INFORMATION ABOUT THE REMUNERATION POLICY
The 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 UCITS Directive 2014/91/EU (“UCITS V”) the Alternative Investment Fund Managers Directive 2011/61/EU (“AIFMD”)
2. To comply with the following guidelines: SLCs 3.52-3.60 of Part BII and SLCs 3.05-3.06 of Part BIII of the Malta Financial Services Authority’s Investment Services Rules for Investment Services Providers (the “Rules”) including in particular, Appendix 12 – Remuneration Policy. European Securities and Markets Authority’s Guidelines on sound remuneration policies under the UCITS Directive and AIFMD (the “ESMA Guidelines”)
3. To comply with Gamma Capital Markets Ltd (“GCM”) remuneration policy practices which aim to: ensure that remuneration is in line with the business strategy, objectives, values and interests of GCM and the Funds it manages or the investors of such Funds; not encourage risk taking which is inconsistent with the risk profiles, rules or articles of incorporation or management regulations of the Funds GCM manages; ensure consistency with and promotion of sound and effective risk management to avoid excessive risk taking; avoid or manage conflicts of interest.
The Policy applies to all remuneration paid either by GCM or by the Funds themselves.
The Policy also complies with the proportionality principle as provided by the ESMA 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.
Therefore GCM has not established a Remuneration Committee. The Board of Directors (the “Board”) of GCM is responsible of the Remuneration of the Company. The Board set and monitor the overall Remuneration Policy and is responsible for awarding the remuneration and benefits. The remuneration and benefits granted will take into consideration
An appraisal of the GCM employees, namely: senior management, individuals performing functions which have significant influence of the direction and operation of the Firm, risk-takers, staff engaged in control functions.
The overall results of GCM
GCM regulatory capital and liquidity Requirements
Fixed and variable components of total remuneration must be appropriately balanced and the fixed component must represent 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.
GCM seeks to ensure that individuals involved in Control Functions remain independent from the business areas they oversee to avoid any potential conflicts of interest. The Board of Directors determines the remuneration of any individuals in Control Functions with such remuneration linked to the Firm’s adherence to its risk profile, provided that any discretionary bonuses to the Control Functions shall be determined primarily by the attainment of their function-specific objectives. The variable remuneration of individuals in Control Functions is only linked to the overall performance of the Firm to the extent that there is a variable remuneration pool.
The annual report shall disclose the aggregate remuneration paid by GCM and by the UCITS according to UCITS V applicable rules and market practice.
Therefore investors can find more details about the remuneration policy in the annual reports of the Management Company and the Funds.
In addition, they may request free of charge additional information by writing to dimitri.aline@gamma.com.mt.