Universal-Investment-Luxembourg S.A. (hereinafter "Universal-Investment") is subject to the applicable regulatory provisions governing the establishment of remuneration systems for capital management companies. Universal-Investment has set out the detailed arrangements in ist remuneration policy.
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 UCITS that the Universal-Investment-Luxembourg S.A. manages.
The remuneration policy is in line with the business strategy, objectives, values and interests of Universal-Investment-Luxembourg S.A. and the UCITS that it manages and of the investors in such UCITS, and includes measures to avoid conflicts of interest.
At least once a year, a remuneration committee of the Universal-Investment checks the remuneration system of Universal-Investment for its adequacy and compliance with all legal provisions. It covers fixed and variable remuneration aspects. The calculation of the variable remuneration includes Universal-Investment's earnings situation, the attainment of the organisational unit's goals and the employee's personal performance. The most important of the goals set during the personal assessment are sustainable business development and protection of the company against excessive risks. Above all, no incentives to take excessive risks should be created. The purpose of the remuneration system should be to control the company's operational risk components, as well as to enhance the efficiency and quality of the work and product by means of clearly structured processes, automation and specific responsibilities. Therefore, the variable remuneration elements in particular are not linked to the performance of the investment assets managed by Universal-Investment.
Furthermore, establishing ranges for the entire remuneration ensures that there is no significant dependence on the receipt of variable remuneration and that the relationship between the fixed and variable remuneration is appropriate. Both the Executive Board and the Board of Directors have the final say in the allocation of variable remuneration. You can familiarise yourself with the members of the Executive Board and the Supervisory Board of Universal-Investment via the following link: www.universal-investment.com/en/Management-Board-Luxembourg . The remuneration committee responsible for defining and checking the remuneration system of the Universal-Investment Group comprises the Chairman of the Supervisory Board, representatives of the Executive Board, the Personnel Department, Risk Controlling and Portfolio Management and Compliance of Universal-Investment-Gesellschaft mbH. In addition to the aforementioned remuneration elements, Universal-Investment employees can obtain voluntary employer benefits-in-kind as well as material and retirement benefits.
Special regulations apply to the Executive Board of Universal-Investment and its employees, whose activities have a considerable impact on the company's overall risk profile and the investment assets managed by it ("risk takers"). Employees who may have a decisive impact on the risk and corporate policy of Universal-Investment have been identified as risk takers. The payment of performance-based remuneration is set in a multi-year framework in order to ensure that the payment of such remuneration is based on the long-term performance of the UCITS and its investment risks. The variable remuneration for these risk-affected employees is paid out in arrears over several years. A mandatory portion of at least 40% of the variable remuneration is deferred over a period of at least three years. During this period, the deferred portion of the remuneration is risk-based, which means it can be reduced in the event of negative profit contributions by the employee or by Universal-Investment. At the end of each year during the qualifying period, the relevant deferred share of the remuneration falls due and is paid out on the respective payment date.