYY-MM-DD] |
| 1.0 | YYYY-MM-DD | [@name] | *Example:* Approved and published for September 2026 |
| 1.1 | YYYY-MM-DD | [@name] | *Example:* Corrected sector weights after a classification fix; withdrawn edition archived |

## Contents

<!-- Guidance: Keep this list aligned with the headings. -->

1. [Key facts](#1-key-facts)
2. [Objective and strategy](#2-objective-and-strategy)
3. [Performance](#3-performance)
4. [Risk indicators](#4-risk-indicators)
5. [Portfolio composition](#5-portfolio-composition)
6. [Fees and costs](#6-fees-and-costs)
7. [Sustainability](#7-sustainability)
8. [Manager commentary](#8-manager-commentary)
9. [Important information and warnings](#9-important-information-and-warnings)
10. [Production, data and approval](#10-production-data-and-approval)
11. [Glossary and references](#11-glossary-and-references)

## 1. Key facts

<!-- Guidance: Give an investor the identity of the product in one table. Questions: is this the exact share class the performance relates to? Do the identifiers, dates and currency match the prospectus? Pitfall: mixing data from different share classes, for example the fund launch date with a later share class's returns. -->

| Item | Entry |
|---|---|
| Fund name | [Fund name] |
| Legal form and regime | [For example: sub-fund of [umbrella], a UCITS; US registered open-end fund; private fund] |
| Management company or adviser | [Name] |
| Investment manager | [Name] |
| Share class | [Class name] |
| Identifier | [ISIN / ticker / CUSIP] |
| Share class currency | [Currency] |
| Fund launch date | [YYYY-MM-DD] |
| Share class launch date | [YYYY-MM-DD] |
| Benchmark | [Index name, variant] and how it is used (comparison only, or constraint) |
| Fund size | [Currency amount] at [YYYY-MM-DD] |
| NAV per share | [Amount] at [YYYY-MM-DD] |
| Dealing frequency and cut-off | [Daily, HH:MM time zone] |
| Distribution policy | [Accumulating / Distributing, frequency] |
| Domicile and countries registered | [Country]; [countries] |
| Minimum investment | [Amount] |

*Example:* Kestrel Bay Global Quality Equity Fund (fictional) is a
sub-fund of [Umbrella name], a UCITS domiciled in [EU member state],
with [Management company] as management company. Kestrel Bay Capital
Europe is the delegated investment manager and the distributor in the
EU. It runs the same global quality strategy as Kestrel Bay Capital's
Global Quality Equity Composite, but it is a separate firm with its own
record (Performance Composite Report, section 1.1), so the fund is not
a member of that composite and its returns below are its own. Share class I USD Acc launched on
2018-10-01 at USD 100.00; NAV per share at 2026-09-30 is USD 211.98;
fund size USD 412.6 million. The benchmark is [a broad developed and
emerging market equity index, net dividends reinvested, USD], used for
performance comparison only; the fund is actively managed and does
not track it.

### 1.1 Share classes

| Share class | Identifier | Currency | Hedged | Ongoing charges (%) | Minimum investment |
|---|---|---|---|---|---|
| I USD Acc *(Example)* | [ISIN] | USD | No | 0.85 | USD 1,000,000 |
| A USD Acc *(Example)* | [ISIN] | USD | No | 1.60 | USD 1,000 |
| I EUR Hedged Acc *(Example)* | [ISIN] | EUR | Yes | 0.89 | EUR 1,000,000 |
| [Class] | [ID] | [Ccy] | [Yes / No] | [x.xx] | [Amount] |

## 2. Objective and strategy

<!-- Guidance: State the objective and the strategy in the same words as the prospectus, shortened but not changed. Questions: does the summary promise anything the prospectus does not? Pitfall: marketing language ("protects capital", "steady income") that the legal documents do not support. -->

| Item | Entry |
|---|---|
| Investment objective | [From the prospectus, shortened without changing its meaning] |
| Strategy summary | [Three to five sentences: universe, process, portfolio construction] |
| Typical number of holdings | [Range] |
| Use of derivatives | [None / for hedging / for investment purposes] |
| Recommended holding period | [Years, from the key information document where one exists] |
| Intended investor | [From the target market assessment] |

*Example:* The fund aims to grow capital over at least five years by
investing in listed shares of companies worldwide that earn high and
stable returns on capital. The manager selects 40 to 60 companies
through fundamental research and builds a portfolio without reference
to benchmark weights. Derivatives are used only to hedge the currency
of hedged share classes. The recommended holding period is five years.

