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Remuneration Policy

The Management Company has established and applies a remuneration policy and practices that are consistent with, and promote, sound and effective risk management and that neither encourage risk taking which is inconsistent with the risk profiles, rules, this Prospectus or the Articles nor impair compliance with the Management Company’s obligation to act in the best interest of the Clients (the Remuneration Policy).

The Management Company has established and applies a remuneration policy and practices that are consistent with, and promote, sound and effective risk management and that neither encourage risk taking which is inconsistent with the risk profiles, rules, this Prospectus or the Articles nor impair compliance with the Management Company’s obligation to act in the best interest of the Clients (the Remuneration Policy).

The Remuneration Policy includes fixed and variable components of salaries and applies to those categories of staff, including senior management, risk takers, control functions and any employee receiving total remuneration that falls within the remuneration bracket of senior management and risk takers whose professional activities have a material impact on the risk profiles of the Management Company, the Clients or the Sub-Funds.

The Executive Committee is in charge of determining the fixed and variable remunerations of employees. The variable remuneration is granted based on two main criteria: the financial benefit realised at each year end of the management company and the individual’s performance.

The Remuneration Policy is in line with the business strategy, objectives, values and interests of the Management Company, the Clients and the Shareholders and includes measures to avoid conflicts of interest.

The Remuneration Policy is consistent with the integration of ‘sustainability risks’ within the meaning of, and as required by Regulation (EU) 2019/2088 of November 27, 2019, as amended.

In particular, the Remuneration Policy will ensure that:

  1. The staff engaged in control functions are compensated in accordance with the achievement of the objectives linked to their functions, independently of the performance of the business areas that they control;
  2. The fixed and variable components of total remuneration are appropriately balanced and the fixed component represents a sufficiently high proportion of the total remuneration to allow the operation of a fully flexible policy on variable remuneration components, including the possibility to pay no variable remuneration component;
  3. The measurement of performance used to calculate variable remuneration components or pools of variable remuneration components includes a comprehensive adjustment mechanism to integrate all relevant types of current and future risks;

In context of delegation, the Remuneration Policy will ensure that the Delegate comply with the following:

a) the assessment of performance is set in a multi-year framework appropriate to the holding period recommended to the investors of the Company in order to ensure that the assessment process is based on the longer-term performance of the Company and its investment risks and that the actual payment of performance-based components of remuneration is spread over the same period;

b) if at any point of time, the management of the Company were to account for 50 % or more of the total portfolio managed by the Delegate, at least 50 % of any variable remuneration component will have to consist of Shares, equivalent ownership interests, or share-linked instruments or equivalent non-cash instruments with equally effective incentives as any of the instruments referred to in this item (e); and

c) a substantial portion, and in any event at least 40 % of the variable remuneration component, is deferred over a period which is appropriate in view of the holding period recommended to the Shareholders and is correctly aligned with the nature of the risks of the Company.

Complaint Policy

Lemanik Asset Management S.A. (the “Management Company”) is subject to the supervision of the Commission de Surveillance du Secteur Financier (“CSSF”). The Management Company has adopted a Complaint Handling policy for managing investor complaints in an effective manner.

Investors may file complaints free of charge in the official language or one of the official languages of their Member State.

Any complaint shall be sent to the attention of the Complaint Handling Officer of the Management Company at:

Lemanik Asset Management S.A.
106 route d’Arlon
L-8210 Mamer
Grand Duchy of Luxembourg

Email: [email protected]

The following steps will be taken by the Complaint Handling Officer upon receipt of an investor’s complaint:

– An acknowledgment letter will be sent to the investor within ten business days after receipt of the complaint where the complaint cannot be closed within these ten business days.
– The investor will be informed of the name of the person handling the complaint.
– An answer will be provided to the investor without undue delay. It must be handled within a period which will not exceed one month between the date of receipt of the complaint and the date at which the answer is sent. When an answer cannot be provided by the Complaint Handling Officer within this period, the Complaint Handling Officer informs the investor of the causes of delay and indicate a timeframe for resolution.

The Management Company informs the investors of the existence of the out-of-court dispute settlement procedure with the Commission de Surveillance du Secteur Financier (the “CSSF”).

