Corporate
Governance

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Policies

  • Best Execution & Order Handling
  • Remuneration
  • Conflict of Interests
  • Voting Rights
  • Complaints Handling

Best Execution & Order Handling

Lemanik Asset Management S.A. (the “Management Company”) adheres to the rules laid down in the UCITS and AIFM Directives and their implementing measures. In this context, the Management Company and its delegates have adopted a best execution policy whose aim is to ensure the fair and prompt execution of portfolio transactions on behalf of UCITS and instructions of its investors.

This policy can be obtained, on simple request, free of charge, via mail to:

Remuneration

<div class="popuptext"><div class="overflow"><p>The Management Company has established and applies a remuneration policy and practices that are consistent with, and promote, sound and effective risk management and that neither encourage risk taking which is inconsistent with the risk profiles, rules, this Prospectus or the Articles nor impair compliance with the Management Company’s obligation to act in the best interest of the Company (the Remuneration Policy).</p><p>The Remuneration Policy includes fixed and variable components of salaries and applies to those categories of staff, including senior management, risk takers, control functions and any employee receiving total remuneration that falls within the remuneration bracket of senior management and risk takers whose professional activities have a material impact on the risk profiles of the Management Company, the Company or the Sub-Funds.</p><p>The Executive Committee is in charge of determining the fixed and variable remunerations of employees. The variable remuneration is granted based on two main criteria: the financial benefit realised at each year end of the management company and the individual’s performance.</p><p>The Remuneration Policy is in line with the business strategy, objectives, values and interests of the Management Company, the Company and the Shareholders and includes measures to avoid conflicts of interest.</p><p>In particular, the Remuneration Policy will ensure that:</p><p>a) the staff engaged in control functions are compensated in accordance with the achievement of the objectives linked to their functions, independently of the performance of the business areas that they control;<br /><br />b) the 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, including the possibility to pay no variable remuneration component;<br /><br />c) the measurement of performance used to calculate variable remuneration components or pools of variable remuneration components includes a comprehensive adjustment mechanism to integrate all relevant types of current and future risks;</p><p>In context of delegation, the Remuneration Policy will ensure that the Delegate comply with the following:</p><p>a) the assessment of performance is set in a multi-year framework appropriate to the holding period recommended to the investors of the Company in order to ensure that the assessment process is based on the longer-term performance of the Company and its investment risks and that the actual payment of performance-based components of remuneration is spread over the same period;<br /><br />b) if at any point of time, the management of the Company were to account for 50 % or more of the total portfolio managed by the Delegate, at least 50 % of any variable remuneration component will have to consist of Shares, equivalent ownership interests, or share-linked instruments or equivalent non-cash instruments with equally effective incentives as any of the instruments referred to in this item (e); and<br /><br />c) a substantial portion, and in any event at least 40 % of the variable remuneration component, is deferred over a period which is appropriate in view of the holding period recommended to the Shareholders and is correctly aligned with the nature of the risks of the Company.</p><p>A paper copy of the Remuneration Policy is available free of charge to the Shareholders upon request.</p></div></div>

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This policy can be obtained, on simple request, free of charge, via mail to:

Conflict of
Interests

We are structured and organized so as to limit as far as possible the risk of conflicts of interest between:

  • the Company
  • the related parties of the Company
  • the UCIs under management of the Company
  • the unitholders of the UCIs under management of the Company.

In accordance with its rules of conduct, the Company endeavours at all times to remove any potential conflicts of interest and, when such conflicts are unavoidable, will ensure that the UCI and investors are treated equitably.

This policy can be obtained, on simple request, free of charge, via mail to:

Voting Rights

Lemanik Asset Management S.A. (the “Management Company”) adheres to the rules laid down in the UCITS and AIFM Directives and their implementing measures. The Management Company has adopted a policy with defined Key Principles regarding the exercise of voting rights attached to the financial instruments held by the funds under management.

This policy can be obtained, on simple request, free of charge, via mail to:

Complaints
Handling

<div class="popuptext"><div class="overflow"><p>Lemanik Asset Management S.A. (the &ldquo;Management Company&rdquo;) is subject to the supervision of the Commission de Surveillance du Secteur Financier (&ldquo;CSSF&rdquo;). The Management Company has adopted a Complaint Handling policy for managing investor complaints in an effective manner.</p><p>Investors may file complaints free of charge in the official language or one of the official languages of their Member State.</p><p>Any complaint shall be sent to the attention of the Complaint Handling Officer of the Management Company at:</p><p>Lemanik Asset Management S.A.<br />106 route d&rsquo;Arlon<br />L-8210 Mamer<br />Grand Duchy of Luxembourg<br /><br />Email: <a href="mailto:[email protected]">[email protected] </a></p><p>The following steps will be taken by the Complaint Handling Officer upon receipt of an investor&rsquo;s complaint:</p><p>- An acknowledgment letter will be sent to the investor within ten business days after receipt of the complaint where the complaint cannot be closed within these ten business days.<br />- The investor will be informed of the name of the person handling the complaint.<br />- An answer will be provided to the investor without undue delay. It must be handled within a period which will not exceed one month between the date of receipt of the complaint and the date at which the answer is sent. When an answer cannot be provided by the Complaint Handling Officer within this period, the Complaint Handling Officer informs the investor of the causes of delay and indicate a timeframe for resolution.</p><p>The Management Company informs the investors of the existence of the out-of-court dispute settlement procedure with the Commission de Surveillance du Secteur Financier (the &ldquo;CSSF&rdquo;).</p><p>This out-of-court resolution applies where the complainant did not receive a response or satisfactory response within one month of a complaint being submitted to the Management Company. In this case, the complainant can refer to the CSSF by the following means:</p><p>- Either by post to the CSSF, 110 route d&rsquo;Arlon, L-2991 Luxembourg<br />- Or by e-mail at <a href="mailto:[email protected]">[email protected]</a></div></div>

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This policy can be obtained, on simple request, free of charge, via mail to:

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