## 3. Performance

<!-- Guidance: Present the share class's own net performance for standard periods, with the benchmark alongside. Questions: are all periods at the same date? Are periods shorter than one year cumulative, and longer periods annualised and labelled? Pitfall: showing only the flattering periods, or annualising a period shorter than a year. -->

All figures are for share class I USD Acc, in USD, net of ongoing
charges and transaction costs, with income reinvested, calculated NAV
to NAV. Past performance does not predict future returns.

### 3.1 Cumulative and annualised returns to 2026-09-30

| Period | Fund (%) | Benchmark (%) | Difference (pp) |
|---|---|---|---|
| 1 month *(Example)* | 1.47 | 1.44 | 0.03 |
| 3 months *(Example)* | 3.04 | 2.65 | 0.39 |
| Year to date *(Example)* | 7.19 | 5.92 | 1.27 |
| 1 year *(Example)* | 10.62 | 9.41 | 1.21 |
| 3 years, annualised *(Example)* | 13.90 | 16.00 | -2.10 |
| 5 years, annualised *(Example)* | 7.50 | 8.40 | -0.90 |
| Since share class launch (2018-10-01), annualised *(Example)* | 9.85 | 9.94 | -0.09 |
| Since share class launch, cumulative *(Example)* | 111.98 | 113.50 | -1.52 |

How the figures are built (*Example*):

- Monthly fund returns in 2026: January 1.80, February -0.90, March
  2.10, April -3.40, May 2.60, June 1.90, July 2.35, August -0.78,
  September 1.47 (%). Linking them gives a year-to-date return of
  7.19%; linking July to September gives 3.04%.
- 1 year: fourth quarter 2025 (3.20%) linked with year to date:
  1.0320 x 1.0719 = 1.1062, so 10.62%.
- 3 years: fourth quarter 2023 (9.80%), 2024 (13.20%), 2025 (10.90%)
  and year to date: 1.0980 x 1.1320 x 1.1090 x 1.0719 = 1.4776; to the
  power 1/3 minus 1 = 13.90% a year.
- 5 years: fourth quarter 2021 (6.10%), 2022 to 2025 and year to date:
  cumulative 43.59%; to the power 1/5 minus 1 = 7.50% a year.
- Since launch: eight complete years from 2018-10-01, cumulative
  111.98% (NAV 100.00 to 211.98); annualised 9.85%.
- Benchmark: the same linking applied to the index provider's series.
  Its calendar years match the benchmark column of the Performance
  Composite Report (`finance/performance-composite-report`), and its
  July to September 2026 months (1.985, -0.774, 1.440%) match the
  Performance Attribution Report
  (`finance/performance-attribution-report`): 1.01985 x 0.99226 x
  1.01440 = 1.02653, so 2.65% for three months. Since launch: fourth
  quarter 2018 (-12.80%), 2019 to 2025 and year to date (5.92%) give
  2.1350, so 113.50% cumulative and 9.94% a year.

$$
R_{\text{ann}} = \left( 1 + R_{\text{cum}} \right)^{1/n} - 1
$$

### 3.2 Calendar-year returns

| Year | Fund (%) | Benchmark (%) |
|---|---|---|
| 2025 *(Example)* | 10.90 | 13.02 |
| 2024 *(Example)* | 13.20 | 17.49 |
| 2023 *(Example)* | 20.30 | 22.20 |
| 2022 *(Example)* | -16.40 | -18.36 |
| 2021 *(Example)* | 19.00 | 18.54 |
| 2020 *(Example)* | 16.80 | 16.27 |
| 2019 *(Example)* | 26.90 | 26.60 |

Show complete 12-month periods only. In the EU, information on past
performance must cover the preceding five years (or the whole period
since launch if shorter) in complete 12-month periods, state the
reference period and source, and carry a prominent warning
(Delegated Regulation (EU) 2017/565 Article 44(4)). The partial launch
period (2018-10-01 to 2018-12-31, fund -11.20%, benchmark -12.80%) is
not shown as a calendar year.

### 3.3 Growth of 10,000

Show a line chart of an initial 10,000 in the share class currency
invested at launch, against the benchmark, using month-end values.
*Example:* USD 10,000 invested at launch was worth USD 21,198 at
2026-09-30 (fund) and USD 21,350 (benchmark), before any entry or exit
charges a retail investor may pay.

