Investor protection

Integration of Sustainability risks

SEB has adopted  SEB Group´s Policy on the Integration of Sustainability Risk and Impact in Investment Decisions and Investment Advice (PDF). More information about sustainability can be found on responsible investing webpage.

SEB has integrated sustainability risks into investment decisions taken while providing portfolio management services, also into provision of investment advice and insurance advice in the following manner.

Funds managed within the SEB Group

Funds managed within the SEB Group are managed by Skandinaviska Enskilda Banken AB (publ) subsidiaries. The funds’ exposure to sustainability risks and the transmission channels that could make such risks materialize are analysed and managed through a strategy involving integration, engagement and exclusion.

Funds managed by external parties

All external fund providers are signatories to the UN Principles for Responsible Investments. The funds available in the investment universe have been evaluated and selected through a sustainability assessment. The level of analysis for each fund is decided using a risk-based approach where the materiality of the strategy is taken into consideration by assessing volume, portfolio composition and risk level. The qualitative fund analysis takes into consideration each fund´s integration of sustainability risks through a methodology involving the following points of analysis:

• Organisation and Resources – management company´s sustainability approach;
• ESG (Environmental, Social and Governance criterias) Integration – sophistication of integration processes;
• Active Ownership – voting and engagement.

Directly owned assets

Directly owned assets (fixed income instruments) are analysed by assessing the asset’s exposure to sustainability risks and the transmission channels that could lead to such risks. The work includes assessing materiality factors for the industry in which the issuer of the financial instrument operates, and managing identified risks, primarily by application of exclusion principles.

Results of the sustainability risk impact assessment

SEB estimates that the diversified nature of funds’ underlying assets and management companies’ work on sustainability integration, together with the exclusions made by SEB, mitigate significant sustainability risks associated with financial instruments and insurance products SEB advises on.

SEB estimates that the diversified nature of portfolios, the exclusions made by SEB and, in case of funds, management companies’ sustainability integration mitigate significant sustainability risks associated with financial instruments included into the available model portfolios.

Different Kinds and Sources of Risk

Any investment activity involves risks, i.e. the threat of suffering losses as well as the threat of failing to achieve the planned investment result. Investment risks must be assessed before making an investment decision as well as regularly when holding a security or a contract. The brief overview given on this website does not provide an exhaustive list or description of all the risks and considerations related to investment.

Each client must, depending on specific circumstances, carefully analyse and independently assess risks related to investment activities and take their possible impact and consequences into account. Thereby the properties and possible yield of each specific security, service or other investment product, the client's own risk tolerance and investment objectives must also be taken into consideration.

General risks related to investment

Avoidance of Conflicts of Interest

SEB Pank Group offers its clients a large range of financial services and may in addition deal on own account. This situation may cause conflicts of interest between:

• different areas of activity and/or units within SEB Pank Group;
• SEB Pank Group (including managers, employees, representatives and persons that are in direct or indirect control relationship with SEB Pank Group) and the clients of SEB Pank Group; or
• the clients of SEB Pank Group.

The bank has thoroughly analysed the areas where potential conflicts of interest may arise. As a result of the analysis, the bank has adopted appropriate measures that must be followed to avoid possible conflicts of interest, or if such conflicts have already arisen, minimise their negative effect on clients.

The measures are as follows:

• areas of activity between which conflicts of interest may occur are separated from each other and the bank ensures that these areas of activity are not exposed to the influence of other activities;
• confidentiality of potentially sensitive activities is ensured;
• internal procedure rules are adopted to ensure that employees (and their close relatives) do not personally profit at the expense of clients while working in the bank;
• lines of accountability and remuneration systems that could have an unfavourable impact on clients are avoided;
• employees are subject to an obligation to keep in mind only the interests of the client at all times while acting on behalf of the client and to refrain from taking into account any inappropriate factors related to the interests of other persons.

A more detailed description of possible conflicts of interest and of measures for prevention and mitigation thereof can be found in the internal procedure rules Policy on the Management of Conflicts of Interest.

Fees and benefits (inducements) when providing investment services and ancillary services

In general, the bank provides its services for a fee and the client pays directly to the bank. The pricelist for the services provided by the bank is available on the website of the bank and in bank offices.