This out-of-court resolution applies where the complainant did not receive a response or satisfactory response within one month of a complaint being submitted to the Management Company. In this case, the complainant can refer to the CSSF by the following means:

– Either by filling in the form (PDF or online) available at the following address: http://www.cssf.lu/en/consumer/complaints/
– Or by e-mail at [email protected]
– or by mail (simple mailing, no registered letter required) to the following address: CSSF, 283 route d’Arlon, L-2991 Luxembourg;
– or by fax sent at the following number: (352) 26 25 12601;
– or by e-mail at the following address: [email protected]

GDPR Request

If you wish to send a GDPR request, please send a email to [email protected] Please ensure that you indicate “GDPR Request” as the subject of your email and the appropriate subcategory of Deletion, Retrieval, or Rectification to indicate the specific GDPR rights you would like to exercise. Please provide the following information with your request (this part is important for us to be able to help you as quickly and accurately as possible):

  • First Name
  • Last Name
  • Street
  • Number
  • Zip Code
  • City
  • Country
  • E-mail
  • Fund Name
  • Telephone

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Conflict of Interests

Lemanik Asset Management SA is a management company under Chapter 15 of the Law of 17 December 2010, an AIFM under Chapter 2 of the Law of 2013 and we provide discretionary portfolio management services. We are therefore required to establish, implement and maintain an effective conflicts of interest policy.

The policy applies to us and our branches and representative offices.

We take all reasonable measures (i) to identify and manage conflicts of interest that arise when rendering services to our clients and (ii) maintain organisational arrangements and procedures to identify and manage relevant conflicts of interest.


Definition
A conflict of interest is a conflict that can arise in any area of business in which we provide services and that adversely affects the interests of one or more clients.

Circumstances

We take all reasonable steps to identify conflicts of interest that arise or may arise in the course of providing any services, between:

  • our company, including our managers, employees or any person directly or indirectly linked to us by control and the Funds or their investors, or
  • our company and a client, or
  • between a Fund or its investors and another Fund or its investors, or
  • between a Fund or its investors and another client, or
  • between two (or more) clients, considering that we are required to meet our obligations to each client.

Identification of conflicts of interest
For the purpose of identifying conflicts of interest that could arise in the course of providing investment services and/or ancillary services to a client, we consider situations where our company, a related person or a person directly or indirectly linked to us by control:

  • is likely to make a financial gain, or avoid a financial loss, at the expense of a client; • has an interest in the outcome of an activity provided to a client or of a transaction carried out on behalf of a client, which is distinct from the client’s interest in the outcome;
  • has a financial or other incentive to favour the interest of a client – over the interest of another client;
  • carries on the same business as a client; and/or
  • receives from, or gives to, a person other than the client an inducement in relation to a service provided to the client, in the form of monies, or a non-monetary benefit, other than the standard fee for that service.

Mechanisms to prevent and manage conflict of interest

We have put in place organisational and administrative mechanisms to identify, prevent, and manage conflicts of interest.

Conflict of interest register
We maintain and update regularly a conflict of interest register that records all known and proved conflicts of interests.

Disclosure
In case conflict of interest cannot be avoided, we ensure they are managed in the best interests of the managed funds/investors/clients.
In the unlikely event that a conflict of interest could not be managed, or in the event that mitigation measures taken do not enable us to properly manage the conflict of interest, we will report to investors by any appropriate medium.


Contact
Investors may request free of charge a copy of the policy at our registered office.

Chef

We are looking for a Senior Fund Risk Officer to join the AIFs Team.
Your mission will consist in being in charge of managing the Risk Management framework of several AIFs clients.

Your role

  • Assist the AIFs team in the implementation of the Risk Management Framework
  • Production of periodical reports
  • Perform risk assessment for existing and new AIFs, determination of risk profile, risk limits (market, credit, liquidity, counterparty, operational) at fund and investments level
  • Monitor the AIFs in DOMOS (AIFs control and reporting tool) and ensure data accuracy
  • Support the Head of Risk in various Risk Management topics
  • Review the existing risk framework (regulatory and internal requirements) in close cooperation with other departments
  • Monitor the liquidity of AIFs and perform stress tests
  • Provide regular updates to the Head of Risk and the governing body
  • Ensure that the general investment policy, the investment strategies and the risk limits of each AIF are properly implemented and complied with 

Skills required

  • Master’s degree in Engineering, Finance, Mathematics or related fields.
  • Have minimum 2 years of relevant risk senior position in the illiquid strategies
  • Have good knowledge and understanding of the Luxembourg fund industry and AIFM regulations
  • Have strong knowledge on various strategies (Real Estate, Private Equity, Private Debt…)
  • Ability to work autonomously and demonstrate initiative
  • Fluent in English any other language will be an asset