## 4. Risk indicators

<!-- Guidance: Give a fair picture of risk next to return. Questions: which risk indicator does the key information document use? Over what window are the statistics measured? Pitfall: showing volatility over a calm window while the performance table covers a crash year. -->

| Indicator | Fund | Benchmark | Basis |
|---|---|---|---|
| Summary risk indicator (1 to 7) *(Example)* | 4 | | From the PRIIPs key information document |
| Annualised volatility, 3 years (%) *(Example)* | 13.10 | 13.60 | Monthly returns, population standard deviation, times the square root of 12 |
| Tracking error, 3 years (%) *(Example)* | 2.60 | | Monthly active returns |
| Beta, 3 years *(Example)* | 0.94 | 1.00 | Against the benchmark |
| Sharpe ratio, 3 years *(Example)* | 0.74 | 0.87 | Risk-free rate 4.20% a year (3-month bill average) |
| Maximum drawdown, 5 years (%) *(Example)* | -21.40 | -24.90 | Month-end NAV, peak to trough |

*Example:* fund Sharpe ratio = (13.90 minus 4.20) / 13.10 = 0.74;
benchmark = (16.00 minus 4.20) / 13.60 = 0.87.

### 4.1 Principal risks

List the risks from the prospectus or key information document that
matter most for this fund, in short plain sentences:

| Risk ID | Risk | Plain description |
|---|---|---|
| FS-RSK-001 *(Example)* | Equity market risk | Share prices can fall sharply and the fund's value can fall with them |
| FS-RSK-002 *(Example)* | Currency risk | Holdings in other currencies can lose value when converted into the share class currency |
| FS-RSK-003 *(Example)* | Concentration risk | With 40 to 60 holdings, a fall in one company has a larger effect than in a broad index |
| FS-RSK-004 *(Example)* | Emerging markets risk | Some markets have less liquidity, weaker investor protection and higher political risk |
| [FS-RSK-NNN] | [Risk] | [Description] |

## 5. Portfolio composition

<!-- Guidance: Show what the fund holds at the data date. Questions: does the firm's holdings disclosure policy allow publication of named holdings and at what lag? Do the weights add up? Pitfall: weights that do not sum to 100%, or a top-10 list that is older than the rest of the factsheet. -->

### 5.1 Top 10 holdings

All company names are fictional.

| Rank | Holding | Sector | Country | Weight (%) |
|---|---|---|---|---|
| 1 *(Example)* | Northgate Instruments | Information technology | United States | 4.1 |
| 2 *(Example)* | Larkspur Biologics | Health care | United States | 3.8 |
| 3 *(Example)* | Tidewater Rail | Industrials | Canada | 3.6 |
| 4 *(Example)* | Aldermoor Software | Information technology | United States | 3.3 |
| 5 *(Example)* | Vessel Diagnostics | Health care | Switzerland | 3.1 |
| 6 *(Example)* | Brightmoor Bank | Financials | United Kingdom | 2.9 |
| 7 *(Example)* | Kinsella Automation | Industrials | Japan | 2.8 |
| 8 *(Example)* | Penhallow Insurance | Financials | Germany | 2.6 |
| 9 *(Example)* | Halden Foods | Consumer staples | Netherlands | 2.5 |
| 10 *(Example)* | Corran Payments | Information technology | United States | 2.4 |
| **Top 10 total** | | | | **31.1** |

### 5.2 Sector and region weights

| Sector | Fund (%) | Benchmark (%) |
|---|---|---|
| Information technology *(Example)* | 29.6 | 25.0 |
| Health care *(Example)* | 21.4 | 15.0 |
| Industrials *(Example)* | 19.8 | 18.0 |
| Financials *(Example)* | 17.5 | 27.0 |
| Consumer staples *(Example)* | 9.9 | 15.0 |
| Cash *(Example)* | 1.8 | 0.0 |
| **Total** | **100.0** | **100.0** |

| Region | Fund (%) |
|---|---|
| North America *(Example)* | 58.4 |
| Europe excluding UK *(Example)* | 18.2 |
| United Kingdom *(Example)* | 6.1 |
| Japan *(Example)* | 7.3 |
| Asia Pacific excluding Japan *(Example)* | 4.6 |
| Emerging markets *(Example)* | 3.6 |
| Cash *(Example)* | 1.8 |
| **Total** | **100.0** |

In this *Example* the benchmark has been simplified to five sectors so
that it matches the attribution report; a real broad index has more
sectors, and the table should list all of them.

