The Remuneration Policy provides a clear direction and policy regarding the Company’s remuneration structure and practices consistent with the principles in the UCITS Regulations and CRD IV. While the general provisions apply to all employees, some elements of the policy are applicable only to certain identified staff.
The Board of Directors recognise the importance of the role played by sound risk management in protecting its stakeholders. Moreover, the Board acknowledges that inappropriate remuneration structures could, in certain circumstances, result in situations whereby individuals assume more risk than necessary.
The Policy takes into account the nature, scale and complexity of its business; the type of Client, the type of investments, the investment strategies, the investment location, the distribution model and investor base. Due consideration is also given to the resources available within the Company and the resources and expertise of the various third parties engaged to support the company and carry out certain functions in its behalf.
Although there is no Remuneration Committee in place, it is important to note that the ultimate responsibility for the oversight of compliance with this Remuneration Policy ultimately rests with Board of Directors.
The key areas of the Policy seek to identify individuals whose professional activities have a material impact on the risk profiles of the Company and the clients it manages including: i) Board of Directors of the Company; ii) Senior Management and iii) Portfolio Managers. Other staff that are considered risk takers whereby all staff members whose professional activities either individually or collectively can exert material influence on the risk profiles of the Company or of a UCITS it manages. The Board approves the list of identified staff annually and individuals are notified of their identification and the implications of this status. It then takes into account the link between pay and performance for these individuals, which is based on a number of factors including but not limited to, the performance of the client, the overall results of the Company and the employee’s commitment to the team.
Remuneration in relation to sustainability risks
In accordance with the Company’s ESG Policy there are no incentives to engage in investments which pose sustainability risks.
The Policy also includes a detailed description of the types of remuneration, namely fixed and variable remuneration. Whereas the fixed remuneration is fairly straightforward, the Policy goes into detail on the variable remuneration, dedicating a section to the structure of the annual bonuses available to certain staff.
Due to the proportionality principal the Company does not adopt any deferral, equity measure. Guaranteed variable remuneration is granted only in exceptional cases to attract highly specialised individuals. In accordance with regulatory requirements such pay will be granted only in the case of hiring new staff and for a maximum period of one year.
|Remuneration type||Pay element||What It does||Key measures|
|Fixed||Base Salary||Provides competitive fixed pay||Experience, seniority, education, job complexity, duties and scope of responsibility.|
Internal and external market factors
|Variable||Annual Cash Bonus||Provides a competitive annual cash incentive opportunity to motivate and reward high performers||Based on annual financial results, individual conduct and performance as well as the company’s and the Client’s progress against long term strategy, strengthen long term customer relations and generate income and shareholder value to the Clients of the Company|