Remuneration Policy

Nevastar Finance (Luxembourg) SA (the “Management Company”) has established a remuneration policy (the “Policy"), in the context of managing undertaking for collective investment on transferable securities (“UCITS”) and alternative investment funds (“AIFs”) (jointly hereafter referred to as the “Funds”), which sets out principles applicable to the remunerations of the senior management, all staff members having a material impact on the risk profile of the financial undertakings as well as all staff members carrying out independent control functions, whose objectives are:

  1. To ensure that the remuneration is in line with the applicable laws and regulations, and more specifically with the provisions defined under:
    • the CSSF Circular 10/437 on guidelines concerning the remuneration policies in the financial sector issued on 1st February 2010
    • the Alternative Investment Fund Managers Directive 2011/61/EU (“AIFMD”), transposed into the Luxembourg AIFM Law dated from 12 July 2013, as amended from time to time, the ESMA guidelines on sound remuneration policies under the AIFM published on 11 February 2013
    • the Directive 2013/36/EU of the European Parliament and of the Council of 26 June 2013 on access to the activity of credit institutions and the prudential supervision of credit institutions and investment firms (CRD IV)
    • the UCITS Directive 2014/91/EU (“UCITS V”), the ESMA consultation paper for the preparation guidelines on sound remuneration policies under the UCITS Directive and AIFMD published on 23 July 2015 (the “Guidelines”)
  2. to be in line with the business strategy, objectives, values and interests of the Management Company and the Funds it manages or the investors of such Funds
  3. not to encourage risk‐taking which is inconsistent with the risk profiles, rules or articles of incorporation or management regulations of the Funds the Management Company manages
  4. to avoid or manage conflicts of interest
  5. To ensure that the remuneration rules are not circumvented when delegating investment management functions (including risk management) under article 110 of the Law of 17 December 2010 for UCITS and under article 18 of the Law of 12 July 2013 for AIFs; in particular:
    • for entities subject to remuneration rules under CRD IV or AIFMD, the Management Company ensures that delegates are subject to regulatory requirements that are equally as effective as those applicable to the Management Company, i.e. (i) the entity is subject to remuneration rules under CRD IV or AIFMD and (ii) its staff qualifies as identified staff for the purpose of the remuneration rules applicable to the entity
    • for other entities, the Management Company ensures that entities which do not fall under the previous paragraph enter into an agreement with the Management Company to ensure that the remuneration rules applicable to the Management Company are not circumvented. To this effect the agreement will include a provision for any payment made to the entity’s identified staff as compensation for the performance of investment management activities on behalf of the Management Company

The Policy applies to all remuneration paid either by the Management Company or by the entities to which investment management functions have been delegated or by the Funds themselves.

The Policy also complies with the proportionality principle as provided by the Guidelines, and therefore has been conceived in a way and to an extent that it is appropriate to our size and internal organisation as well as the nature, scope and complexity of our activities.

The annual report shall disclose the aggregate remuneration paid according to UCITS V applicable rules and market practice.

In addition, it is possible to request additional information, free of charge, by writing to:

Nevastar Finance (Luxembourg) SA
36-38 Grand-Rue, L-1660 Luxembourg