The Remuneration Policy provides a clear direction and policy regarding the Company’s remuneration structure and practices consistent with the principles in the UCITS Regulations and AIFMD. While the general provisions apply to all employees, some elements of the policy are applicable only to certain identified staff.
The Board of Directors recognise the importance of the role played by sound risk management in protecting its stakeholders. Moreover, the Board acknowledges that inappropriate remuneration structures could, in certain circumstances, result in situations whereby individuals assume more risk than necessary.
Although there is no Remuneration Committee in place, it is important to note that the ultimate responsibility for the oversight of compliance with this Remuneration Policy ultimately rests with Board of Directors.
The Remuneration Policy has been adopted in compliance with SLCs 3.05 and 3.06 of the Malta Financial Services Authority’s (“MFSA”) Investment Services Rules for Investment Services Providers – Part BIII: Standard Licence Conditions applicable to Investment Services Licence Holders which qualify as AIFMS (the “AIFM Rules”) including, in particular, Appendix 12 – Remuneration Policy to the AIFM Rules (the “Remuneration Provisions”). The Remuneration policy has also been adopted in compliance with SLCs 3.52 and 3.56 of the MFSA Investment Services Rules for Investment Services Providers Part BII: Standard Licence Conditions applicable to Investment Services Licence Holders which qualify as UCITS Management Companies (the “UCITS Rules”).
In drawing up the Remuneration Policy account has also been taken of the European Securities and Markets Authority’s (“ESMA”) Guidelines on sound remuneration policies under the AIFMD (ESMA/2013/201) (the “ESMA Guidelines”), the European Commission’s Recommendation 2009/384/EC on remuneration policies in the financial services sector (the “EC Recommendation”) and the Authority’s Guidance Notes on the Application of the Proportionality Principle in relation to the ESMA Guidelines on Sound Remuneration Policies under the UCITS Directive and the AIFMD which were issued on the 31st January 2017 (“MFSA Guidance Notes”).
Furthermore, the Remuneration Policy includes information establishing how remuneration is consistent with the integration of sustainability risks in accordance with Article 5 of Regulation (EU) 2019/2088 relating to sustainability-related disclosures in the financial services sector (the “SFDR”).
As with other aspects of the Company’s systems and controls, its remuneration policies, procedures and practices are required to be comprehensive but compliance with the Remuneration Provisions is expected to be proportionate in view of the size, internal organisation and the nature, scope and complexity of its activities (the “Proportionality Principle”).
For further information on the Company’s Remuneration Policy, kindly contact us on [email protected].
The Company has in place a Conflict of Interest Policy that sets out to identify, manage and mitigate any potential conflicts that may arise.
The key to making this policy effective is transparency and early identification.
The Policy also identifies the main conflicts that could arise, the manner in which to manage these conflicts and dictates the action to be taken where conflicts are identified.
For further information on the Company’s Conflict of Interest Policy, kindly contact us on [email protected]
STATEMENT AS PER ARTICLE 4(1)b of the DISCLOSURE REGULATION – NO CONSIDERATION OF SUSTAINABILITY ADVERSE IMPACTS
Pursuant to EU 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 (the “SFDR”), SevenHills Investment Management Limited (the “Company“) is required to disclose the manner how ESG Factors (as defined hereafter) are integrated into the investment decisions and the assessment of the likely impacts of Sustainability Risks.
The Company qualifies as a Financial Market Participant in terms of the SFDR. As a result of this, the Company is required to have in place policies and procedures setting out the approach adopted by the Company on the integration of sustainability factors in the investment decision‐making process/ investment advisory process and within its risk management framework. SFDR defines “sustainability factors” as environmental, social and employee matters, respect for human rights, anti‐corruption, and anti‐bribery matters (the “ESG Factors”). Financial Market Participants shall also publish and maintain on the websites, the reasons why they do not consider adverse impacts of investment decisions on sustainability factors, clear reasons for why they do not do so, including, where relevant, information as to whether and when they intend to consider such adverse impacts.
The Company is a boutique AIF and UCITS Manager authorised by the Malta Financial Services Authority. To date, the Company manages two funds, which are both classified as article 6 funds. Due to its size, assets under management, type of assets managed, business and investment strategy, the adverse impact of its investment decisions on the sustainability factors is of an extremely limited nature.
The Company is committed to the promotion of the employee well-being and the work-life balance. Initiatives have been taken and continue being developed to promote the personal and professional development of employees and the Company’s officials. The Company has also put in place robust governance structure to ensure high standards of its management and employees’ ethical behaviour.
While the Company does not currently consider sustainability adverse impacts, the Company is committed to transparency and provide other relevant sustainability disclosures. These may include information on our engagement efforts, adherence to industry standards and guidelines, and any positive contributions we make to sustainable practices within our investment portfolios. Additional information can be found in the Company’s ESG policy.
The Company continuously reviews and assesses its investment processes and regularly evaluates the feasibility of integrating sustainability adverse impacts into the Company’s decision-making. We remain committed to staying abreast of developments in the market and regulatory landscape, and we will reassess our approach should the circumstances change. Any future changes or updates to our consideration of sustainability adverse impacts will be promptly communicated via the Company’s website and to our clients.
ESG POLICY AND ESG INTEGRATION
The Company recognises the important contribution to society that Financial Market Participants can make via a conscious effort to abide by ESG principles. The Company’s ESG Policy sets out a framework for the inclusion of Environmental, Social and Governance factors into the Company’s investment process, including evaluation of prospective investments and investment decision-making, as well as appropriate documentation. To date, the Company manages two funds, which are both classified as article 6 funds (the “Funds”).
The Company does not currently integrate sustainability factors in its investment decision-making process.
The reason for this is that the Funds managed by the Company do not promote environmental or social characteristics and do not have sustainable investment objectives. Given the investment strategies pursued, and the nature of the products offered, sustainability risks are not systematically integrated into the Company’s investment decision-making process.
The Company continuously reviews and assesses its investment processes and regularly evaluates the feasibility of integrating sustainability adverse impacts into the Company’s decision-making. The Company remains committed to staying abreast of developments in the market and regulatory landscape and will reassess its approach should the circumstances change. Any future changes or updates to our consideration of sustainability adverse impacts will be promptly communicated via the Company’s website and to our clients.
The Company is committed to handling complaints promptly, fairly, and transparently.
A summary of our complaints management procedures is available upon request and will be provided free of charge.
If you wish to make a complaint or request this summary, kindly contact us at [email protected].