The Manager has put in place a remuneration policy (the “Remuneration Policy”) that is in accordance with the requirements of SYSC 19 E of the FCA. The Remuneration Policy is designed to ensure that the Manager’s remuneration practices are consistent with and promote sound and effective risk management, do not encourage risk taking and are consistent with the risk profile of the Schemes. The Manager considers the Remuneration Policy to be appropriate to the size, internal operations, nature scale and complexity of the Schemes and in line with the risk profile, risk appetite and the strategy of the Schemes.
The matters covered by the Remuneration Policy include:
• An assessment of the individual member of staff’s performance;
• restrictions on the awarding of guaranteed variable remuneration;
• the balance between fixed and variable remuneration;
• any payment of remuneration in the form of units or shares in the Schemes;
• any mandatory deferral periods for the payment of some or all of the variable remuneration component;
• the reduction or cancellation of remuneration in the case of underperformance.
The Remuneration Policy will apply to the fixed and variable (if any) remuneration received by the identified staff.
In respect of any investment management delegates, the Manager requires that:(i) the entities to which such activities have been delegated are subject to regulatory requirements on remuneration that are equally as effective as those applicable under the European Securities and Market’s (ESMA’s) Guidelines on Sound Remuneration Policies under the UCITS Directive and AIFMD / Article 14 of the UCITS Directive; or (ii) appropriate contractual arrangements are put in place with entities to which such activities have been delegated in order to ensure that there is no circumvention of the remuneration rules set out in the ESMA Guidelines or the FCA Handbook.