In certain cases, however, the bank may receive monetary and non-monetary fees and benefits from a party other than the client (or the representative of the client) in relation to the provision of an investment service or an ancillary service to the client. It may also happen that the bank pays fees and offers benefits to a person other than the client. In order to avoid conflicts of interest and to comply with statutory requirements, the bank receives inducements from a party other than the client and provides them to a party other than the client only if:

• the inducement does not cause a conflict of interest between the bank and the client due to its character or function;
• the inducement does not prevent the bank from providing services honestly, professionally, and in accordance with the best interests of the client; and
• the inducement is designed to enhance the quality of the service provided to the client.

Information about inducements received or paid shall be disclosed to the client before a transaction. An individual notification about inducements that the bank has received from or given to third persons in relation to the provision of an investment service or an ancillary service to the client during the year is included in the annual report on costs and charges presented to the client.

In relation to the provision of an investment service or an ancillary service the bank may receive from or offer to third persons the following minor non-monetary benefits:

• generalised or individualised information or document related to an investment service or a security;
• written materials received from a third person contracted by and paid for by the issuer or a potential issuer and intended for marketing a new issue of securities or that the third person regularly prepares under an agreement made with and for a fee payable by the issuer, provided that the material clearly sets out the relevant contractual relationship and the material is made simultaneously available to any investment firm that has requested it or to the general public;
• participation in a conference, seminar, and other training that discusses the advantages and properties of a certain investment service or security;
• hospitality of a reasonable minimised value, such as food and drink served during a business meeting or the above-mentioned events;
• other minor non-monetary benefit that could enhance the quality of service provided to a client and, having regard to the total level of inducements provided by one or several entities, is of the scale and nature that are unlikely to prevent the investment firm from providing its services honestly, professionally, and in accordance with the best interests of the client.

Fund units

The bank may distribute different funds managed by different fund managers and a fund manager may pay the bank a fee for sold fund units.

The bank may receive the following fees for distribution of fund units:

• a one-off fee upon issue or redemption of fund units calculated as a percentage of the sum invested in the fund units; or
• an annual fee that is a specific percentage of the management fee received by the fund manager; or
• as a combination of both of the above fees.

The amount of the fee received by the bank and the terms of payment is stipulated in a contract made between the bank and the relevant fund manager. The amount of the fee and the terms of payment may be different for different fund managers as well as for different funds managed by the same fund manager. Information about the amount of the fee (PDF).

The bank does not recieve a fee for brokering SEB UC/UD fund units.

NB! The following description of financial instruments is of a general nature. The terms and conditions applying to individual financial instruments can vary, and investors should always take care to ensure that they investigate and are fully informed about the particular characteristics and risks of the instruments in which they invest. The bank does not assume any liability for damage that clients may incur if they make their investment decisions on the basis of only the following information and do not study the respective instruments more closely.

Please note that SEB can not fully evaluate the target market for financial instruments that are available solely at the customer’s initiative since in that case SEB does not have sufficient information available to ensure a full target market assessment. Due to that, client’s protection decreases as there is no certainty that a product is compatible to the client.

Target market information (PDF)

Regarding Securities in General
Securities (i.e. bonds, units of funds, custody certificates or other rights or obligations which are the subject of trading on financial instruments markets) normally yield a positive return in the form of a dividend (in the case of shares), or interest (in the case of bonds). In addition, the price (i.e. market value) of the security may appreciate and depreciate relative to its price / market valuation at the time when the investment was made. Hereinafter, the word "investment" is also used in the case of negative positions in securities (i.e. the "short" sale by an investor of a security which it does not own, but has borrowed).

The total return on an investment is the sum of dividends/interest rate payments and any change in the market value of the security. Derivative instruments, such as options, forwards, futures, etc., are issued for a variety of underlying assets, including shares, bonds, precious metals and currencies. Derivative instruments may be used to decrease the risk of an investment or to produce greater returns.

