investor relations

Corporate

Governance

COMPLAINTS MANAGEMENT POLICY
CONFLICTS OF INTEREST POLICY
INDUCEMENT POLICY
REMUNERATION POLICY
BEST EXECUTION POLICY
EXERCISE OF VOTING RIGHTS POLICY

Complaints Management Policy

The Company maintains a Complaints Management Policy. For more information regarding the Complaints Management Function at the Company and the procedure to be followed to file a complaint, please download our Policy.

 

 

Conflicts of Interest Policy

The Company employs a Conflict of Interest Policy that sets out to identify, manage and mitigate any potential conflicts that arise.

The key to making this Policy effective is transparency and early identification. Members of the Board of the Company and all staff members must declare their involvements quarterly. This ensures transparency and by disclosing such information, it ensures that conflicts are clearly identified and therefore mitigated in that respect.

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.

The Conflict of Interest Policy is reviewed annually or whenever the need arises.

For further information on the Company’s Conflict of Interest Policy, kindly contact us on info@praude.com.mt or download our Policy

Extract of Inducement Policy

The Inducement Policy sets out to manage the Company’s arrangements with respect to any fees, commission or non-monetary benefit paid or provided to by the Company for investment management or ancillary services. The Company must always act honestly, fairly and professionally in accordance with the best interest of a client and therefore this inducement policy sets out the parameter within which the Company may pay out or receive inducements which are in line with the applicable EU Directives and MFSA Rules.

Inducements procedures are in addition to the rules on Conflicts of Interest, therefore the Company cannot rely solely on its general Conflicts of Interest Policy for the purpose of inducement rules. The Conflicts of Interest and Inducement Policy are complementary and are not substitutes or alternatives. The Inducement Policy is applicable to payments to or by legal entities outside Praude Asset Management Limited and the policy is in line with the applicable Directives and MFSA rules. The Inducement Policy is reviewed annually or whenever the need arises.

The Policy sets out the legal requirements regarding inducements and the Company’s principles.

For further information on the Company’s Inducement Policy, kindly contact us on info@praude.com.mt.

Remuneration Policy

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. 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.

The Policy takes into account the nature, scale and complexity of its business; the type of Client, the type of investments, the investment strategies, the investment location, the distribution model and investor base. Due consideration is also given to the resources available within the Company and the resources and expertise of the various third parties engaged to support the Company and carry out certain functions in its behalf.

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 key areas of the Policy seek to identify individuals whose professional activities have a material impact on the risk profiles of the Company and the clients it manages including: i) Board of Directors of the Company; ii) Senior Management and iii) Portfolio Managers. Other staff that are considered risk takers whereby all staff members whose professional activities either individually or collectively can exert material influence on the risk profiles of the Company or of a UCITS it manages. The Board approves the list of identified staff annually and individuals are notified of their identification and the implications of this status. It then takes into account the link between pay and performance for these individuals, which is based on a number of factors including but not limited to, the performance of the client, the overall results of the Company and the employee’s commitment to the team.

Remuneration in relation to sustainability risks

In accordance with the Company’s ESG Policy there are no incentives to engage in investments which pose sustainability risks.

Remuneration Structure

The Policy also includes a detailed description of the types of remuneration, namely fixed and variable remuneration. Whereas the fixed remuneration is fairly straightforward, the Policy goes into detail on the variable remuneration, dedicating a section to the structure of the annual bonuses available to certain staff.

Due to the proportionality principal the Company does not adopt any deferral or equity measures.  Guaranteed variable remuneration is granted only in exceptional cases to attract highly specialised individuals. In accordance with regulatory requirements such pay will be granted only in the case of hiring new staff and for a maximum period of one year.

Remuneration type Pay element What It does Key measures
Fixed Base Salary Provides competitive fixed pay. Experience, seniority, education, job complexity, duties and scope of responsibility.
Internal and external market factors.
Variable Annual Cash Bonus Provides a competitive annual cash incentive opportunity to motivate and reward high performers. Based on annual financial results, individual conduct and performance as well as the company’s and the Client’s progress against long term strategy, strengthen long term customer relations and generate income and shareholder value to the Clients of the Company.

Exercise of Voting Rights Policy

It is the Company’s duty to exercise the voting rights of the securities held by it’s clients, in the best interes of the clients. The Company has therefore developed a Proxy Voting Policy to implement a strategy to determine when and how to exercise the voting rights of such securities. Please access our Policy here.