### 5.3 Portfolio characteristics

| Characteristic | Fund | Benchmark |
|---|---|---|
| Number of holdings *(Example)* | 52 | [Number] |
| Active share (%) *(Example)* | 84 | |
| Weighted average market capitalisation (USD billion) *(Example)* | 186 | [Value] |
| Return on equity, weighted median (%) *(Example)* | 24.5 | [Value] |
| Price to earnings, forward, weighted harmonic mean *(Example)* | 22.8 | [Value] |
| Portfolio turnover, trailing 12 months (%) *(Example)* | 21 | |

Define each statistic in the glossary, state its source and date, and
use the same method every month.

## 6. Fees and costs

<!-- Guidance: Show the costs an investor bears in this share class, consistent with the legal documents. Questions: are the figures from the latest key information document or prospectus? Are entry, exit and performance fees shown? Pitfall: showing only the management fee when ongoing charges and transaction costs are higher. -->

| Cost item | Amount | Source |
|---|---|---|
| Entry charge *(Example)* | None for class I | Prospectus |
| Exit charge *(Example)* | None | Prospectus |
| Management fee (% a year) *(Example)* | 0.75 | Prospectus |
| Ongoing charges (% a year) *(Example)* | 0.85 | Key information document dated [YYYY-MM-DD] |
| Transaction costs (% a year) *(Example)* | 0.08 | Key information document |
| Performance fee *(Example)* | None | Prospectus |

*Example:* the ongoing charges of 0.85% include the 0.75% management
fee and 0.10% of administration, custody and other operating costs.
On an investment of USD 1,000,000, ongoing charges are about USD 8,500
a year and transaction costs about USD 800 a year, assuming a constant
value.

Costs reduce returns. For EU retail investors, cost figures must not
contradict the key information document; refer readers to it and to
the prospectus for the full cost disclosure.

## 7. Sustainability

<!-- Guidance: Show the fund's sustainability classification and the characteristics it promotes, consistent with its regulatory disclosures. Questions: what is the SFDR classification, if any? Does every sustainability claim appear in the pre-contractual disclosure? Pitfall: sustainability claims that go beyond the legal disclosures, which marketing rules treat as misleading. -->

| Item | Entry |
|---|---|
| SFDR classification (EU) | [Article 6 / Article 8 / Article 9 product] |
| Characteristics promoted or objective | [From the pre-contractual disclosure] |
| Binding elements | [Exclusions, minimum proportions] |
| Principal adverse impacts considered | [Yes, how / No] |
| Link to disclosures | [Website section with pre-contractual and periodic disclosures] |
| Fund name rules | [Whether the name uses ESG or sustainability terms, and the applicable rules] |

*Example:* the fund promotes environmental and social characteristics
(an Article 8 product under Regulation (EU) 2019/2088). It excludes
companies above the revenue thresholds set out in its pre-contractual
disclosure for thermal coal and controversial weapons. Article 13 of
that Regulation requires marketing communications not to contradict
the sustainability disclosures, so this section repeats them only in
summary. SFDR 2.0, the Commission proposal
COM(2025) 841 to amend that Regulation, is a proposal and not law as of 2026-10: the European Parliament and the Council have adopted their negotiating positions and trilogue negotiations are under way; check the current status before each edition.

## 8. Manager commentary

<!-- Guidance: Explain the month or quarter in plain language: what happened, what drove the result, what the manager did. Questions: is the commentary balanced, mentioning detractors as clearly as contributors? Pitfall: forecasts or promises ("we expect strong returns") that a reviewer must remove; describe positioning and reasons instead. -->

[Two to four short paragraphs, at most about 200 words: market
background, main contributors and detractors, changes made to the
portfolio, and current positioning. Avoid predictions of returns.]

*Example:* Global equities rose in September as inflation data eased.
The fund returned 1.47%, slightly ahead of the benchmark (1.44%).
Northgate Instruments contributed most after raising its guidance,
while Brightmoor Bank detracted as expectations for bank margins fell.
Over the quarter, stock selection in industrials added most to
relative return, while not owning a large semiconductor company that
led the benchmark was the biggest single cost. During the month the
manager reduced the position in Halden Foods and added to a new
holding in the health care sector. The portfolio remains overweight
health care and information technology and underweight financials and
consumer staples. Detailed attribution for the strategy's
representative portfolio is in the quarterly attribution report.