What every investor seeks is a positive return on an investment - that is, an investment that yields a profit, preferably as large as possible. But there is also a risk that the net return of an investment is negative, i.e. that the investment generates a loss. The risk of a loss varies with the security, as the prospect of a profit is usually correlated with the risk of a loss. The longer the duration of an investment, the greater the prospect of a profit and the risk of a loss. There are varying methods of investing in securities to minimise risks. It is usually considered safer not to invest solely in one or a few securities, but to instead diversify the investment across several or many financial instruments. These securities should then provide a dispersion of the risks, rather than producing a concentration of risks that may be realised simultaneously. When investing in securities listed in a foreign denomination, there is also a foreign exchange risk.

Investments in specific securities are associated with specific financial risks, as described in more detail at "Risks".

The risk is assumed by the client, who must therefore seek advice from its investment service provider or asset manager in relation to the properties, risks, terms and conditions applicable to specific investments. The client must also continuously monitor its investments in securities regardless of whether the client received individual investment advice before entering into the investment. Information required to monitor holdings of investments, such as prevailing market prices, are published in major newspapers, at various websites maintained by market operators, financial service companies and other public media. Furthermore, the client should, with its own best interests in mind, be prepared to take swift action, where necessary, to close positions which unexpectedly develop negatively, or to provide additional collateral for investments that have been financed by the use of loans if the collateral has depreciated in value.

The buying and selling of shares on regulated markets and other market venues constitutes a secondary market in the shares issued by a company. Efficient secondary markets, which are markets in which it is easy to find buyers and sellers and where bids and prices of concluded transactions are continuously published in an environment of open information, are also beneficial to the companies whose securities have been admitted for trading on regulated markets, since as a result it will be easier for them to issue new securities to raise new capital.

Different market venues
There are several kinds of market venues in which to buy and sell securities. Market venues are normally regulated markets, multilateral trading facilities (MTF) or systematic internalisers and where OTC-trading is provided with investment service companies; market makers or other liquidity guarantors or other persons who perform similar duties or functions with the aforementioned persons.

Regulated markets
Various securities can be traded on a regulated market. Strict requirements are imposed on companies admitted for trading on regulated markets with obligations that relate, among other things, to the size of owners' equity, owners, business history and financial disclosures of the company. A list of regulated markets is maintained by the European Commission

Multilateral trading facility
A multilateral trading facility (MTF) may be described as a trading system that is provided by a regulated market or a financial service company. Generally, the requirements imposed on issuers of securities admitted for trading at an MTF are lower than the requirements imposed by regulated markets.

An MTF is often also called an alternative market, because it is an alternative to a regulated market, the latter being subject to far stricter requirements regarding admitting securities for trading, etc. In a multilateral trading facility non-concurrent or concurrent offers for trading in securities can be made and financial instruments can be traded between different persons on equal terms. The main difference between the facility and a regulated market (e.g. a stock exchange) is lower liquidity of the securities traded at the MTF in comparison with securities traded on a regulated market.

Systematic internalisers
A systematic internaliser is an investment service company that on a regular and systematic basis matches clients' orders outside a regulated market or an MTF by concluding transactions with clients on its own account.

A systematic internaliser must disclose its price quotation about liquid shares admitted for trading on a regulated market on a regular and constant basis at the usual trading time. A systematic internaliser must disclose to other market participants the volume, price and time of the transactions executed by it in an easily available manner.

The share price quotation contains the price the execution of which is mandatory for a systematic internaliser in the case of transactions that are not larger than the standard market volume of the class of share. The share price must indicate the conditions applicable with regard to the share on the market.

Classification of Investment Products

Bonds (PDF)
Funds (PDF)
Exchange-traded products (PDF)
Equities (PDF)
Derivatives (PDF)
General information about classification of securities (PDF)

For the purpose of investor protection guarantee systems financed by market participants have been established on the initiative of the state or different market participants. The main goal thereof is to:

• protect investors against risks which may threaten them upon investment in securities markets;
• ensure regular and reliable functioning of the securities market;
• Increase the reliability and stability of the financial sector;
• preclude the possibility of inflicting losses on investors due to acts or omissions of the provider of investment services and to
• alleviate the consequences of loss events, which have already taken place.

1. Investor protection arising from the Guarantee Fund Act

The Guarantee Fund is a legal person in public law founded under the Guarantee Fund Act (GFA) who commenced operation on 1 July 2002. The objective of the Fund is to guarantee protection of depositors, investors, unit-holders of mandatory pension funds and funds invested by the policyholders in the insurer's pension agreements.

