The remuneration policy of the Company applies to all categories of staff, including senior management, risk takers, control functions and any employees receiving total remuneration that takes them into the same remuneration bracket as senior management and those risk takers, whose professional activities have a material impact on the risk profiles of the managed UCITS/AIFs to all employees.
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:
- the Company is able to attract, develop and retain high-performing and motivated employees in a competitive local market;
- employees are offered a competitive and market aligned remuneration package making fixed salaries a significant remuneration component;
- employees feel encouraged to create sustainable results;
- 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 UCITS/AIFs;
- is in line with the business strategy, objectives, values and interests of the Company and the managed UCITS/AIFs or the investors of such UCITS/AIFs, and includes measures to avoid conflicts of interest;
The Board has set guidelines 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 determines the performance based remuneration of each employee.
An appraisal interview shall be conducted annually, where the individual employees and managers evaluate and document performance in the past year and set new goals. Decisions on adjustment of the employee’s fixed salary or on annual performance-based 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);
- performance-based remuneration (variable salary);
- provident fund contributions;
- other benefits.
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 performance-based remuneration motivates and rewards high performers who significantly contribute to sustainable results, perform according to set expectations for the individual in question, strengthen long-term customer relations, and generate income and value to the Company.
The Board has determined a maximum percentage of performance-based remuneration relative to the fixed remuneration. The maximum limit on variable remuneration remains at 50 per cent of fixed salary inclusive of provident fund contributions. The limit will be reduced if required by applicable legislation.
Performance based remuneration shall be disbursed solely as cash bonus. Bonuses are offered in order to offer competitive remuneration packages, however, always ensuring alignment of the interests of the employees, the Company, and the managed UCITS/AIFs. Performance-based remuneration is offered as a range, where the actual remuneration will be determined based on the employee’s appraisal.
Provident fund contributions provide all employees with a defined contribution pension plan. The Company shall not grant discretionary pension benefits.
Other benefits are awarded on the basis of individual employment contracts and local market practice.
Performance-based remuneration is awarded in a manner which promotes sound risk management and does not encourage excessive risk-taking. In this respect the Company shall not award any performance-based remuneration which is linked to the performance of managed UCITS/AIFs.
For material risk takers, a performance-based remuneration is conditional upon the employee not having been responsible for or having taken part in conduct resulting in significant losses for the Company and the managed UCITS/AIFs, and that the employee has proven to be fit and proper.
Concerning all employees, performance-based remuneration is subject to claw back provisions if granted on the basis of data which has subsequently proven to be manifestly misstated or inaccurate.
Further, performance-based pay is awarded by ensuring:
- an appropriate balance between fixed and performance-based components;
- that the fixed component represents a sufficiently high proportion of the total remuneration to make non-payment of the performance-based component possible.
Performance-based remuneration must be based on an assessment of the Company’s results and a number of KPIs reflecting the Company’s strategic key priorities.
The KPIs cover the following:
- profit before tax;
- client satisfaction;
- compliance with internal procedures;
- management skills;
- personal effectiveness;
- thinking skills;
- human relation skills.
Performance-based remuneration is offered as a range and the final disbursed amount is subject to the assessment of the employee, based on the abovementioned KPIs.
Performance-based remuneration is granted to reflect the Company’s financial results, the results of the function in which the employee is employed and the individual employee’s performance. As a minimum this applies to material risk takers. Further, both financial and non-financial factors shall be taken into consideration when determining the individual´s bonus, i.e. compliance with internal guidelines and procedures, including customers and investor related guidelines. A discretionary assessment is always made to ensure that other factors – including factors which are not directly measurable – are considered.
Performance-based pay is granted to employees with particular influence on the Company’s results. As an overall starting point the Company ensures a balanced split between fixed salary and variable pay.
Guaranteed variable remuneration is not granted to any employee.