Swedish Code of Conduct for fund management companies

Adopted by the Board of Directors of the Swedish Investment Fund Association on 6th December 2004. The Code was most recently revised on 13th May 2019.

This is the introduction to the Code of conduct, please download the full document. (pdf 55kB)


This Code is designed to promote sound fund activities and thereby to safeguard public confidence in the same. The Code comprises rules that exceed the standards imposed on fund management operations by legislative and other statutory requirements.[1]

The Code takes into account the principles adopted by the European Fund and Asset Management Association, EFAMA.

The Code applies to the operations conducted by Swedish and foreign fund management companies in Sweden. Where the fund management company has delegated operations to another party, the fund management company shall strive to ensure that the principles of the Code, where relevant, are applied by the contractor.

In those sections where the Code exceeds the legislative and other statutory requirements, the principle to be applied is “comply or explain”, since the preconditions may vary for individual fund management companies with regard, for example, to organization and size. Foreign fund management companies may experience difficulties in complying with every aspect of the Code due to regulatory differences in their home countries. For Swedish fund management companies, however, the intention is that deviations shall not be permitted when the word “must” is used. Members of the Swedish Investment Fund Association must, in their Annual Reports or on their website, clearly state that they comply with the Code and must provide an explanation for any deviations.

The Code is complemented by concrete rules of conduct issued by the Association in other Guidelines. The Association has, in addition to this Code, issued the following Guidelines, which must be adhered to by its members:

  • Guidelines for marketing and information by fund management companies
  • Guidelines for investment fund managers as shareholders
  • Guidelines concerning trading in securities for own and related person’s account
  • Guidelines for key ratio accounting of investment funds

A fund management company is tasked with managing the monies with which it is entrusted. The fund management company must behave with considerable integrity in the fulfillment of this position of trust. The fund management company must, in conjunction with the management of a fund, act exclusively in the common interests of the unit holders, which means that other interests must yield in the event of any conflicts of interest. The operations of the fund management company must be conducted in an honest, fair and professional manner and the conduct of the company and its operations must also otherwise be such that confidence in the fund management company and the sector is maintained. Any person representing a fund management company must act in an ethically acceptable manner.

Fund management companies may, in addition to their fund activities, be licensed to engage in individual portfolio management. This Code focuses primarily on the fund activities. The operations conducted within the framework of individual portfolio management are regulated by the Swedish Securities Market Act (2007:528) and the Swedish Financial Supervisory Authority Regulations, FFFS 2007:16. In cases where the rules laid down in the Code may, in addition to unit holders, include clients in the individual portfolio management sector, the term “investor” is used.

A number of the concepts used in the Code are defined in appendix 1.