Group Remuneration Policy

Valid from January 1, 2021

1. Purpose

This Policy describes the remuneration philosophy and principles of 2Xideas AG (in the following referred to as Company). The purpose of this Policy is to ensure a sound and clear risk management in alignment with Company’s business strategy and with regard to legal and regulatory requirements, such as the FINMA Circular 2010/1 on Remuneration Schemes, the Asset Management Association Switzerland’s (AMAS) code of conduct and applicable European Regulations. This Policy further integrates the sustainability risks, as required by the EU Sustainable Finance Disclosure Regulation (“SFDR”). Company strives to render all services in their clients’ interests. For this reason, Company is concerned not to create any potential and harmful incentives through remuneration components but providing a clear and sound remuneration Policy which is resistant to any potential incentive. Furthermore, this Policy shall establish a remuneration scheme that fits the dedication and responsibilities of the employees to whom it applies, aiming the completion of the strategic objectives of the company within its activities framework.

2. Scope

The Remuneration Policy affects employees within categories where their professional activities impact significantly the risk profile in the company. In particular, it is applied to the executive management, to employees who assume risks, to those who perform control functions, as well as to every employee receiving a global remuneration included in the same remuneration scale as the previously described and whose professional activities affect in an important manner the risk profile of the entity.

3. Proportionality

The remuneration of all of Company’s employees is based on the company’s size, the Assets under Management (both funds and managed accounts), the company’s organization as well as the nature, scope and complexity of Company’s businesses. Company’s management categorizes the company based on its size, structure, assets and business as a complex financial institute. Variable remunerations are accordingly to be treated with the appropriate caution and need to be justified by the beneficiary’s personal performance as well as through the way of their payment instrument (cash, bonus, etc.).

The responsibilities and functions of the different bodies involved in the establishment, approval, execution and oversight of the Remuneration Policy (Board of Directors, HR, Head of Risk Management and the Compliance Officer) are consistent with the following principles:

• Compliance with adequate and efficient risk management, and does not offer incentives towards assuming risks above the company’s pre-established levels.
• Compliance with the company’s strategy, its objectives, values and long-term interests, including procedures to avoid possible conflicts of interests.
• Acknowledgment of market trends. Positioning towards these must comply with the company’s strategic approach.
• The remuneration assigned to each employee is defined based on its position, under a homogenous treatment to those with similar responsibilities and functions.
• The remuneration of the control functions is independent of the results generated by the business units supervised.
  
  

4. Principles on Remuneration

Company’s employees’ remuneration is compound by market-compliant fixed wages as well as variable and performance-related, discretionary bonus components. Both payments must be appropriately well balanced to each other. Company acknowledges that this Policy and an individual Employee’s remuneration, must be consistent with and promote sound and effective risk management and not encourage risk-taking that exceeds the level of tolerated risk of the Company. The risk-limiting features of this Policy include (amongst other things) application of non-financial metrics, such as an assessment of an Employee’s compliance with the Company’s Risk Management, Compliance and Code of Conduct Directives, as well as the Company’s Sustainability Policy. The fixed remuneration will primarily reflect the relevant professional experience and the responsibility within the organization. The variable bonus component must not create any encouragement to enter into any excessive risk and considers both the employee’s individual performance as well as the company’s revenue, risk, capital und liquidity situation.

The variable remuneration is subject to a series of generic or specific objectives and, generally, is based in a series of qualitative and quantitative criteria, of which the most important are listed below, but not limited to:

• The total variable remuneration does not limit the entity’s capacity to strengthen the solidity of its capital base and undermine its solvency.
• The variable remuneration reflects a sustainable performance within a set of Directives and Policies (including Risk, Compliance, Code of Conduct and Sustainability), as well as a performance superior than required in order to fulfil the stipulated in the description of functions as part of the working conditions.
• The variable salary, within a multiannual scheme, is determined taking into account individual results from management, the development and positioning of the business on the corporate level, as well as the employee’s contribution to the progress and proper functioning of the company.
• The variable components of the remuneration are sufficiently flexible to allow its modulation; to the extent it is possible to suppress the variable remuneration in case the objectives to which it is linked are not achieved.
• In any case the variable remuneration is not guaranteed.
  
  

5. Annual Review

This Policy shall be reviewed and amended as necessary on an annual basis.