Regulatory Disclosures
On 25 May 2018, the EU General Data Protection Regulation (“GDPR”) came into effect in the UK. In order to comply with the requirements of GDPR, CAML has updated its privacy statement. This statement provides detailed information about how we collect, use and disclose personal data and your rights in relation to this.
The EMT provides a description of CAML’s financial products, target market, distribution strategy, costs and charges, to enable product distributors to facilitate data exchange between different investors.
Persons who do not have professional experience in matters relating to investments should not rely solely on the content of this document. Further details of the risks associated with investing in each fund can be found in the Key Investor Information Document or Prospectus, printed copies of which are available on request. Should you need advice, or if you’re interested in any of CAML’s range of funds, please seek advice from a financial adviser.
This document provides additional information and guidance on the definitions and codification used in the EMT v1.0 as it relates specifically to CAML’s Funds. It is not intended to alter the meaning of the relevant regulation, and may be subject to revisions as regulatory and industry practice change.
Summary of the ACD’s Remuneration Policy
Courtiers Asset Management Limited (“CAML”) is authorised to operate as an Authorised Corporate Director (“ACD”) and Investment Manager. The current funds under CAML’s management include the Courtiers Investment Funds ICVC, which is a Non-UCITS Retail Scheme and the Courtiers UCITS Investment Funds ICVC.
The ACD has adopted a remuneration policy in accordance with the requirements of both the UCITS Directive and the Alternative Investment Fund Managers Directive and which is designed to ensure that the ACD’s remuneration practices:
- Are consistent with and promote sound and effective risk management.
- Do not encourage risk taking that is inconsistent with the risk profiles of the Funds, their Instrument of Incorporation or Prospectus.
- Do not impair the ACD’s compliance with its duty to act in the best interests of the Company and the Funds.
- Include fixed and variable elements of remuneration, including salaries and discretionary pension benefits.
The Remuneration Policy applies to “Remuneration Code Staff”, being (in summary) those persons whose professional activities have a material impact on the risk profile of the ACD and the Funds (Material Risk Takers), including but not limited to, senior management and risk takers (such as, for example, portfolio managers).
How the ACD Calculates Remuneration and Benefits
At the heart of CAML’s Remuneration Policy is the need to ensure that the structure of an employee’s remuneration is consistent with, and promotes, effective risk management.
CAML will ensure that the fixed and variable elements of total remuneration are appropriately balanced and that the fixed element is a sufficiently high proportion of total remuneration so that variable remuneration can be fully flexible including the possibility to pay no variable remuneration.
Where remuneration is performance-related, in addition to the performance of the individual, CAML will also consider the performance of the business unit or fund concerned and the overall results of CAML. Performance assessment will not relate solely to financial criteria but will also include compliance with regulatory obligations and adherence to effective risk management. In keeping with CAML’s long-term objectives, the assessment of performance will take into account longer-term performance, and payment of any such performance-related variable remuneration may be spread over more than one year to take account of CAML’s business cycle.
Financial performance is an important factor in the calculation of any variable remuneration. The measurement of financial performance will be based primarily on net profits and not on gross profitability, revenue or turnover. In those instances when the latter is used in assessment, then CAML will also consider the quality of business undertaken or services provided and their appropriateness for clients.
If subdued or negative financial performance of CAML occurs, total variable remuneration would in general be considerably contracted.
The Identities of the Persons Responsible for Awarding Remuneration and Benefits
When establishing and applying remuneration policies for Remuneration Code employees, a firm is permitted to apply a proportionate approach in a way that is appropriate to:
.• Its size
- Internal organisation
- The nature, scope and complexity of its activities.
CAML has considered the size of its assets under management (AuM) and other proportionality elements referred to in the Financial Conduct Authority’s general guidance on the AIFM Remuneration Code and in Guidelines issued by the European Securities and Markets Association (“ESMA”) and has concluded that it is not a “significant firm”. Whilst appreciating the contribution that can be made by a remuneration committee, CAML considers that such a body would not be proportionate given its size and the non-complex nature of both its activities and organisation. Instead, CAML’s Board undertakes this role.
The Board is responsible for approving and maintaining CAML’s Remuneration Policy and reviews the Policy periodically as necessary and at least once a year to ensure that it remains consistent with the Remuneration Code Principles. The Board is also responsible for overseeing the implementation of the Policy, approving any subsequent material exemptions and changes to the Policy and for monitoring the effects of the Policy.