Remuneration Policy of the Management Company. The Management Company has in place a remuneration policy which seeks to ensure that the interests of the Management Company and the Unitholders are aligned. Such remuneration policy imposes remuneration rules on staff, including senior management, risk-takers, staff engaged in control functions and employees receiving a total remuneration that puts them in the same income bracket as senior management and risk-takers, whose actions may have a significant influence on the risk profile of the Management Company and/or the UCITS. The Management Company shall seek to ensure that such remuneration policies and practices will be consistent with sound and effective risk management and shall not encourage risk-taking inconsistent with the risk profile and constitutional documents of the UCITS and shall ensure that its actions shall comply with the UCITS Act and the ESMA Guidelines on sound remuneration policies under the UCITS Directive (ESMA/2016/575). In line with the provisions of the UCITS Act, the Manager applies its remuneration policy and practices in a way and to the extent that is proportionate to its size, its internal organisation and the nature, scope and complexity of its activities. The Management Company shall seek to ensure the remuneration policy will at all times be consistent with the business strategy, objectives, values and interests of the Management Company, the UCITS and the Unitholders and that the remuneration policy includes measures to ensure that all relevant conflicts of interest can be managed appropriately at all times. The remuneration policies and practices of the Management Company are specified in Annex C.