In order to achieve its objective, the Fund:

• collects single and quarterly contributions from credit institutions, investment institutions, management companies of mandatory pension funds and insurers concluding pension agreements; 
• pursuant to the terms and conditions and in the extent and according to the procedure stipulated by law compensates:
  • deposits for depositors placed thereby with credit institutions;
  • investors for their investments and
  • any damage caused by a pension management company to unit-holders;
• supports the transfer of the insurance portfolio of insurer's pension agreements to another insurer.

Out of the contributions received by the Guarantee Fund, the Fund will establish:

• the Deposit Guarantee Sectoral Fund,
• the Investor Protection Sectoral Fund,
• the Pension Protection Sectoral Fund, and
• the Annuity Protection Sectoral Fund and
• the Resolution Sectoral Fund.

The specific procedure for guaranteeing and compensating deposits and investments as well as the categories of deposits and investments not subject to guarantees or compensation has been provided for in the GFA and legislation issued on the basis thereof.

The following is a brief summary of the main aspects of functioning of the Guarantee Fund. For further information about the activities of the Guarantee Fund contact the Fund (Roosikrantsi 2, 10119 Tallinn; phone 611 0730; e-mail tf@tf.ee; www.tf.ee). SEB or its subsidiaries have made the required contributions to the respective sectoral funds.

The Deposit Guarantee Sectoral Fund is established out of the contributions of credit institutions and used in order to guarantee and compensate, according to the provisions of the GFA, 

• for deposits of depositors of a credit institution established and received its activity license in Estonia and of the branches of this credit institution, established abroad.
• the deposits of such an Estonian branch of a credit institution of a Contracting States of the European Economic Area or of an Estonian branch of a credit institution of another foreign country concerning the part, which is guaranteed under a protection scheme of such a foreign country in a smaller amount than the guaranteed rates, set out in GFA.

Deposits, with the interest thereon as of the date, on which the deposits become unavailable, are guaranteed and compensated for, but not more than in the amount of 100,000 euros per depositor in any one credit institution. Interest on a deposit is calculated:

• on the basis of the rates provided for in the settlement or loan contract or,
• in the absence of a written agreement, on the basis of the rates provided for in the standard depositing terms valid in the credit institution on the date on which the deposits become unavailable.

Compensation shall be paid by transfer to the bank account indicated by the depositor or, on the basis of an application of the depositor, in cash through one or several Estonian or foreign credit institutions specified in a resolution of the supervisory board of the Guarantee Fund.

The compensation is paid out in euros, in account currency or in the currency of the country of location. Based on the application of the depositor, the compensation can be paid also in the currency of the EU member state, which is the country of residence of the depositor. If the account currency was different from the payment currency of compensation, the European Central Bank daily rates as at the day the deposits become unavailable are used as exchange rate.

If the fee payable by a depositor for payment of compensation in cash or by a bank transfer is higher than or equal to the amount of compensation, the compensation shall not be paid. The fee chargeable for the payment of compensation may not be higher than the usual fee chargeable by a credit institution for similar services.

The payment of compensations shall be completed within 7 working days as of the date on which deposits become unavailable.

The Investor Protection Sectoral Fund is established out of the contributions of investment institutions. It is used in order to guarantee and compensate the investors, in accordance with the provisions of the GFA, for investments made through an investment institution registered in Estonia or the Estonian branch of a foreign investment institution.

Investment institutions are investment firms for the purposes of the Securities Market Act, credit institutions and management companies.

Investments are claims based on an agreement between the parties or on legislation, arising from which an investment institution is obliged to disburse to an investor money or transfer securities which are owed or which belong to the investor and which the investment institution has kept on the investor's account or disposed of with regard to the provision of investment services.

Investments are guaranteed and compensated for to the extent of their value as of the compensation date, but not more than in the amount of 20,000 euros per investor in any one investment institution.

The value of a foreign currency and securities nominated in a foreign currency is converted into euros on the basis of the foreign exchange reference rate of the European Central Bank as of the compensation date. Compensation is paid in money by a bank transfer to the account indicated by the investor.

