Information of Bantleon AG, Management Company of the umbrella funds BANTLEON ANLEIHENFONDS, BANTLEON OPPORTUNITIES and
BANTLEON SELECT SICAV
Conflict of interest policy
In the unlikely event that a conflict of interest could not be managed by the Management Company or its delegates, confidentiality permitting, the Management Company will take the relevant measures to inform the investors.
In case you would need to address any complaint to the Management Company, please send your concerns to:
Complaints Handling Officer
Telephone: +49 (0) 511 288 798-0
Contact via E-Mail
The Complaints Handling Officer will confirm receipt of your mail/e-mail and organize the answer to your concerns in the shortest possible timeframe.
General principles of remuneration policy
This document outlines Bantleon AG’s general remuneration principles, which have the following aims:
- The remuneration principles promote a solid and effective risk management environment in line with investors’ interests and discourage staff from taking on risks that are not compatible with the risk profiles, contractual terms and articles of association of the funds managed by the Management Company.
- They are aligned with the Management Company’s corporate strategy, objectives, values and interests and those of the funds it manages as well as investors in such funds and include measures to avoid conflicts of interest. The remuneration principles are also in line with the sustainability objectives of the Company and the managed funds and promote the identification, analysis and mitigation of sustainability risks.
- They guarantee that remuneration complies with the applicable regulatory requirements, specifically (i) § 37 of the German Capital Investment Code (Kapitalanlagegesetzbuch, KAGB), (ii) the UCITS Directive 2014/91/EU, (iii) the ESMA final report on sound remuneration policies under the UCITS Directive and AIFMD of 31 March 2016 and (iv) the Regulation (EU) 2019/2088 on sustainability-related disclosure requirements in the financial services sector.
This remuneration policy applies to employees of Bantleon AG who qualify as »identified staff«, including the Executive Board, Portfolio Management, Compliance and Risk Management. All employees in the above functions are in a position to exert a potentially material influence, either individually or collectively, on the balance sheet and/or the income statement by endangering performance targets or on the risk profiles of the funds managed by the Management Company.
2. Calculation of remuneration
The remuneration paid to the Management Company’s employees comprises a fixed component and a variable component. The two components are suitably proportionate to each other and do not create an incentive to take on risks that are not compatible with the risk profiles and investment restrictions of the investment portfolios the employees manage. The fixed component is sufficient to ensure a flexible policy with regard to the variable component, which may be omitted entirely.
Guaranteed variable remunerations (bonuses) are only offered at the start of an employment relationship, and then only for a maximum of one year.
3. Principle of proportionality
The principle of proportionality allows the Management Company to exclude certain requirements of the UCITS Directive 2014/91/EU. Specifically, the Management Company does not comply with the requirements for payments to identified staff set out in the following paragraphs of the Directive:
- Art. 14b para. 1 h) assessment of performance set in a multi-year framework and actual payment of performance-related components of remuneration spread over the same period;
- Art. 14b para. 1 l) adjustment mechanism for variable remuneration components;
- Art. 14b para. 1 m) payment in the form of fund shares;
- Art. 14b para. 1 n) deferred payment.
4. Identity of persons responsible for allocation
The senior management of the Management Company is responsible for drafting, reviewing and implementing the remuneration policy and for allocating remuneration.
5. Review and amendment
These remuneration principles are reviewed at least once a year.