It is TMF-FM policy that remuneration is consistent with and promotes sound and effective risk management and does not encourage risk management which is inconsistent with risk profiles, rules or instruments of incorporation of the investment funds management by TMF-FM (“Funds”).
TMF-FM has established a remuneration policy, which sets out principles applicable to the remuneration of the senior management, all staff members having a material impact on the risk profile of the Funds as well as all staff members carrying out pre-approved control functions, including Directors (in-scope staff). TMF-FM has elected to apply the proportionality principle as provided by the guidelines, and the remuneration policy has therefore been conceived in a way and to an extent that it is appropriate to its size and internal organization as well as the nature, scope and complexity of its activities.
Remuneration includes a combination of fixed and variable remuneration, and may include participation in the TMF Groups’ group-wide discretionary bonus scheme. Variable remuneration is discretionary and based upon a number of factors that are not directly linked to the investment performance of the Funds, although performance of the Funds could ultimately affect the performance of TMF-FM by virtue of its business model. Variable remuneration will be assessed by senior management to ensure that it does not encourage excessive risk taking.
The remuneration policy is in line with the business strategy, objectives, values and interests of TMF-FM, the Funds and the investors of the Funds and includes measures to avoid conflicts of interest.
One individual acting as non-executive independent director received fixed remuneration for their role as a member of the board of TMF-FM. No variable remuneration is paid to this director.
The remuneration policy provides that:
- The fixed and variable components of total remuneration of in-scope staff are appropriately balanced and the fixed component represents a sufficiently high proportion of the total remuneration.
- Identified staff are compensated in accordance with their professional experience, responsibility, job complexity as well as relevant market conditions and entity and group performance.
As provided for under the regulations, TMF-FM discloses the remuneration on an annual basis to shareholders of the funds.
Where TMF-FM appoints a delegate to carry out portfolio management or risk management, it ensures that the delegate is subject to regulatory requirements on remuneration that are equivalent to those set out in the guidelines or puts in place appropriate contractual arrangements to ensure that there is no circumvention of the remuneration requirements.