An investment the owner of which has outstanding liabilities to the same investment institution shall not be compensated for out of the Sectoral Fund to the extent of such liabilities. Investments, which are subject to compensation under §§ 52 and 53 of the Estonian Central Register of Securities Act, which regulates the civil liability of the registrar of the Estonian Central Register of Securities and the account manager in compensating for damage, is not compensated for out of the Sectoral Fund.

The Pension Protection Sectoral Fund is established out of the contributions of pension management companies and used in order to compensate, in accordance with the terms and conditions and pursuant to the procedure provided for in the GFA, for the loss caused to the unitholders of a mandatory pension fund for which the unit-holders have not been compensated by the pension management company pursuant to §§ 32-36 of the Funded Pensions Act (FPA) by the due date established by the Supervision Authority.

Loss means loss for the purpose of subsection 32 (1) and (2) of the FPA, whereby the Financial Supervision Authority has ascertained that there has been a violation of the requirements provided by legislation or the rules of a pension fund and the violation has caused loss to the unit-holders of the pension fund.

The extent of the loss is determined on the basis of all the proprietary damage caused, including any loss of profit compared to the situation that would exist if such violation had not occurred and where the assets of the pension fund associated with the violation would have been invested similarly to the other assets of the pension fund.

A unit-holder is compensated in full for loss subject to compensation out of the Pension Protection Sectoral Fund in the amount of up to 10,000 euros per specific loss event. Any loss exceeding 10,000 euros per specific loss event of a unit-holder shall be compensated for to the extent of 90%.

The registrar of the Estonian Central Register of Securities shall, for the amount of compensation granted to a unit-holder, acquire for the unit-holder the maximum whole number of units of the pension fund to which the unit-holder makes mandatory funded pension contributions at the time of payment of the compensation.

If a unit-holder has entered into a pension agreement or if he/she has deceased, the units of the existing pension fund, whose units he/she acquired last shall be acquired for him/her. If all the pension funds, whose units the unit-holder has acquired, have been liquidated, the units of the pension fund specified by the unit-holder or their successor shall be acquired for the compensation.

The Annuity Protection Sectoral Fund is established out of the contributions of insurers and used in order to guarantee the performance of the liabilities under pension agreements to the extent provided for in the GFA, supporting the transfer of the pension agreement insurance portfolio of an insurer and an Estonian branch of an insurer of a Member State of the European Economic Area, except Estonia, to another insurer in the case of revocation of the activity licence, establishment of a special regime or declaration of bankruptcy of the insurer.

The support guarantees the contributions to pension under pension agreements (insurance contract for mandatory funded pension) for policyholders. The support amount shall be found as the difference between the technical provisions and financial liabilities according to pension agreements and the committed assets according to the insurance portfolio.

Resolution Sectoral Fund is formed of the contributions of credit institutions and investment firms specified in the Financial Crisis Prevention and Resolution Act and the resources of this sectoral fund are used only for the purpose of financing the crisis resolution tools and powers applicable to credit institutions and investment firms, their subsidiaries and branches specified in the Financial Crisis Prevention and Resolution Act.

2. Investor protection arising from the Rules of the Tallinn Stock Exchange

The guarantee of transactions (Stock Exchange Transactions) made on the NASDAQ Tallinn Stock Exchange (the Stock Exchange) are regulated by the Rules of the Stock Exchange. A guarantee fund has been established out of monetary contributions made by the members of the Stock Exchange for the purpose of securing Stock Exchange Transactions.

The Stock Exchange disposes of the funds of the guarantee fund if it becomes evident that a Stock Exchange Transaction cannot be realised due to insolvency of a member of the Stock Exchange. Insolvency includes initiation of bankruptcy proceedings, declaration of a moratorium or other similar proceedings which result in restrictions on disposal of the assets of a member of the Stock Exchange.

The Stock Exchange also has the right to use the funds of the guarantee fund if any other failure to realise a Stock Exchange Transaction would obviously jeopardise the regular functioning of the market. A member of the Stock Exchange is also responsible for ensuring that its client has sufficient funds to realise a Stock Exchange Transaction (securities in the case of a sales transaction and money in the case of a purchase transaction).

