Remuneration Policy

The remuneration policy of the Company applies to all staff.

The Board of Directors has adopted the remuneration policy in order to comply with the regulatory and legislative framework.

The policy reflects the Company’s objectives and ensures that:

• 1. the Company is able to attract, develop and retain high-performing and motivated employees in a competitive local market;
• 2. employees are offered a competitive and market aligned remuneration package;
• 3. employees feel encouraged to create sustainable results;
• 4. is consistent with and promotes sound and effective risk management and does not encourage risk-taking which is inconsistent with the risk profiles, rules or instruments of incorporation of the managed UCITSs;
• 5. is in line with the business strategy, objectives, values and interests of the Company and the managed UCITSs or the investors of such UCITSs, and includes measures to avoid conflicts of interest.

The Board is responsible for the review and control of compliance with the Remuneration Policy.

If necessary, considering changes or development within the business of the Company, the Board implements adjustments to the Remuneration Policy.

The Board also assesses whether the incentive structure is aligned with the Company´s risks, capital and liquidity and the Board further evaluates the probability and timing of the remuneration. The Board has decided not to award variable performance based remuneration to discourage risk-taking that is inconsistent with the managed UCITS or other clients’ risk profile.

APPRAISALS

An appraisal interview shall be conducted annually, where the individual employees and managers evaluate and document performance during the current year and set new goals. Decisions on adjustment of the employee’s fixed salary are made on the basis of this appraisal.

The various remuneration components are combined to ensure an appropriate and balanced remuneration package.

The remuneration components are:

• fixed remuneration (including fixed supplements);
• health care insurance.

The fixed remuneration is determined on the basis of the role and position of the individual employee, including professional experience, responsibility, job complexity and local market conditions.

The Company may decide to provide fixed supplements to the salary of the employees taking into account many factors, among others:

• employee-related qualities such as employee’s contribution, the “extra mile” to advance and excel, ability to take initiatives and “read between the lines”, cooperative spirit, trustworthiness, loyalty, high level of ethical and professional standards;
• overall market conditions, i.e. long term performance of the company;
• inflation.

Employees’ salaries may be reviewed annually without necessarily resulting in an increase.  Other benefits are awarded on the basis of individual employment contracts and local market practice.