Investment Fund Services Limited (the Company ) The Remuneration Policy (the Policy ) Policy Document

Similar documents
Bridge Fund Management Limited

DMS Investment Management Services (Europe) Limited (the Manco )

Aberdeen believes that rewarding staff for their contribution is key to recruiting and retaining a talented workforce.

KBA Consulting Management Limited (the Company)

UCITS V: Remuneration Factsheet

Beresford Funds plc Remuneration Policy. Version:

ALTERNATIVE INVESTMENT FUND MANAGEMENT DIRECTIVE (AIFMD)

INDEPENDENT FRANCHISE PARTNERS VARIABLE CAPITAL COMPANY PLC. (the "Fund") UCITS V Remuneration Policy

1. Introduction and interpretation. 2

trust transparency tenacity teamwork

Senior Management Arrangements, Systems and Contro. Chapter 19B. AIFM Remuneration Code

The Alternative Investment Fund Managers Directive What you need to know

DOCUMENT FOR EXTERNAL PUBLICATION. Remuneration Policy. FundPartner Solutions (Europe) S.A. Luxembourg March 2016

UCITS V and VI preparing for the new rules, and beyond

Alternative Investment Fund Managers Directive (AIFMD) Remuneration Disclosure AIF Annual Report and Accounts Aberdeen Latin American Income Fund

Direction. 5. In the table below, underlining indicates new text and striking through indicates deleted text.

Remuneration Policy. Version No 6 Total Pages No 19. Author: Compliance Function Issue date: December, / v4

UK Authorised Investment Funds

AIFMD. Fundamental considerations to be addressed at a strategic level for marketing in the EU:

UCITS & AIFMD Remuneration Policy as at 23rd October NGAM S.A. (Luxembourg) and its branches (the NGAM SA Remuneration Policy ) 1.

Alternative Investment Fund Managers Directive

Prospectus. IFSL Brooks Macdonald Fund

IFSL Tilney Bestinvest Multi Asset Portfolio Series II

Marlborough European Multi-Cap Fund Class A Units

CIG Fund Management Company Limited Remuneration Policy

Navigating the markets. Multi-asset funds

Guidance. Notes The Alternative Investment Fund Managers ("AIFM") Gibraltar Remuneration Code

Information page Alternative Investment Fund Managers Directive Operating conditions Conflicts of interest

FWU INVEST S.A. Remuneration Policy

Marlborough Multi Cap Income Fund Class A Shares

FIDANTE PARTNERS EUROPE LIMITED. Pillar III Disclosure. 30 June 2017

Pillar 3 Risk Disclosure Statement AS OF DECEMBER 2016

November Page 1

Vontobel Asset Management S.A. Remuneration Policy. Contents. Last Update 30 November Valid as of 1 July 2011

ICAAP Pillar 3 Disclosure

The impact of MiFID II on AIFMD investment managers

IFSL Tilney Bestinvest Multi Asset Portfolio

Pillar 3 Disclosures as at 31 st December 2017

The Regulation of Remuneration: Where are we now with the Remuneration Codes?

EOS INVESTMENT MANAGEMENT LIMITED. Best Execution Policy

AIFM toolbox. AIFM toolbox - May Updated version

Asset Management Director PwC Year-end accounting update. January 2017

Objectives and Investment Policy. Risk and Reward Profile. invested back into the fund and reflected in the price of your units.

AIFMD Hot Topics: Contractual Discharge, Valuation, Remuneration and Private Equity

Marks and Spencer Unit Trust Management Limited. Remuneration: strategy, principles and governance

Collective Investment Schemes. Chapter 4. Investor Relations

F&C Capital and Income Investment Trust PLC

UCITS V: Who needs to do what by when?

REMUNERATION POLICY. November 2017

Pillar 3 Disclosures. 31 December 2013

Deciphering the Remuneration Codes

EFAMA Response to ESMA s Consultation Paper on Guidelines on sound remuneration policies under the AIFMD

Investment Funds sourcebook. Chapter 10. Operating on a cross-border basis

A GUIDE TO ESTABLISHING AN ALTERNATIVE INVESTMENT FUND MANAGER IN MALTA

Featuring contributions from Afme Allen & Overy Asifma Bonn Steichen & Partners Cuatrecasas Elias Neocleous & Co Fellner Wratzfeld & Partners

ESMA Publishes Consultation on UCITS Remuneration Guidelines

the amended text inserted by the CRA III Directive 2013/14/EU, which came into force on 20 June 2013;

