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Remuneration Policy

Information about the compensation policy of Baumann & Partners S.A.

Baumann & Partners S.A. ("B&P") was established on April 23, 2008, in Luxembourg as a Société Anonyme for unlimited duration, registered in the R.C.S. under the number B 138.247, and is licensed as an asset manager under Article 24-3 of the Law of April 5, 1993, on the Financial Sector by the CSSF. General financial advisory, brokerage, and commission activities under Articles 24, 24-1, and 24-2, ancillary services as per Annex II, Section C, point 1, and custody and management of financial instruments on behalf of clients, including custodianship and associated services like cash management or safekeeping of securities, are also covered by the license.

As an asset manager, B&P is obligated to establish, implement, and maintain a remuneration policy that aligns with the business strategy, objectives, values, and long-term interests of the financial firm.

The policy pursued and available by the company is in accordance with:

  • MiFID II – Directive (EU) 2014/65
  • IFD – Directive (EU) 2019/2034
  • IFR – Regulation (EU) 2019/2033
  • Delegated Regulation (EU) 2017/565
  • Delegated Regulation (EU) 2021/2154
  • Delegated Regulation (EU) 2021/2155
  • EBA/GL/2021/13 – Guidelines on remuneration policies
  • EBA/GL/2021/14 – Supplementary guidelines on remuneration
  • Financial Sector Law – Law of April 5, 1993
  • Law of May 30, 2018, on Markets in Financial Instruments
  • CSSF Circular 21/789
  • CSSF Circular 20/758
  • CSSF Circular 23/841
General Information

This excerpt from the compensation policy of B&P applies to all employees of the company and aligns with the business strategy, objectives, values, and interests of investors. The remuneration system of B&P includes measures to avoid conflicts of interest. Employees' compensation is agreed upon as a fixed salary in the employment contract, and B&P may pay a variable compensation.

The total annual salary (fixed salary plus incentive potential) is reviewed annually and adjusted if necessary.

The remuneration system is subject to the approval and at least annual review by the Board of Directors, which also ensures the implementation of the compensation policy. Additionally, the compliance function reviews the remuneration system at least once a year.

Overview of the compensation structure

The compensation system includes fixed and variable salary components as well as voluntary special payments (bonuses), and they are paid out exclusively in cash. The ratio between fixed and variable compensation is limited; the variable compensation may not exceed 100% of the fixed compensation.

Guaranteed bonuses may only be granted in exceptional cases, which can only occur in connection with the hiring of new employees and are limited to the first year of employment. In the event of changes in the legal framework, the compensation system will be adjusted accordingly to meet all applicable requirements.

The bonus is determined anew each year, with the individual achievement of the employee's goals and the available bonus budget being crucial for a bonus payout. The annual bonus budget is set by the Board of Directors, with the business success of B&P, taking sustainability factors into account, being a key consideration.

Within B&P, the budget is distributed by management down to the employees, taking into account the following:

  • the individual's performance,
  • the respective business unit, and
  • the company (B&P) based on quantitative and qualitative goals.

Employees and their supervisors typically set the goals at the beginning of each fiscal year as part of a performance appraisal meeting, with any significant negative points identified in the evaluation that can be considered in subsequent years, allowing for a multi-year assessment framework.

SFDR Requirements

According to Article 5 of the SFDR, financial market participants are required to include information in their remuneration policy on how it is consistent with the integration of sustainability risks. The remuneration policy aims for sustainable compensation for sustainable performance by focusing on coherence between remuneration and performance, as well as between remuneration and long-term value creation for stakeholders. It considers both the actual results achieved and the manner in which they have been generated.

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