Information about the Remuneration Policy

Casa4Funds SA qualifies as a regulated investment fund manager (“IFM”) authorized for the management of undertaking for collective investment on transferable securities (“UCITS”) and alternative investment funds (“AIFs”) (jointly hereafter referred to as the “Funds”).

The IFM’s Executive Committee has established a remuneration policy (the “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 financial undertakings as well as all staff members carrying out independent control functions, whose objectives are:

  1. To ensure that the remuneration is in line with the applicable laws and regulations, and more specifically with the provisions defined under:
  • Article 388 of the CSSF Circular 18/698 providing that every IFM must implement a remuneration policy in compliance with Articles 111a and 111b of the 2010 Law and/or Article 12 of the 2013 Law respectively;
  • the UCITS Directive 2014/91/EU (“UCITS V”), implemented by the Luxembourg law dated 17 December 2010 (the “2010 Law”) as amended from time to time; the Alternative Investment Fund Managers Directive 2011/61/EU (“AIFMD”), transposed into the Luxembourg AIFM Law dated from 12 July 2013 (the “2013 Law”), as amended from time to time,
  • the CSSF Circular 10/437 on guidelines concerning the remuneration policies in the financial sector issued on 1st February 2010;
  • the ESMA Guidelines on sound remuneration policies under the UCITS Directive and AIFMD dated 31 March 2016 (the “Guidelines”) as amended;
  • the Regulation EU 2019/2088 on sustainability-related disclosures in the financial services sector (“SFDR”)
  1. To comply with Casa4Funds SA remuneration policy practices which aim to:
  • ensure consistency with and promotion of sound and effective risk management to avoid excessive risk taking;
  • ensure that remuneration is in line with the business strategy, objectives, values, sustainable development principles and the interests of Casa4Funds SA and the Funds it manages or the investors of such Funds;
  • not encourage riskÔÇÉtaking which is inconsistent with the risk profiles, rules or articles of incorporation or management regulations of the Funds Casa4Funds SA manages;
  • not encourage excessive risk-taking with respect to the sustainability risks and link the remuneration structure to a risk-adjusted performance;
  • avoid or manage conflicts of interest.

The Policy applies to all remuneration paid either by the Management Company or by the Funds themselves.

The Company has elected to apply the proportionality principle as provided by the Guidelines, and the 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.

The Policy seeks appropriate balance between fixed and variable remuneration elements in line with the business strategy, objective, value and interest of Casa4Funds SA.

The Company’s annual report shall disclose the aggregate remuneration paid by the Management Company and by the UCITS according to UCITS V applicable rules and market practice.

The Funds’ Shareholders may request free of charge additional information by writing to:


Casa4Funds SA

Attention: Compliance Department

44 rue de la Vallée, L-2661 Luxembourg


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