Effective Date: March 2024
In accordance with the UCITS Directive, Crown and Bates has established a remuneration policy designed to support sound and effective risk management. The policy discourages risk-taking that is misaligned with the risk profile or the constitution of the Crown and Bates fund.
This policy rewards individual contributions that demonstrate the delivery of long-term, sustainable results in line with the business and the funds under management. It also promotes values and behaviors that prioritize the best interests of our clients and shareholders. Crown and Bates employs a mix of financial and non-financial targets, using both short- and long-term incentive strategies to attract, retain, and motivate key talent.
We are dedicated to ensuring this policy promotes inclusivity, ensuring fair treatment and opportunities for all employees, regardless of gender, ethnicity, age, disability, or any other protected characteristic.
Governance
Crown and Bates has reviewed the UCITS Directive’s requirements concerning the establishment of a Remuneration Committee. Given the company’s size, internal structure, and the nature, scope, and complexity of its activities, it has been determined that a separate committee is not required.
The policy will be reviewed at least annually by an independent individual with expertise in risk management and remuneration, who does not perform executive functions in the UCITS business. The board will oversee any necessary updates and implementation of the policy. To avoid conflicts of interest, any board members who receive remuneration directly or indirectly from the funds will not participate in decisions related to variable remuneration.
UCITS Remuneration Code Staff (‘Code Staff’)
Code Staff refers to employees whose professional activities materially influence the risk profile of the management company or the funds it manages. This includes:
- Senior Management
- Risk Takers
- Employees in control functions
- Employees whose total remuneration is on par with senior management and risk takers
Remuneration Structure
The remuneration for Code Staff is composed of fixed and variable elements. The fixed component, or base salary, is designed to provide competitive compensation based on the individual’s experience, duties, and responsibilities.
Malus and Clawback Provisions
Variable remuneration is performance-based and will only be paid or vested if it is deemed sustainable and justified based on the performance of the relevant business unit, the UCITS/AIF, and the individual. Under malus provisions, variable remuneration may be reduced or forfeited. Additionally, clawback provisions allow for the recovery of amounts paid or released for up to 12 months in certain circumstances, including but not limited to:
- Subpar or negative financial performance of the firm or the relevant UCITS
- Fraud, misconduct, or misbehavior by the individual
- Serious errors resulting from individual negligence
Prohibition of Personal Hedging Strategies
Employees are prohibited from using personal hedging strategies that may undermine the risk alignment embedded in their remuneration arrangements.
