The objective of this remuneration policy is to attract, motivate and retain employees in the long term, while ensuring an appropriate management of risks and compliance.

The Fund’s policy is to compensate employees in a manner that does not encourage excessive risktaking by employees, but on the contrary, promotes sound and effective risk management, consistent with the risk profiles of the assets managed by the Fund. The Fund’s Board of Directors (“Board of Directors”) shall be responsible for approving and maintaining this policy, and overseeing its implementation. This policy shall be reviewed on an annual basis to confirm that it operates as intended and is compliant with national and international regulations, principles and standards.

Compensation of Fund employees shall be decided by the Board of Directors in a manner consistent with the promotion of effective risk management and avoidance of conflicts of interest. The Board of Directors meets regularly to evaluate the performance of the Fund, which includes the performance of the Fund’s employees. Performance of individuals within control functions such as compliance, risk, finance and HR, shall be assessed against objectives based on the performance of the individual in their functional role and is independent of the results of any revenue generating business unit. The Board of Directors shall take into account the inputs received by all competent corporate functions when making remuneration decisions.

Fixed and variable remuneration shall be paid primarily in cash, except that the most senior investment personnel may be allocated a portion of their remuneration in shares or equity interests in an affiliated company that vest over a period of time, generally five years. Fixed remuneration shall be sufficiently high to remunerate the professional services rendered in accordance with market standards, in line with relevant business experience, education and job requirements. Variable remuneration shall be based on performance, including the risk management and compliance inputs described above, and risk adjusted over the relevant accrual period as determined appropriate by the Board of Directors. Variable remuneration shall also generally be subject to a malus clause in case of misconduct. The determination of the fixed and variable components should take into account market practice. The Board of Directors shall ensure that the pool of variable remuneration for any given year shall not adversely affect the financial situation of the Fund.

The Board of Directors shall evaluate the remuneration policy of any delegates to ensure that it has been established and applied in accordance with the requirements of the 2010 law and the ESMA Guidelines on sound remuneration policies under the UCITS Directive and AIFMD, including with respect to principles of proportionality, and ensures that there is no circumvention of the Fund’s own remuneration policy.

  • When establishing and applying its remuneration policy, the Fund shall comply with the requirements of the 2010 Law and specifically with the following principles:
  • The remuneration policy 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 Fund;
  • The remuneration policy is in line with the business strategy, objectives, values and interests of the Fund and of the investors in the Fund, and includes measures to avoid conflicts of interest;
  • The assessment of performance is set in a multi‐year framework appropriate to the holding period recommended to the investors of the Fund in order to ensure that the assessment process is based on the longer‐term performance of the Fund and its investment risks and that the actual payment of performance‐based components of remuneration is spread over the same period

Fixed and variable components of total remuneration are appropriately balanced and the fixed component represents a sufficiently high proportion of the total remuneration to allow the operation of a fully flexible policy on variable remuneration components in accordance with market standards, including the possibility to pay no variable remuneration component under appropriate circumstances.

The details of the up‐to‐date remuneration policy, including a description of how remuneration and benefits are calculated are available on the following website: A paper copy of this up‐to‐date remuneration policy will be made available free of charge upon request at the registered office of the Fund at 28‐32, Place de la gare, L1616 Luxembourg.