AS SEB Pank is a member of the Tallinn Stock Exchange and it has paid its contribution to the guarantee fund.

For further information about the guarantee fund of the Stock Exchange contact the Stock Exchange (Tartu mnt 2, 10145 Tallinn; phone 640 8800; tallinn(at)nasdaq.com; www.nasdaqbaltic.com).

3. Investor protection arising from the Estonian Central Register of Securities Act

According to subsection 53 (2) of the Estonian Central Register of Securities Act, an account administrator shall insure the liability arising from administration of accounts.

As a member of the group of Skandinaviska Enskilda Banken AB, AS SEB Pank is insured against possible damage and losses arising from illegal activities of bank employees or third parties or criminal attacks or bank employees' negligence related to office.

AS SEB Pank (hereinafter SEB or the Bank) operates in Estonia on the basis of an operating licence as a credit institution and can provide investment services in addition to other financial services.

SEB offers the following investment services:

• receiving and transmitting orders relating to securities;
• executing orders relating to securities in the name or on behalf of customers;
• dealing in securities on its own account;
• management of securities portfolios;
• providing investment advice.

Transmission and execution of the transaction orders of customers

Securities may be traded both in designated trading venues (such as a regulated market or a multilateral trading facility) and outside of them. The customer can submit orders for securities transactions either in a branch office of the Bank or via the Internet Bank and, in certain cases, also through an employee of SEB Markets. In addition, it is possible to submit certain orders in Roboinvestor.

Depending on whether the Bank has access to a particular trading venue, the broker will execute the order of the customer themselves or transmit it to another broker (another bank or investment firm) with access to the relevant market for execution.

When executing and transmitting an order, SEB follows the Best Execution Policy.

The customer relationships of SEB in the provision of investment services are governed by the terms and conditions of the relevant product.

The terms and conditions relating to the securities account of the Bank and trading in securities as well as the terms and conditions of transactions (including currency transactions) executed under financial markets customer agreements can be found on the website of the terms and conditions for products and services.

Contact details of the SEB Markets department, which is related to services provided under financial markets customer agreements

The Bank may also trade various securities on its own account.

Securities portfolio management

The bank provides the service of managing a securities portfolio consisting of funds traded on the stock exchange to all private clients in Roboinvestor, which is part of the SEB mobile application. Similar to robo-advice, it is an automatic solution where the communication takes place in a mobile application without direct communication with a bank employee, and the information and documents necessary to receive the service are available to the client through the mobile application. The signed documents are submitted to the customer's internet bank, and the customer can monitor his securities portfolio in the mobile application, and more detailed information is available in the internet bank.

In addition, the bank provides securities portfolio management services to private banking customers, i.e. customers whose investment assets are larger than average.

You can find out about private banking services and contact information on the private banking website.

Investment advice

The customer executives and private banking customer executives of the Bank provide an advisory service to customers, one part of which is investment advice. A virtual advisory service is also offered to private customers as an automated solution through the Robo-Advisor mobile application, which is part of the Internet Bank of the Bank. The virtual advisory service does not involve direct interaction with a bank employee and the documents and information needed to complete the session are available to the customer via the mobile application. During the provision of the virtual advisory service for the funds, a limited number of investment opportunities offered by companies belonging to the same group as the Bank are used.

The investment advice will result in a personal recommendation to the customer regarding a securities transaction. The bank will provide investment advice to the customer if this is explicitly agreed.

In order to determine the investment services and products that are suitable for the customer, the circumstances of each customer are assessed individually during the provision of investment advice (suitability assessment). The investment services and products must be appropriate to the investment objectives, risk tolerance, loss tolerance, financial capability, and investment knowledge and experience of the customer as well as other circumstances relating to them. (Including client initial or adapted sustainability preference).

All investment advice is based on the information provided by the customer to the Bank in the course of the provision of investment advice. Therefore, it is of the utmost importance that the customer provides the Bank with accurate and up-to-date information.

The investment advice results in a document issued to the customer on paper or electronically (to the Internet Bank of SEB or by email), containing a suitability assessment and a personal recommendation on investment products.

Bank offers a suitability reassessment only for portfolio management service.

It is important to keep the details of the customer up to date during the suitability reassessment.

