Employee compensation Policy
In order to ensure that it is not a source of risk to the management company, the objective of this policy is to promote sound and effective risk management by not encouraging risk-taking that is incompatible with risk profiles, the statutes Or constituent documents of the managed Sicavs.
Pergam’s compensation policy is consistent with the economic strategy, objectives, values and interests of managers and Sicavs managed or those of investors, and includes measures to avoid conflicts of interest.
Thus, this policy specifies the modalities for determining and remitting the overall allocation of remuneration allocated by management for a given year, to the collaborators concerned, this global envelope including the Fixed remuneration and variable remuneration.
The management company shall ensure that its financial situation is not adversely affected by the overall variable remuneration allocated for a given year and/or by the variable remuneration paid or acquired during the year.
The compensation policy has been set up to:
Actively support the strategy and objectives of the management company
Support the competitiveness of the management company in the market in which it operates;
Ensure the attractiveness, development and retention of motivated and qualified employees.
The criteria used by the management company for the evaluation of the performance of the persons concerned are accessible and understandable, by means of this policy.
A printed copy of this compensation policy is available free of charge upon request.
The principles of the Remuneration policy are revised on a regular basis, with annual minima, and adapted according to the regulatory evolution. The general management also ensures its respect and its correct application.
In accordance with the regulatory provisions, Pergam applies the principle of proportionality for the practical implementation of this compensation policy.
These rules are developed in such a way that the level of total variable remuneration awarded is linked to the wealth created by Pergam in the long term, and that these rules also allow for an alignment of interests between the management company and the Managed or advised OPC investors.
Pergam is based on the following principles to prevent risks to the management company and its customers:
The compensation policy is consistent with sound and effective risk management, promotes it and does not encourage risk-taking that would be inconsistent with the risk profiles, regulations or documents constituting the OPC that the manages or advises management;
The remuneration policy is in line with the economic strategy, objectives, values and interests of the management company and the mutual funds that it manages or advises and those of the investors in these mutual funds, and includes measures to avoid conflicts of interest;
The remuneration policy shall be adopted by the management body of the managing company in the exercise of its supervisory mission, which shall adopt and review at least once a year the general principles of the remuneration policy and shall be responsible for Their implementation and supervises it. The tasks referred to in this point shall be carried out on the one hand by members of the governing body of the management company concerned whose remuneration is validated by the Board of directors, and on the other hand by employees specialising in the Risk Management and compensation systems
The implementation of the remuneration policy shall be subject, at least once a year, to an internal evaluation which is intended to verify that it is in conformity with the remuneration policies and procedures adopted by the management body;
Staff engaged in control functions are remunerated according to the achievement of the objectives related to their duties, irrespective of the performance of the operating sectors that they control;
When the remuneration varies according to performance, its total amount is determined by combining the evaluation in relation to the performance of the individual and the operational unit or the OPC concerned and with regard to their risks with that of the results Of the management company in evaluating individual performance, taking into account financial and non-financial criteria;
The performance evaluation is part of a multi-year framework adapted to the recommended period of detention to investors of the OPC managed or advised by the management company, in order to ensure that it deals with the long-term performance of the OPC and On its investment risks and that the actual payment of performance-dependent components of remuneration is in the same period;
The guaranteed variable remuneration is exceptional, applies only in connection with the hiring of a new staff member and is limited to the first year of employment;
An appropriate balance is established between the fixed and variable components of the overall remuneration, the fixed component represents a sufficiently high share of the overall remuneration so that a fully flexible policy can be exercised in terms of Variable components of remuneration, including the possibility of paying no variable component;
Payments related to the early termination of a contract correspond to performance over time and are designed so as not to reward failure;
Performance measurement, when used as the basis for calculating variable components of individual or collective remuneration, includes a global adjustment mechanism that integrates all types of current and future relevant risks;
Variable remuneration is paid or acquired only if it is compatible with the financial situation of the management company as a whole and is justified by the performance of the operational unit, the OPC and the person concerned. The total amount of variable remuneration is generally considerably reduced when the management company or the OPC concerned registers poor or negative financial performance, taking into account both current remuneration and Reductions in payments of previously acquired amounts, including by means of malus or recovery devices;
Staff are required to undertake not to use personal coverage strategies or insurances related to compensation or liability to counteract the impact of alignment on the risk incorporated in its Compensation
Variable remuneration shall not be paid through instruments or methods which facilitate circumvention of the requirements laid down in this directive.
Implementation of the Principles
The application of the principles set out above is reflected in:
Identification of employees: for the sake of fairness and homogeneity of treatment, the Directorate-General has decided to extend the principles of this compensation policy to all employees of the management company;
The identification of the remuneration concerned: the fixed part and the variable part of the remuneration of the employees concerned. Dividends received by shareholders or remuneration in the form of profit-sharing from the management company are not within the scope of this policy;
The definition of the qualitative and quantitative criteria for allocating variable remuneration;
The definition of the persons responsible for the attribution of remuneration: the Directorate-General of Pergam and the Compensation committee meet annually, it is responsible for the preparation of compensation decisions, Particularly those that have an impact on the risk and risk management of the management company and the funds managed.
Voting Exercise Report
In accordance with article 314-101 of the AMF’s general regulations, PERGAM shall establish a report each year, four months after the end of its financial year, in which PERGAM reports on the application of its voting policy during the financial year ended.
However, since 4 March 2009, a management company which, in accordance with its voting policy, has exercised no rights during the financial year, is exempt from establishing the said report. PERGAM did not exercise any rights in the last fiscal year.
“Best Selection” policy
Investment Policy and ESG criteria (environment, SOCIAL, governance)
The OPC and the mandates managed by PERGAM do not at the same time take into account the social, environmental and quality of governance criteria in their investment policy.
All or part of these criteria may however be taken into account individually and/or on request in the context of a dedicated management.
Report on the costs of intermediation
Pursuant to the provisions of article 314-82 of the General Regulations of the Autorité des marchés financiers, PERGAM is not required to report on the costs of intermediation for the financial year 2019.
Conflict of Interest
PERGAM has established and maintains an operational procedure for the rapid and efficient processing of claims by its customers. Any claim can be sent by mail to PERGAM-49/51 Avenue George V-75008 Paris France or by email to email@example.com. The management company will acknowledge receipt of the claim within a maximum of ten working days from the date of receipt of the claim, unless the reply itself is made to the customer within that time limit. Unless duly substantiated special circumstances occur, it will provide a response to the customer within two months of receipt of the claim. In case of persistent disagreement, the client may contact a mediator including the AMF mediator. The contact details of the AMF Ombudsman are: Autorité des marchés Financiers, mediator of the AMF, 17 Place de la Bourse 75082 PARIS CEDEX 02. The request form for mediation with the AMF and the Charter of mediation are available on the website http://www.amf-france.org.
Concerning claims relating to the brokerage activity, the client may contact the supervisory Supervisory and resolution authority (PTA) DCPC/SIR 61 rue Taitbout 75536 Paris Cedex 09-Tél: + 33149954995//Fax: + 33149954041//@: firstname.lastname@example.org