## 9. Important information and warnings

<!-- Guidance: Include the warnings and statements required where the factsheet is distributed, in the language of the audience. Questions: which jurisdictions, which audiences, which product regime? Is each warning as prominent as the performance? Pitfall: one generic disclaimer block for every country, which misses specific requirements such as the summary of investor rights in the EU. -->

### 9.1 Warnings to show prominently

- **Past performance does not predict future returns.** The value of
  investments and the income from them can fall as well as rise, and
  investors may get back less than they invested.
- **Currency.** Where returns are shown in a currency other than the
  investor's own, the return may rise or fall because of exchange-rate
  movements.
- **Marketing communication.** This is a marketing communication.
  Read the prospectus and the key information document before making
  any final investment decision.
- **No advice.** This factsheet does not take account of any
  investor's objectives or circumstances and is not a recommendation.

### 9.2 Requirements by jurisdiction (as of 2026-10; check local law)

| Jurisdiction and product | Main rules | What to include or check |
|---|---|---|
| EU, UCITS or AIF marketed to investors | Regulation (EU) 2019/1156 Art. 4; ESMA guidelines on marketing communications (ESMA34-45-1272, applied from 2022-02-02) | Identify as marketing communication; risks and rewards equally prominent; fair, clear, not misleading; for UCITS, say a prospectus and key information document exist and where, how and in which language to get them, with links; link to a summary of investor rights; state that marketing arrangements may be terminated |
| EU, information from MiFID investment firms | Delegated Regulation (EU) 2017/565 Art. 44 | Firm name; risk warnings in at least the predominant font size; past performance not the most prominent feature, five years of complete 12-month periods, reference period and source, currency warning, effect of fees where gross |
| EU, retail packaged products | Regulation (EU) No 1286/2014 (PRIIPs) | Factsheet must be consistent with the key information document, including the summary risk indicator, costs and past-performance information published with the KID |
| EU, sustainability | Regulation (EU) 2019/2088 Art. 13 | Marketing must not contradict SFDR disclosures |
| US, registered investment adviser marketing (including private fund factsheets) | 17 CFR 275.206(4)-1 | General prohibitions; net with gross at equal prominence; 1-, 5- and 10-year periods for portfolio performance (not required for private funds); rules on extracted, hypothetical and predecessor performance |
| US, registered open-end fund advertising | 17 CFR 230.482 | Standardised 1-, 5- and 10-year average annual total returns to the latest calendar quarter end; required legend on past performance; toll-free number or website for month-end performance; FINRA filing where a member firm distributes (FINRA Rule 2210, cited by number only) |
| UK | FCA conduct and financial promotion rules (cited by reference) | Fair, clear and not misleading; past performance and risk warnings; Consumer Duty consumer understanding outcome |
| [Other jurisdiction] | [Rule] | [Requirement] |

Insert the legal notices for each distribution country here (for
example the representative and paying agent in countries that require
them), the index provider attribution line required by the benchmark
licence, and the data sources and their dates.

### 9.3 Issuer statement

*Example:* Issued by Kestrel Bay Capital Europe, [authorised and
regulated by [regulator] in [country]], for [professional and retail]
investors in [countries]. [Umbrella name] is a UCITS authorised in
[country]. The prospectus, key information documents (in [languages])
and a summary of investor rights (in [languages]) are available free
of charge at [website] and from [address]. The management company may
decide to terminate the arrangements for marketing the fund in any
country.

## 10. Production, data and approval

<!-- Guidance: Record how the factsheet is produced each month and what is checked. Questions: who owns each data item, and how are figures reconciled to the official NAV? Pitfall: a design agency or platform adding figures or wording after compliance approval. -->

```mermaid
flowchart LR
    N[Official NAV and returns] --> D[Factsheet data file]
    H[Holdings and characteristics] --> D
    K[KID, prospectus, SFDR disclosures] --> D
    D --> C[Commentary drafted by PM]
    C --> P[Figures check by performance team]
    P --> M{Compliance review passed?}
    M -- No --> R[Correct and resubmit]
    R --> P
    M -- Yes --> L[Publish, archive, notify platforms]
```