• The Bank then assesses whether the investment product(s) that it recommended to the customer at the previous advice session and for which the customer made a transaction is (are) still suitable for the customer.
• As a result of the suitability reassessment process, a suitability assessment is issued to the customer.

If the customer also wishes to receive further investment advice, the Bank will issue a new personal recommendation to the customer following the provision of further advice.

The customer will be required to undergo a new suitability assessment if there is a change in their investment objectives, risk tolerance, loss tolerance, financial capability, investment knowledge or experience, or other circumstances relating to them. If you are interested in the advisory services of SEB (including investment advice) to find the best solution for you together with the experienced specialists of the Bank or if you would like to have an investment recommended by the Bank re-assessed, or if you have any questions during the use of the Robo-Advisor, please register for a consultation. The terms and conditions under which the Bank provides advisory services (including investment advice) can be found under the terms and conditions of products and services.

Management of securities portfolios

The Bank offers a portfolio management service consisting of exchange-traded funds to all private customers via the Robo-Advisor mobile application. Similar to the virtual advisory service, this is an automated solution where communication takes place in the mobile application without the need to interact directly with a bank employee, and the information and documents required to access the service are available to the customer via the mobile application. Signed documents are submitted to the Internet Bank of the customer, and the customer can monitor their securities portfolio in the mobile application, with more detailed information available in the Internet Bank.

In addition, the Bank provides a portfolio management service to private banking customers, i.e. customers with an above-average amount of investable assets.

For private banking services and contact details, please visit the private banking website.

Important additional information

Before using the services of SEB and executing transactions with investment products offered via SEB, the customer must carefully read the terms and conditions, features, and risks of the specific service or product. In case of any questions, you should contact the customer service representative of the Bank or your tax, financial, or legal advisor.

In the case of investment services and products, the customer must understand, among other things, the following.

• The customer must refrain from activities considered as market abuse. Market abuse is unlawful behaviour in financial markets, such as insider dealing, unlawful disclosure of insider information and market manipulation or attempted market manipulation. Market manipulation is an activity that interferes with the price-formation process of financial instruments. For example, artificial transactions that have no economic value and the purpose of which may be to create the false impression of market activity, such as increased interest in buying or selling a financial instrument, when in fact there is none. Market abuse is in more detailed described in Article 12 and Annex I of the European Parliament and of the Council Regulation (EU) No. 596/2014 on Market Abuse.
• Investments are made in securities and positions in securities are held at the own risk of the customer.
• The return on securities and investment products is generally not guaranteed and the price may decrease as well as increase.
• It is important for the customer to thoroughly understand the terms and conditions of the Bank that govern investment services and products.
• The customer should carefully read the transaction confirmation provided for the transaction. In doing so, the customer must inform the Bank immediately of any errors.
• The customer must monitor their securities investments on an ongoing basis.
• The customer must take measures to minimise the risk of loss on the investment and other positions actively and on their own initiative.
• The rights related to foreign securities and funds may differ from those provided for in the local legislation governing such securities and funds.
• The depository, settlement system, or administrator used to hold customer securities or money may have a right of security, right of retention, or right of set-off over customer assets where permitted by the relevant national law.

During the provision of investment and ancillary investment services clients deposit their securities and money on accounts administered by SEB or on accounts administered through SEB by other account administrators (i.e. on nominee accounts). In the depositing and safeguarding of clients’ assets SEB adheres to the requirements established in legislation and terms and conditions agreed on with the client. When providing the investment and ancillary investment services SEB follows the rules of protecting and safeguarding the clients' assets.

The terms and conditions of securities account and transactions.

You can review the terms and conditions of securities account also at a bank office.

Upon depositing the securities and conducting the transactions in foreign countries and through nominee accounts, the regulations, different technical solutions, rules established by local market participants and market practice in relevant countries must be taken into account.

Circumstances of depositing securities through account administrators of foreign countries.

Each client and investor must definitely take account of the related risks.

Possible conflicts of interest.

SEB classifies all clients to whom investment services, or ancillary investment services are provided as retail clients, professional clients and eligible counterparties. The following explains the classification of clients and the meaning of the classification.

