Effective Date: March 2023
In compliance with the UCITS directive, we have established a remuneration policy that aligns with sound and effective risk management, discouraging risk-taking inconsistent with the risk profile or the Garrick and Crown fund’s constitution.
Our policy is aimed at rewarding individual contributions, demonstrated by the delivery of long-term sustainable results that align with the business and fund under management. It also adheres to the values and behaviors that serve the best interests of our clients and shareholders. By focusing on a combination of financial and non-financial targets and employing short and long-term incentive pay strategies, Garrick and Crown aims to attract, retain, and motivate our key talent.
We are committed to ensuring that this policy is designed to attract, motivate, retain, and reward employees regardless of gender, ethnicity, age, disability, or any other protected characteristic.
Governance
Garrick and Crown has reviewed the UCITS Directive requirement for establishing a Remuneration Committee, considering the size, internal organization, and the nature, scope, and complexity of activities. It has been determined that a committee is not required. The Policy will be reviewed at least annually, internally by an individual who does not perform any executive functions in the UCITS business and possesses expertise in risk management and remuneration. The board will review, update, and implement the policy as necessary. Any board members receiving remuneration directly or indirectly from the funds will not be allowed to have decision-making powers regarding variable remuneration to avoid conflicts of interest.
UCITS Remuneration Code Staff (‘Code Staff’)
Code Staff are individuals whose professional activities are deemed to have a material impact on the risk profiles of the management company or the funds it manages. These staff members include:
• Senior Management
• Risk Takers
• Staff engaged in control functions
• Staff receiving total remuneration that places them in the same remuneration bracket as senior management and risk takers
Remuneration
The remuneration of Code Staff consists of fixed and variable components. The fixed remuneration is a base salary designed to offer competitive compensation, considering experience, duties, and responsibilities.
Malus or Clawback
Variable remuneration is performance-adjusted and is only paid or vests if it is sustainable and justified based on the performance of the business unit, the UCITS/AIF, and the individual in question. Variable remuneration may be reduced or forfeited under malus terms, and amounts paid or released may be recovered for up to 12 months under clawback terms in specific situations, which may include but are not limited to:
• Subdued or negative financial performance of the Firm or the UCITS concerned
• Fraud, misbehavior, or misconduct of the individual
• Serious error due to the individual’s negligent conduct
Personal Hedging Strategies
Staff members are prohibited from using personal hedging strategies that could undermine the risk alignment effects incorporated into their remuneration arrangements.
If you have further questions or would like to discuss any aspect of this policy, please contact us at compliance@garrickandcrow.com.