| Control ID | Control | Owner | Evidence |
|---|---|---|---|
| FS-CTL-001 *(Example)* | Every return reconciles to the official NAV series to two decimals | [@head-of-performance] | Reconciliation sheet |
| FS-CTL-002 *(Example)* | Sector, region and top-10 weights sum to 100% and match the holdings file at the same date | [@product-data-analyst] | Data check log |
| FS-CTL-003 *(Example)* | Costs, risk indicator and sustainability text match the latest legal documents | [@compliance-officer] | Marketing review record |
| FS-CTL-004 *(Example)* | Holdings published only within the firm's disclosure policy (for example a one-month lag) | [@compliance-officer] | Policy reference |
| FS-CTL-005 *(Example)* | Approved PDF is the only version distributed; prior editions archived | [@product-marketing-manager] | Archive index |
| [FS-CTL-NNN] | [Control] | [@owner] | [Evidence] |

| Data item | Source | Date | Owner |
|---|---|---|---|
| NAV and returns *(Example)* | Fund administrator | 2026-09-30 | [@fund-accounting] |
| Benchmark returns *(Example)* | Index provider file | 2026-09-30 | [@head-of-performance] |
| Holdings and weights *(Example)* | Portfolio accounting system | 2026-09-30 | [@product-data-analyst] |
| Ongoing charges, risk indicator *(Example)* | Key information document | [YYYY-MM-DD] | [@product-governance] |
| [Item] | [Source] | [Date] | [@owner] |

Keep each published edition, its data file and its approval record for
the period required by the applicable record-keeping rules; for a US
adviser, check 17 CFR 275.204-2.

## 11. Glossary and references

<!-- Guidance: Define every statistic used in the factsheet in plain language, and list the rules consulted with their dates. -->

### 11.1 Glossary

| Term | Meaning in this document |
|---|---|
| NAV | Net asset value per share: the value of the fund's assets minus liabilities, divided by shares in issue |
| Accumulating share class | A class that reinvests income instead of paying it out |
| Annualised return | The constant yearly return that would give the same cumulative result over the period |
| Volatility | How much returns vary, measured as the annualised standard deviation of monthly returns |
| Tracking error | Annualised standard deviation of the difference between fund and benchmark returns |
| Maximum drawdown | The largest fall from a peak to a later low in the period |
| Active share | Half the sum of absolute differences between fund and benchmark holding weights |
| Ongoing charges | Annual costs of running the fund deducted from its assets, as shown in the legal documents |
| Summary risk indicator | The 1 to 7 risk class shown in a PRIIPs key information document |
| Marketing communication | Any communication that promotes the fund, other than the legally required documents |

### 11.2 References

| Reference | Version or date | Use |
|---|---|---|
| Regulation (EU) 2019/1156 (cross-border distribution of funds), Article 4 | OJ L 188, 12.7.2019; check the consolidated text | Marketing communication requirements |
| ESMA Guidelines on marketing communications under the Regulation on cross-border distribution of funds (ESMA34-45-1272) | Published 2021-08-02, applied from 2022-02-02 | Identification, risks and rewards, fair and clear presentation |
| Commission Delegated Regulation (EU) 2017/565, Article 44 | As amended; check the consolidated text | Past, simulated and future performance information |
| Regulation (EU) 2019/2088 (SFDR), Articles 8, 9 and 13 | As in force 2026-10; amendments proposed | Sustainability classification and marketing consistency |
| Regulation (EU) No 1286/2014 (PRIIPs) | As in force 2026-10 | Key information document consistency |
| 17 CFR 275.206(4)-1 (Investment Adviser Marketing) | As in force 2026-10 | US adviser advertising |
| SEC Marketing Compliance FAQ | Updated 2025-03-19 and 2026-01-15 | Net performance with actual fees, extracted performance |
| 17 CFR 230.482 (advertising by investment companies) | As in force 2026-10 | US registered fund performance advertising |
| FINRA Rule 2210 (number only) | Current | Communications with the public by member firms |

## Standard and licence note

Based on EU legislation (Regulation (EU) 2019/1156, Delegated
Regulation (EU) 2017/565, Regulation (EU) 2019/2088 and Regulation
(EU) No 1286/2014, reused from EUR-Lex with acknowledgement), the ESMA
guidelines on marketing communications (cited by reference; ESMA does
not endorse this template) and US federal rules (17 CFR 275.206(4)-1
and 17 CFR 230.482, public domain), all cited by article or section
and summarised in original wording. FINRA and FCA rules are cited by
number or reference only. The fund, managers, companies and figures in
the worked example are fictional. The text is original. Check the
current official versions and local law in each distribution country
before use. This is a document format, not investment, legal, tax or
accounting advice. Template licence: MIT.