Remuneration policy in relation to the integration of sustainability risks

EU Sustainable Finance Disclosure Regulation

The Sustainable Finance Disclosure Regulation (”SFDR” or “the Regulation”) entered into force on 10 March 2021. The Regulation requires fund managers like Volpi Capital (Volpi) as an authorised AIFM to provide information to investors with regards to the integration of sustainability risks, the consideration of adverse sustainability impacts, the promotion of environmental or social characteristics, and sustainable investment.

This document specifically addresses Article 5 of the Regulation:

“Financial market participants and financial advisers shall include in their remuneration policies information on how those policies are consistent with the integration of sustainability risks, and shall publish that information on their websites.”

More information related to the SFDR, and Volpi’s approach to ESG and Responsible Investment in general, can be found on Volpi’s website, including:

• Sustainability risk policy
• Principal adverse impact statement
• Responsible Investment Policy

Volpi Capital’s Remuneration Policy

This document provides as summary of Volpi’s Remuneration Policy. The full Remuneration Policy is available upon request at Volpi’s registered office.

Volpi’s Remuneration Policy aims to promote sound and effective risk management, and to discourage risk-taking which is inconsistent with the risk profiles, rules or instruments of incorporation of the alternative investment funds the Manager manages, and to avoid conflicts of interest.

The Remuneration Policy has been adopted by the Board of Volpi Capital in accordance with binding rules implementing EU directive 2011/61/EU on Alternative Investment Fund Managers and relevant implementing regulations (together, the AIFMD), and in accordance with the principle of proportionality.

Remuneration policy considerations in relation to the integration of sustainability risks

Volpi’s Remuneration Policy promotes sound and effective risk management with respect to sustainability risks, ensuring that the structure of remuneration does not encourage excessive risk-taking with respect to sustainability risks. Volpi also considers the effect of potential conflicts of interest on remuneration in a way that is consistent with the integration of sustainability risk, including (but not limited to), any activities that give rise to greenwashing, misselling, or misrepresentation of investment strategies.

Remuneration

Remuneration of the employees having a material impact on the managed funds’ risk profile comprises of fixed and variable remuneration. Remuneration levels shall be justified according to performance of the individual concerned. The total amount of variable remuneration shall be based on a combination of the assessment of the performance of the employee and the overall results of the fund, as well as the conduct of the employee under the internal procedures and compliance requirements applicable.

This includes an assessment of the performance of the employee under Volpi’s Responsible Investment Policy. Assessment of performance under the Responsible Investment Policy is discretionary, and shall be based on (i) how the employee integrates sustainability risk into investment decisions, and (ii) the extent to which the employee promotes the principles set out in Responsible Investment Policy in the management of the portfolio, thereby reducing sustainability risk and contributing to the sustainability objectives.

Board approval and revision

The Remuneration Policy is approved by the Board of the Manager. It shall be reviewed by the Board at least annually and updated if deemed necessary or desirable.