Client categories and principles of classification

The extent of investor protection is defined for each client by classifying the client in one of the following manners:

• retail client;
• professional client;
• eligible counterparty.

A retail client is a client who may not have sufficient knowledge, experience, or proficiency to make investment decisions and adequately assess the risks involved on their own (for example, a private person, a small business, a local government unit, etc.). Consequently, retail clients are offered the highest level of investor protection. The obligation to provide information regarding SEB and the investment products and services and securities offered by them is the most extensive in the case of retail clients.

A retail client may request to be classified as a professional client if they believe that they have the necessary expertise, level of experience and knowledge, and, during the transaction or service performed, it becomes evident that the client is able to make investment decisions and understand the risks involved. SEB is obliged to assess the given circumstances and, upon the assessment, SEB must take the nature of the planned trades or services into account. Furthermore, during the assessment, at least two of the following conditions must have been met:

• the client has carried out on average at least 10 transactions of significant size on the securities market per quarter over the previous four quarters;
• the volume of the client’s securities portfolio exceeds 500,000 euros;
• the client (or, in the case of a legal person, a client representative) works or has worked for at least one year in the field of finance at a position which requires knowledge about the planned transactions or services.

Professional clients are presumed to have more extensive knowledge and experience in investment products and services to make investment decisions on their own and adequately assess the risks involved. In the provision of investment services and ancillary services, all the general obligations that SEB owes to a regular client are also owed to a professional client, but compared to regular clients, the level of evaluation and investor protection applied is not as comprehensive.

Generally, a professional client is a legal person who meets at least two of the following conditions:

• their balance sheet equals at least 20 million euros;
• their net turnover equals at least 40 million euros;
• their equity capital equals at least 2 million euros.

SEB also considers the following persons professional clients:

• an Estonian or foreign credit institution, investment company, management company, investment fund, insurer, or other financing institution subject to financial supervision;
• the Republic of Estonia or a foreign country or a regional government unit (but not a local government unit) or the central bank of Estonia or a foreign country;
• an international organisation, incl. the International Monetary Fund, European Central Bank, European Investment Bank;
• an Estonian of foreign financial institution whose sole business is investing in securities;
• a trader of commodities and commodity derivatives on the market (for example, a broker).

Clients who do not correspond to the aforementioned conditions are generally considered retail clients by SEB, but under some of the conditions described above, a retail client may request to be regarded as a professional client.

A professional client may request to be treated as a retail client if, according to the client, they are not able to sufficiently assess or manage the risks relating to the services and trades. In such an event, SEB does not presume in the case of such a client as high level of awareness of the securities market as in the case of a professional client. Professional clients are responsible for keeping SEB informed about any change which could affect their treatment as a professional client. If SEB becomes aware that the circumstances related to the client have changed and the classification of the client as a professional client is no longer relevant, SEB shall apply the provisions of retail clients to the client according to the changed circumstances.

In the case of certain investment services (i.e. upon the receipt and forwarding of orders related to securities and upon the execution of orders on the client’s behalf and account), SEB may treat certain clients as an eligible counterparty. In the case of such clients, investor protection arising from legislation is the lowest. Such clients are presumed to have competence equal to that of SEB. Consequently, SEB does not need to acquire from its clients information about their knowledge or experience related to their investment and ancillary investment services and about the aims and circumstances related to such services, or present information about the securities and the planned investment strategy or provide guidelines and warnings related to risks. SEB will, however, remain honest, fair, and professional towards eligible counterparties and facilitate fair, clear, and non misleading communication.

Reclassification
A client may also request to be regarded as a client belonging into a different category. If reclassification means that the extent of investor protection applicable to the client is reduced (e.g. when a retail client is reclassified as a professional client), SEB will assess the aforementioned circumstances in the case of the client. However, if reclassification means an increase in investor protection (e.g. classification of a professional client as a retail client), then SEB will assess the risks and consequences of the reclassification for SEB.

Retail clients may request to be treated as professional clients, and vice versa. Professional clients may request to be treated as eligible counterparties and eligible counterparties may request to be treated as professional clients or retail clients. An application for the amendment of client classification must be submitted to the client service assistant.

Explanations about the rights that the clients may forfeit if they choose the client classification providing less investor protection (PDF).