Remuneration Policy

Nevastar Finance (Luxembourg) SA (the “Management Company”) has established a remuneration policy (the “Policy"), in the context of managing undertaking for collective investment on transferable securities (“UCITS”) and alternative investment funds (“AIFs”) (jointly hereafter referred to as the “Funds”), which sets out principles applicable to the remunerations of the senior management, all staff members having a material impact on the risk profile of the financial undertakings as well as all staff members carrying out independent control functions, whose objectives are:

1. To ensure that the remuneration is in line with the applicable laws and regulations, and more specifically with the provisions defined under:
   • the Law of 17 December 2010 relating to undertakings for collective investment (the 2010 Law);
   • the Law of 12 July 2013 relating to alternative investment fund managers (the AIFM Law)
   • the ESMA guidelines 2013/232 on sound remuneration policies under the AIFMD (the ESMA guidelines 2013/232);
   • the ESMA guidelines 2016/575 on sound remuneration policies under the UCITS Directive (the ESMA guidelines 2016/575);
   • ESMA Questions and Answers, as updated from time to time, on the application of the UCITS directive (the ESMA Q&A UCITS);
   • ESMA Questions and Answers, as updated from time to time, on the application of the AIFMD (the ESMA Q&A AIMD); and
   • Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability‐related disclosures in the financial services sector (SFDR).
2. to be in line with the business strategy, objectives, values and interests of the Management Company and the Funds it manages or the investors of such Funds
3. not to encourage risk‐taking which is inconsistent with the risk profiles, rules or articles of incorporation or management regulations of the Funds the Management Company manages, including with respect to sustainability risks. For the avoidance of doubt, a sustainability risk means an environmental, social or governance event or condition that, which if they occur have or may potentially have significant negative impacts on the assets, financial and earnings situation, or reputation of a supervised entity.
4. to avoid or manage conflicts of interest
5. To ensure that the remuneration rules are not circumvented when delegating investment management functions (including risk management) under article 110 of the 2010 Law and under article 18 of the AIFM Law for AIFs; in particular:
   • for entities subject to equivalent remuneration rules, the Management Company ensures that delegates are subject to regulatory requirements that are equally as effective as those applicable to the Management Company, i.e. (i) the entity is subject to remuneration rules and (ii) its staff qualifies as identified staff for the purpose of the remuneration rules applicable to the entity
   • for other entities, the Management Company ensures that entities which do not fall under the previous paragraph enter into an agreement with the Management Company to ensure that the remuneration rules applicable to the Management Company are not circumvented. To this effect the agreement will include a provision for any payment made to the entity’s identified staff as compensation for the performance of investment management activities on behalf of the Management Company

The Policy applies to all remuneration paid either by the Management Company or by the entities to which investment management functions have been delegated or by the Funds themselves.

The Policy also complies with the proportionality principle as provided by the ESMA guidelines 2013/232, and therefore has been conceived in a way and to an extent that it is appropriate to our size and internal organisation as well as the nature, scope and complexity of our activities.

The annual report shall disclose the aggregate remuneration paid according to applicable rules and market practice.

In addition, it is possible to request additional information, free of charge, by writing to:

Nevastar Finance (Luxembourg) SA
17a Rue des Bains, L-1212 Luxembourg