MONEY MARKET FUNDS REGULATION INSTRUMENT 2018

EUROPEAN UNION. Brussels, 13 May 2011 (OR. en) 2009/0064 (COD) PE-CONS 60/10 EF 181 ECOFIN 738 CODEC 1293

ESMA Publishes Final UCITS Remuneration Guidelines

AIFMD Initial Guidance And Advice For The Sub-Threshold AIFM

ODEY EUROPEAN INC. Annual Report and Audited Financial Statements For the year ended 31 st December Management and Administration 3

The Affirmative Deposit Fund for Charities

Valu-Trac Investment Management Limited Pillar 3 Disclosure

Senior arrangements, Systems and Controls. Chapter 8. Outsourcing

DEVELOPMENTS INVESTMENT FUNDS

LEGAL ALERT (THE LAW ) JUNE

EU Commission s Proposed Prudential Regime for Investment Firms

IMPLEMENTATION OF THE AIFMD IN THE UK

AIFMD: What it is and what to do.

March 23, ESMA Discussion Paper Key concepts of the Alternative Investment Fund Managers Directive and types of AIFM (23 February 2012)

Investment Funds sourcebook. Chapter 10. Operating on a cross-border basis

AMF Position Frequently asked questions on the transposition of the AIFM Directive into French law

Quality of Execution Annual Report

Governance under AIFMD

Wells Fargo Asset Management Luxembourg S.A. Société anonyme 19, rue de Bitbourg L-1273 Luxembourg R.C.S. Luxembourg B192268

AIFMD The First 3 Years and What Non-EU Fund Managers Need to Know

Danske Bank Group's Remuneration Policy, March 2014

Information page Alternative Investment Fund Managers Directive Operating conditions - General

EuVECA Regulation.

Investment Funds sourcebook

The European Long-Term Investment Fund ("ELTIF") Regulation in a nutshell

The importance of Risk Management under AIFMD. Nordic Capital Markets Forum

BlueBay Asset Management LLP Remuneration Policy


Senior arrangements, Systems and Controls. Chapter 10. Conflicts of interest

A7-0171/22 AMENDMENTS BY PARLIAMENT * to the Commission proposal for a

AMF Instruction Procedure for marketing units or shares of AIFs DOC

Pillar 3 disclosures 3I GROUP PLC. As at 31 March 2018

Senior Management Arrangements, Systems and Contro. Chapter 21. Risk control: additional guidance

The Alternative Investment Fund Managers Directive. Key features & focus on third countries

A Guide to the Implications of the Alternative Investment Fund Managers Directive (AIFMD) for Annual Reports of Alternative Investment Funds (AIFs)

BANK SEPAH INTERNATIONAL plc PILLAR 3 DISCLOSURES (including Remuneration Code disclosures) As at 31 March 2017

EUROPEAN UNION. Brussels, 23 July 2014 (OR. en) 2012/0168 (COD) LEX 1569 PE-CONS 75/1/14 REV 1 EF 84 ECOFIN 270 CODEC 808

Consultation Paper CP12/32. Financial Services Authority. Implementation of the Alternative Investment Fund Managers Directive.

Asset Management Market Study Interim Report: Annex 2 Recent regulatory developments

ALTERNATIVE INVESTMENT FUND MANAGERS DIRECTIVE FREQUENTLY ASKED QUESTIONS

AIFMD - The Depositary

Preparing for PRIIPs. September 2016

Pillar 3 Disclosure November 2016

Transcription:

Investment Fund Services Limited (the Company ) The Remuneration Policy (the Policy ) Policy Document Document name: Investment Fund Services Limited Remuneration Policy Version: Final v1.0 Effective date: 01 March 2018

Definitions Meaning AFM ACD AIF AIFM ESMA FCA IFSL Investment Manager NURS SYSC UCITS Authorised Fund Manager Authorised Corporate Director Alternative Investment Fund Alternative Investment Fund Manager European Securities and Markets Authority Financial Conduct Authority Investment Fund Services Limited Investment Fund Services Limited, or any other person or persons being duly appointed investment manager of the Company in succession to Investment Fund Services Limited, in accordance with the requirements of the FCA, and where the Investment Manager has delegated responsibility for the management of all or part of the assets of a fund of the Company, the term Investment Manager shall also refer to the investment manager of that fund. Non-UCITS retail investment scheme Senior Management Arrangements, Systems and Controls Undertaking for Collective Investment in Transferable Securities

