Remuneration Policy


(the “Company”)

Remuneration Policy as at 30 April 2019

The Company is authorised by the Central Bank of Ireland (the “Central Bank”) as a UCITS investment company.

The purpose of the Policy is to describe the remuneration practices of the Company in relation to its identified staff, namely the non-executive directors of the Company (the “Directors”) and the designated persons responsible for the managerial functions identified in the Company’s UCITS Business Plan (the “Designated Persons”). The Company’s board of Directors (the “Board”) has established these practices to ensure that they are consistent with and promote sound and effective risk management and do not encourage risk taking that is inconsistent with the risk profile and articles of association of the Company.

The total net assets of the Company as at most recent year end date (30 April 2019) was USD nil.

Identified Staff

The categories of staff, including senior management, risk takers and control functions whose professional activities may have a material impact on the risk profile of the Company and of the Funds are identified in the Schedule to this Policy (the “Identified Staff”).

The only Identified Staff are the Directors and the Designated Persons.

 Types of Remuneration

This policy applies to all forms of payments or benefits paid by the Company to the Identified Staff in exchange for professional services. Such forms of payment or benefit may include:

  1. fixed remuneration (payments or benefits without reference to performance); and
  2. variable remuneration (additional payments dependent on performance or other contractual criteria as described below).

The Company currently only pays fixed remuneration to the non-executive directors.  The Designated Persons do not receive any remuneration directly from the Company.

Remuneration Policy

The Company’s policy is to pay the relevant Identified Staff fixed remuneration only with no variable component being paid.


The Company will comply with the disclosure requirements set out in:

  • Directive 2009/65/EC of the European Parliament and of the Council of 13 July 2009 on the coordination of laws, regulations and administrative provisions relating to undertakings for collective investment in transferable securities as amended by Directive 2014/91/EU of the European Parliament and of the Council of 23 July 2014 as regards depositary functions, remunerations policies and sanctions, including its mandatory implementing regulations on an EU or Home Member State level and as further amended from time to time (the “UCITS Directive”);
  • Any regulations enacted or adopted from time to time by the European Commission pursuant to or in accordance with the UCITS Directive, whether as delegated acts or otherwise;
  • the Central Bank (Supervision and Enforcement) Act 2013 (Section 48(1)) (Undertakings for Collective Investment in Transferable Securities) Regulations 2015 S.I. No 420 of 2015; and
  • the ESMA Guidelines on sound remuneration policies under the UCITS Directive and AIFMD issued pursuant to Article 14a(4) of the UCITS Directive (the “UCITS Remuneration Guidelines”)

The Company’s up to date remuneration policy is disclosed on the following website: A summary statement in relation to this Policyhas beenincluded in the Company’s Prospectus and in each of the Company’s KIIDs.

The total amount of remuneration for the financial year, split into fixed and variable remuneration (if any), paid by the Company to the relevant Identified Staff is disclosed in the Company’s annual report, as well as the aggregate amount of remuneration broken down by senior management whose actions have a material impact on the risk profile of the Company.

The Board considers that this policy is in line with the strategy, objectives and values of the Company and is not inconsistent with the best interests of the Company and its investors.

Remuneration Committee/Board Oversight

The Board has determined in light of the size, internal operations, nature, scale and complexity of the Company that a remuneration committee is not required.  Remuneration matters will be dealt with by the Board with the relevant affected director absenting himself from such discussions.

The Company has in place a Directors’ conflicts of interest policy and the remuneration policy and its implementation shall be subject to the requirements of such conflicts of interest policy.


The Board will review the implementation of this remuneration policy on a quarterly basis and will review its practices for compliance with the policy on an annual basis. All reviews conducted concluded that the Company had continued to comply with this remuneration policy, and that the policy remained consistent with the strategy, objectives and values of the Company and was not inconsistent with the best interests of the Company and its investors.


This is the Company’s remuneration policy and does not extend to any of the Company’s delegates. However, it is the Company’s policy that it will comply with the ESMA Remuneration Guidelines, including insofar as and to the extent such guidelines oblige the Company to ensure that similar remuneration requirements are applied to its delegates.

The Company pays investment management fees at fixed rates which are disclosed in the Company’s Prospectus documents and annual report.


Identified Staff

Board Members                                                                                                                                                                       

Mr Killian Buckley

Mr David Suratgar

Mr Mark Ebert

Mr Dermot Walsh

Mr Simon Hopkins

Designated Persons

Ms Maria Galan, Duff & Phelps

The above named Board Members and Designated Persons are the Identified Staff.