1. Introduction The Remuneration Policy ( Policy ) records the remuneration policy for Investment Fund Services Limited ( IFSL ). IFSL provides investment management services, including; acting as an AFM and an Investment Manager, for both UCITS and NURS. IFSL is authorised and regulated by the FCA in the control of such business. The Company has adopted a remuneration policy in accordance with the requirements of both the UCITS Directive (Directive 2014/91/EU of 23 July 2014) and the AIMF Directive (Directive 2011/61/EU of 8 June 2011) and is subject to the Remuneration Codes set out by ESMA and in Chapters 19B and 19E of the FCA s SYSC Handbook. The Company s Policy also complies with the Investment Association s Principles of Remuneration. The Policy is designed to ensure that the Company s remuneration practices; are consistent with and promote sound and effective risk management, don t encourage risk taking which is inconsistent with the risk profile and prospectuses of the Company s Funds, don t impair its duty to act in the interest of the Funds, and include measures to avoid conflicts of interest. The Company considers the Policy to be appropriate to the size, internal operations, nature, scale and complexity of the Funds it manages and in line with the risk profile, risk appetite and the strategy of those Funds. 2. Remuneration code staff The Policy will apply to the fixed and variable (if any) remuneration, including salaries and pension benefits received by the identified remuneration code staff. The identified remuneration code staff are those whose professional activities have a material impact on the risk profile of the AFM, AIFM and the Funds, including but not limited to; senior management 1, risk takers, staff engaged in control functions, and any employee receiving total remuneration that takes them into the same remuneration bracket as senior management and risk takers and whose professional activities have a material impact on the Company s risk profile. in the context of remuneration code staff, this applies to those managers assessed as having a material impact on the Company s risk profile 3. The Remuneration Committee (the Committee ) The Committee has been appointed by the Company s Board of Directors and is responsible for awarding the remuneration for remuneration code staff.

4. Fixed and variable remuneration The structure of remuneration for remuneration code staff is designed to be in line with the Company s business strategy, taking account of any conflicts of interest and the existing and future capital requirements of the business. It typically consists of fixed pay and variable remuneration, potentially consisting of an annual bonus and long term incentives. Remuneration is based on, but not limited to; an appropriate balance between fixed and variable remuneration, including the possibility of paying no variable remuneration, fixed remuneration, based on market rates and the experience and skill of the individual, variable remuneration that is discretionary and involves assessment of the performance of the individual, the financial performance of the Company, the performance of the Company s Funds, the performance of the business unit and its risks, individual performance assessment will not solely relate to financial criteria but will also include compliance with regulatory obligations, adherence to effective risk management, adherence to the Company s Code of Conduct, and adherence to the Company s business principles and policies, the measure of the Company s financial performance is based principally on net profits and not revenue or turnover, long term variable incentives are aligned to the Company s strategic objectives, and the reduction or cancellation of any variable remuneration in the case of an individual s underperformance. 5. Pension The Company operates a self-invested personal pension scheme and contributions are set at an appropriate level to attract and retain high performing people. The Company doesn t offer any discretionary pension benefits. 6. Conflicts of interest Conflicts of interest involve a failure by the Company to act in the best interests of its clients and a material risk of damage to the interests of those clients. To ensure that individuals act in a fair manner, the Company has procedures in place to reduce conflicts and manage risks. The management of potential remuneration conflicts includes: Any assessment for awarding financial remuneration, other benefits and career progression is clearly linked to performance criteria that encourages staff to act in the best interests of clients. Remuneration awards that aren t solely linked to sales. Clear structural segregation of business functions is in place to allow for their independent running and this is reflected in the composition of the Management Board. The Remuneration Committee provides independent recommendations on remuneration. The Company regularly reviews potential and actual conflicts and maintains an up to date conflicts of interest register.

7. Delegation In respect of any investment management delegates, the Company requires, under the ESMA guidance on remuneration of AIFs and UCITS, that the delegated entities; (i) (ii) are subject to regulatory requirements on remuneration that are equally as effective as those applicable to the Company; or must have appropriate contractual arrangements in place to ensure that there is no circumvention of the remuneration rules set out in the ESMA Guidelines or the FCA Handbook. 8. Annual review On an annual basis the Company will review the terms of this Policy and assess whether the overall remuneration system operates as intended and is compliant with their obligations on remuneration. This Policy will be updated as and when required. Investment Fund Services Limited. Registered in England No. 06110770. Registered Office Marlborough House, 59 Chorley New Road, Bolton, BL1 4QP Telephone: 0808 178 9321 Fax: 01204 533045 Email: enquiries@ifslfunds.com Website: www.ifslfunds.com Authorised and regulated by the Financial Conduct Authority and a member of The Investment Association